ML17299A773
| ML17299A773 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/12/1985 |
| From: | Licitra E Office of Nuclear Reactor Regulation |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8511270291 | |
| Download: ML17299A773 (22) | |
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Docket Nos.:
50-528, 50-529 and 50-530 t
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 RECBVZD NiK l38S NOY l8 PH
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MEMORANDUM FOR:
Dennis Kirsch, SALP aboard
- Chairman, Deputy Director, