IR 05000528/1997021
| ML17312B625 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/07/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17312B624 | List: |
| References | |
| 50-528-97-21, 50-529-97-21, 50-530-97-21, NUDOCS 9708130253 | |
| Download: ML17312B625 (32) | |
Text
ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates; Inspector:
Approved By:
50-528 50-529 50-530 NPF-41 NPF-51 NPF-74 50-528/97-21 50-529/97-21 50-530/97-21 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona June 30 through July 3, 1997 Thomas H. Andrews Jr., Radiation Specialist Plant Support Branch Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENT:
Supplemental Information 9708i30253 970807 PDR ADQCK 05000528
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-2-EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report 50-528/97-21; 50-529/97-21; 50-530/97-21 A routine, announced inspection of the operational status of the licensee's emergency preparedness program was conducted.
The inspection included the following areas:
emergency plan and implementing procedures, emergency facilities and equipment, organization and management control, training, audits, and effectiveness of licensee controls.
Emphasis was placed on changes that had occurred since the last routine emergency preparedness inspection.
Plant Su ort
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Emergency events were correctly classified.
A noncited violation was identified related to a late notification of offsite agencies during an actual event (Section P1).
Emergency response facilities, equipment, instrumentation, and supplies were operationally maintained.
Emergency kit inventories were not always performed as required and the inventory results were not reviewed on a timely basis.
A noncited violation was identified related to inventory of the soil sampling kit (Section P2).
Program changes were appropriately incorporated into the emergency plan and procedures.
Emergency action levels were reviewed with offsite agencies as required.
Documentation was detailed and retrievable.
A noncited violation was identified for failure to submit emergency plan procedures to the NRC within 30 days of change (Section P3).
Overall, shift crew performance during the simulator walkthroughs was satisfactory.
Plant conditions were promptly recognized and classified, and offsite agency notifications were timely. The self-critique process was effective (Section P4).,
Emergency response personnel were trained in accordance with the emergency plan, and required drills were performed.
Inconsistent wording in the emergency plan regarding the scope and content of onsite and offsite radiological monitoring drills was identified (Section P5).
Changes to the emergency response department organization did not adversely impact the implementation of the program.
Offsite agreement letters were reviewed and certified as required.
All agreements were current (Section P6).
An effective audit of the emergency preparedness program was performed by knowledgeable individuals.
The offsite interface was effectively evaluated.
The 1997 audit was critical in that it identified ineffective corrective actions (Section P7).
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-3-Re ort Details IV. Plant Su ort P1 Conduct of Emergency Preparedness Activities a.
Ins ection Sco e 93702 The inspector reviewed event notifications made since November 27, 1995, to determine if events were properly classified.
b.
Observations and Findin s Licensee documentation related to the following actual declared emergency events was reviewed to ensure notifications were made in a correct and timely manner.
The inspector reviewed notifications to the NRC Operations Center since November 27, 1995, and determined that events were appropriately classified.
February 25, 1996, Unit 1, notification of unusual event due to a suspected lightning strike (NRC Event 30026).
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April 4, 1996, Unit 2, alert due to'
fire in a lighting panel in the control room (NRC Event 30236).
March 6, 1997, Unit 3, notification of unusual event due to a partial spent fuel pool drain down (NRC Event 31902).
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April 21, 1997, Unit 2, notification of unusual event due to pressurizer main spray valve leak (NRC Event 32190).
With one exception, notifications to offsite agencies for the above events were made in a correct and timely manner.
The form used to document the notifications for the February 25, 1996, notification of unusual event contained information indicating state and local officials were notified 18 minutes after the notification of unusual event was declared.
The notification form used was an event termination form. The event was declared at 8:32 p.m., terminated at 8:46 p.m., and the notifications were documented as made at 8:50 p.m.
Following the event, personnel in the emergency planning department questioned the notification times, but there was no documentation on file showing how the questions were addressed.
Procedure 16IG-OEP053, "Emergency Message Forms," Revision 2, required notification of state and local agencies within 15 minute f l
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-4-The licensee hypothesized that the event was terminated about the time the communicator had completed filling out the notification form. When the event was terminated, the information was transferred to the termination form. The communicator then made the state and local agency notifications with the completed and approved termination form. It was not known if the communicator logged the time the call was initiated or completed.
After this event, the licensee conducted training for communicators related to the proper method for completion of notification and termination forms.
The inspector confirmed there had not been any other instances since this event where notifications to state and local agencies were late.
The inspector concluded that the licensee had implemented proper corrective actions to this issue.
Based upon the information provided by the licensee, the inspector concluded the notification was made later than the 15 minutes allowed and was a violation of the licensee's procedure.
The violation was licensee-identified, non-repetitive, and corrected within a reasonable time. Accordingly, the violation is being treated as a noncited, violation consistent with Section VII.B.1 of the NRC Enforcement Policy (50-258;-529;-530/9721-01
).
c.
Conclusions Events were correctly classified.
A noncited violation was identified related to a late notification of offsite agencies during an actual event.
P2 Status of Emergency Preparedness Facilities, Equipment, and Resources aO Ins ection Sco e 82701-02.02 The inspector reviewed the status of emergency response facilities, equipment, instrumentation, and supplies to ensure they were maintained in a state of operational readiness.
The inspector toured the following facilities:
Control rooms Satellite technical support centers Remote shutdown panels Operations support centers Technical support center Emergency operations facility
-5-b:
Observations and Findin s During the tour, the inspector made the following observations:
There were eight self-contained breathing apparatuses with bottles in storage cases located in each control room.
Each storage case had a medium face piece.
There was one small and one large face piece stored in the rack with the storage cases.
The inspector determined that on-shift personnel were cognizant of the location of the small and large face pieces.
One shift supervisor demonstrated good foresight by having already determined that an adequate supply of appropriately sized face pieces was available.
The inspector observed operators on-shift who were required to wear
'orrective lenses.
Operations personnel, who were required to have corrective lenses as a condition of their license, demonstrated they maintained the corrective lens insert for respirators in a location where it could be obtained quickly.
Documentation on each of the storage cases indicated the self-contained breathing apparatus and face pieces were inspected on a regular basis.
The inspector observed one of the small face pieces was stored on its side.
This was not considered to be a proper orientation for storage and may have impacted the shape of the sealing surface.
The licensee quickly inspected the face piece for deformation, then oriented it properly.
While touring the battery room for the technical support center, the inspector noted two of the batteries were approximately three-quarters of an inch taller than the remaining batteries.
The batteries were all from the same manufacturer, same model number; and same capacity rating.
However, the two larger batteries had a newer manufacturing date.
The inspector asked if this difference had been identified and reviewed.
The licensee stated that no review was performed because the batteries were not quality-related components.
However, the licensee assured the inspector that if it had been a quality-related component then a review would have been performed.
The licensee further stated the equipment powered by these batteries was not covered by the maintenance rule.
During the tour of the technical support center, the inspector questioned the location used for air sampling in the facility. The technical support center had been modified to have an enclosed central area for key personnel, and a space available for a library and work area for support personnel surrounding the center.
The air sampling location was within the closed-in area.
The licensee stated they would evaluate the need for additional sampling or the need to relocate the air sampling locatio I
-6-The inspector found all emergency response facilities contained necessary communications equipment, supplies, and procedures.
The inspector examined the content of facility emergency equipment lockers and offsite field team kits. The kits and lockers contained appropriate items, such as calibrated survey instruments, dosimeters, and potassium iodide.
Respirator face pieces (various sizes) were stored in the facilities. The inspector determined the emergency response facilities were operationally maintained.
The inspector reviewed emergency equipment inventory records for emergency facilities. All equipment inventories were conducted as required with the following exceptions:
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There were no records of inventory for the soil sampling kit.
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The inventory of the kit located in the site emergency medical facility was not performed during the second quarter of 1996.
The licensee performed a soil sampling kit inventory and determined all of the equipment was present.
The licensee issued a condition report disposition request to initiate an investigation for the reason why the inventory had not been documented.
The site emergency medical facility emergency kit was inventoried two times during the third quarter of 1996.
The licensee speculated that the second quarter inventory was performed late.
The failure to perform these inventories was a violation of the licensee's emergency kit inventory procedure and of the emergency plan.'ecause the licensee demonstrated the required materials were available, the inspector determined the safety significance of this situation was minor. Therefore, the inspector concluded that there was no actual radiological safety consequence associated with.this item.
This failure constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (50-528;-529;-530/9721-02).
The inspector examined the process used to schedule and document emergency kit inventories.
Specific individuals were assigned the responsibility for inventorying particular emergency kits. A tracking system was used to ensure the inventories were performed each quarter.
The inspector. noted there was often a substantial time lag between the time an inventory was performed and when it was reviewed by the responsible individual.
In one instance, the review was performed more than 3 months after the inventory
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-7-had been performed.
The inspector questioned the need for a review if it was not timely. The licensee stated they would evaluate alternatives related to improving the timeliness of emergency kit inventory reviews.
The inspector determined that if conditions identified were not corrected, untimely reviews would not aid in correcting the problem.
C.
Conclusions Emergency response facilities, equipment, instrumentation, and supplies were operationally maintained.
Emergency kit inventories were not always performed as required and were not reviewed on a timely basis.
A noncited violation was identified related to inventory of the soil sampling kit.
P3 Emergency Preparedness Procedures and Documentation a.
Ins ection Sco e 82701-02.01 The inspector used Inspection Procedure 82701 to determine whether the emergency plan and procedures were maintained.
b.
Observations and Findin s The inspector reviewed portions of the emergency plan and selected emergency plan procedures and found program changes were appropriately incorporated.
During a review of Audit Report 97-003, which was conducted during February 1997, the inspector noted the licensee discovered 14 instances in 1996 where emergency plan procedures were not transmitted to the NRC within 30 days of implementing changes.
A similar finding was made during Audit Report 96-001, involving one example of late submittal of an emergency plan procedure.
Appendix E to 10 CFR Part 50 requires, "Licensees who are authorized to.operate a
nuclear power facility shall submit any changes to the emergency plan or procedures to the Commission, as specified in 5 50.4, within 30 days of such changes."
The licensee identified that an oversight method to track submittals to the NRC had not been developed.
Corrective actions resulting from the investigation included development of a tracking process.
The inspector reviewed the licensee's tracking program and noted that 1997 submittals had been made in a timely manner after the tracking process was implemented.
According to information contained in the 1996 audit report, a condition report disposition request was issued. based on the finding in the 1996 audit.
This condition report disposition request was closed based on actions taken at the time
-8-of the audit.
The reason the procedure was not provided to the NRC within 30 days was that a copy of the procedure was not distributed to Nuclear Regulatory Affairs. Therefore, Nuclear Regulatory Affairs did not know that the procedure had been revised and needed to.be sent to the NRC per 10 CFR Part 50.4.
Emergency plan procedures were converted to department procedures and instructional guides in June 1996.
When these procedures were revised, they were forwarded to Nuclear Regulatory Affairs. However, because of the change in numbering, personnel in Nuclear Regulatory Affairs did not recognize that these procedures were required to be submitted to the NRC by 10 CFR Part 50.4.
There were seven procedures which were not transmitted within 30 days.
There were seven subsequent revisions to these procedures that also were not transmitted to the NRC within 30 days.
The inspector confirmed that the procedures. had been transmitted to the NRC in a timely manner after this issue was identified.
'he inspector determined the failure to submit emergency plan procedures to the NRC within 30 days of change was a violation of 10 CFR Part 50, Appendix E. As stated, there was one example identified that occurred in 1995, and 14 examples identified that occurred in 1996.
The root cause of the 1995 example was not the same as the root cause for the 1996 examples.
The inspector concluded that corrective actions taken for the 1995 incident would not have prevented the violation from reccurring and, therefore, was not repetitive.
The inspector concluded corrective actions taken following the 1997 audit had been effective.
The violation was licensee identified; non-repetitive, and corrected within a reasonable time. Accordingly, the violation is being treated as a noncited, violation consistent with Section VII.B.1 of the NRC Enforcement Policy (50-258;-529;-530/9721-03).
The inspector examined the licensee's process for reviewing emergency action levels with offsite authorities.
In accordance with Appendix E.IV.&of 10 CFR Part 50, these reviews are required annually and upon revision.
The licensee maintained detailed and retrievable records to show the required reviews were conducted.
The records included documentation from the offsite authorities confirming the review.
Conclusions Program changes were appropriately incorporated into the emergency plan and procedures.
Emergency action levels were reviewed with offsite agencies as required.
Documentation was detailed and retrievable.
A noncited violation was identified for failure to submit emergency plan procedures to the NRC within 30 days of chang P4 Staff Knowledge and Performance in Emergency Preparedness a.
Ins ection Sco e 82701-02.01 The inspector conducted walkthroughs with two operating crews using a dynamic simulation on the plant-specific control room simulator, During the walkthroughs, the licensee was evaluated on the ability to:
Evaluate plant conditions Identify respective emergency action levels Evaluate or, where appropriate, perform dose calculations Classify the emergency using the latest procedures Recommend appropriate protective actions Make timely notifications to offsite agencies The scenario consisted of a sequence of events requiring escalation of emergency classifications, culminating in a general emergency.
Each walkthrough lasted approximately 90 minutes.
b, Observations and Findin s There were two scenarios used; one for each operating crew.
One scenario was based on a steam generator tube leak, and the other scenario was based on a loss-of-coolant accident.
In the first scenario, a 30 gallon per minute steam generator tube leak resulted in declaration of an notification of unusual event.
The 2A reactor coolant pump seized, followed by a failure of the reactor to trip. The failure to trip resulted in upgrading to an alert.
The steam generator tube leak increased and a main steam safety valve stuck open, giving a release path.
This resulted in declaration of a site area emergency.
Site boundary dose assessments resulted in escalation to a general emergency.
In the second scenario, a 30 gallon per minute reactor coolant system leak resulted in declaration of a notification of unusual event.
A control element assembly dropped into the core and a failure to trip resulted in escalation to an alert.
The reactor coolant system leak rate increased to greater than 44 gallons per minute and evidence of fuel failure was observed, resulting in escalation to a site area emergency.
The reactor coolant system continued to degrade resulting in a loss of subcooling, and generation of safety injection, containment isolation, main steam isolation, and containment spray actuation signals.
The "B" containment spray pump failed to start, and the "A" containment spray pump was out of service, resulting in a loss of containment spray.
This resulted in the escalation to a general emergenc '4
-10-Overall, shift crew performance during the simulator walkthroughs was good.
Plant conditions were promptly recognized and classified, protective action recommendations were performed and offsite agency notifications were timely.
Command and control during the scenarios was good.
Both crews consistently used three-part communications.
Three-part communications involve:
(1) information communicated by provider, (2) information restated by the receiver, and (3) information confirmed by the provider.
Three-part communications were also consistently used within the satellite technical support center.
The critique after each walkthrough was performed in three steps.
The controllers/
evaluators met to consolidate comments and observations, then they met with key participating management to discuss the results and to gather additional information.
Finally, they met with all the players to critique the performance.
The inspector observed a very thorough critique of the performance during the walkthrough.
c.
Conclusions Overall, shift crew performance during the simulator walkthroughs was good.
Plant conditions were promptly recognized and classified, and offsite agency notifications were timely. The self-critique process was effective.
P5 Staff Training and Qualification in Emergency Preparedness a.
Ins ection Sco e 82701-02.04 The inspector reviewed training records for selected individuals and records and documents associated with emergency drills/exercises.
b.
Observations and Findin s The inspector reviewed training records to ensure emergency response personnel received training required.
The records indicated the training program was properly implemented.
The inspector reviewed the licensee's drill and exercise program, including completion of required specialty drill (e.g., post-accident sampling system, radiological monitoring, and health physics drills) documentation, and drill/exercise objective matrix (objectives tested over a 6-year period).
During the review, the inspector identified an inconsistency between the licensee's documentation and the emergency pla ii
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-11-Section 8.1.3 of the emergency plan described the various types of drills which are to be conducted on a routine basis.
One'paragraph stated, "Radiological Monitoring Drills are conducted annually for both onsite and offsite survey team personnel."
The licensee had only performed an onsite survey team drill in 1996.
The licensee stated offsite monitoring was performed by the State of Arizona; however, they did not retain any documentation to demonstrate a drill was performed by the offsite survey team.
The emergency plan contained multiple references to "onsite/offsite monitoring teams."
This implied these teams were the same, but performed monitoring in different locations.
This was consistent with the licensee's implementation process.
The licensee also provided information indicating the definitions of onsite sometimes referred to within the protected area and sometimes referred to the owner controlled area.
Because of confusion related to interpretation of what was meant by "onsite and offsite monitoring teams," the inspector determined the licensee had assessed the performance of its team based upon the narrow interpretation.
The licensee stated the emergency plan was being reviewed and they would clarify wording to ensure consistent interpretation.
The inspector considered that the licensee's response was satisfactory.
During a review of the onsite survey team report for 1996, the inspector noted the scenario stated both vegetation and soil samples would be taken during the drill.
The report only discussed the taking of soil samples.
When questioned, the licensee was able to locate supporting information showing vegetation samples had been taken.
The inspector concluded the drill was conducted appropriately, but documentation of drill results was incomplete.
The report further stated the analysis of samples was simulated.
According to the emergency plan, the radiological monitoring drill include the "collection and analysis" of the sampled media.
The licensee stated this was simulated since collection and analysis of soil and vegetation samples was a routine part of the environmen'tal monitoring program.
The same laboratory that evaluates the environmental samples would monitor the samples taken during the radiological monitoring drill. The inspector concluded the licensee's logic was good, but noted the process appeared to be inconsistent with the emergency plan.
The licensee stated it would review potential changes to address this issue.
This response was satisfactory.
Conclusions Emergency response personnel were trained in accordance with the emergency plan, and required drills were performed.
Inconsistent wording in the emergency plan regarding the scope and content of onsite and offsite radiological monitoring.,'; ',.
drills was identifie ~i e
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-1 2-P6'mergency'Preparedness Organization and Administration a.
Ins ection Sco e 82701-02.03 The inspector reviewed:
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Emergency planning organization changes
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Changes in offsite support organization agreements b.,
Observations and Findin s The major change involving the emergency planning organization occurred in 1996 when security, fire protection, emergency services programs, industrial health and safety, and emergency planning were combined to form the emergency services division. The inspector determined that the impact to the emergency planning department was minimal and did not affect staffing or primary duties within the department.
The inspector reviewed the licensee's process for maintaining current letters of agreement with offsite support organizations.
The licensee's emergency plan stated the agreement letters were reviewed annually.
The inspector determined offsite agreements were reviewed and certified in accordance with the emergency plan.
All offsite agreements were current.
c.
Conclusions Changes to the emergency response department organization did not adversely impact the implementation of the program.
Offsite agreement letters were reviewed and certified as required.
All agreements were current.
P7 Quality Assurance in Emergency Preparedness Activities a.
Ins ection Sco e 82701-02.05 Using Inspection Procedure 82701, the inspector examined the latest emergency preparedness program audit reports to determine compliance with NRC requirements and licensee commitments.
b.
Observations and Findin s The inspector reviewed the program audits performed in 1996 and 1997.
The audits were performed by knowledgeable personnel, including a technical specialist from other licensees.
The 1997 report was very critical of the corrective action process used by the emergency planning grou The findings included a review of management controls and corrective actions associated with problems identified during exercises and actual events.
According to the audit report, previous findings were closed based upon the understanding of the issue rather than upon actual corrective actions.
According to the 1997 audit, the evaluators reviewed previous audit findings and determined that a trend of non-corrective action had existed for several audits.
Reviews of exercise and drill findings indicated that there was a repetitive nature associated with issues identified.
The audit determined that corrective actions were not effective to correct previously identified problems.
The inspector reviewed the 1997 audit findings to determine regulatory significance.
Based upon this review, the inspector determined that the most significant issue was the failure to submit emergency plan procedures to the NRC within 30 days per 10 CFR Part 50.4.
This was discussed in Section P3.
As a result of the audit finding, the licensee initiated several comprehensive corrective actions, including a root-cause determination, contributing 'factors, and a course of action to address the problems.
The root cause was attributed to ineffective management oversight of the emergency preparedness program.
A casual factor for this was that the self assessment program was not fully implemented.
Corrective actions included fully implementing the self assessment program.
This included adding performance indicators, regular monitoring intervals, and tracking of issues to closure.
These indicators were added to the key performance indicators provided to management on a regular basis.
The audit team evaluated the offsite interface as part of the audit.
The evaluation included meeting with key individuals from offsite agencies.
The audit team characterized the interface with offsite officials as a strength.
The inspector noted that the 1997 audit report was classified as containing proprietary and confidential information.
The inspector requested the licensee to identify the portions of the report that contained the proprietary and confidential information: After further review, the licensee determined that the report did not contain proprietary or confidential information.
The inspector confirmed that the audit results concerning the offsite interface were transmitted to offsite officials and that.the transmittal was not impacted by the erroneous classification of the material.
The inspector concluded the audit was conducted in accordance with regulatory requirements by knowledgeable individuals.
The offsite interface was effectively evaluated and the licensee made the evaluation available to offsite authoritie '
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Conclusions The audit scope met regulatory requirements and was performed by knowledgeable individuals.
The offsite interface was effectively evaluated.
The 1997 audit was critical in that it identified ineffective corrective actions.
V. IVlana ement IVleetin s X1 Exit Meeting Summary The lead inspector presented the inspection results to members of licensee management at the conclusion of the inspection on July 3, 1997.
The licensee acknowledged the findings presented.
No proprietary information was identifie ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee T. Barsuk, Senior Coordinator, Emergency Planning H. Bieling, Program Leader, Emergency Planning R. Duncan, Coordinator, Emergency Planning D, Larkin, Senior Engineer, Nuclear Regulatory Affairs J. Neilson, Evaluator, Nuclear Assurance NRC F. Brush, Senior Resident Inspector (Acting)
D. Carter, Resident Inspector LIST OF INSPECTION PROCEDURES USED 82701 93702 Operational Status of the Emergency Preparedness Program Prompt Onsite Response to Events at Operating Reactors LIST OF ITEMS OPENED
~Oened 50-528; 50-529;50-530/9721-01 NCV.Late notification of state and local officials during February 25, 1996 notification of unusual event 50-528; 50-529;50-530/9721-02 NCV Failure to perform emergency kit inventories 50-528; 50-529;50-530/9721-03 NCV Failure to submit emergency plan procedures to the NRC within 30 days of change LIST OF ITEMS CLOSED Closed 50-528; 50-529;50-530/9721-01 NCV Late notification of state and local officials during February 25, 1996 notification of unusual event 50-528; 50-529;50-530/9721-02 NCV Failure to perform emergency kit inventories
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-2-50-528; 50-529;50-530/9721-03 NCV Failure to submit emergency plan procedures to the NRC within 30 days of changes LIST OF DOCUMENTS REVIEWED De artmental Procedures and Instructional Guides 1 6DP-OEP1 3 16DP-OEP14 1 6IG-OEP01 2 1 6IG-OEP041 1 6IG-OEP053 1 6IG-OEP1 61 Other Documents Emergency Classification Satellite Technical Support Center Actions Assembly Dose Projections Emergency Message Forms Protective Actions Revision 0 Revision
Revision
Revision 0 Revision 2 Revision
Palo Verde Nuclear Generating Station Emergency Plan, Revision 18 PASS Drill Report (96-D-PSS-06007),
June 14, 1996 Onsite Environmental Sampling Drill Report 96-D-ENV-11012, February 13, 1997 1996 Assembly, Accountability Drill Report, December 13, 1996 HP Air Sampler Drill Report 96-D-ENV-11013, February 13, 1997 1997 Emergency Preparedness Exercise 97-E-AEV-05003, June 19, 1997 1997 PVNGS Full-Scale Drill 97-D-FSD-05002 Final Report, June 19, 1997 Audit Report 96-001, "Emergency Planning" Audit Report 97-003, "Emergency Planning"
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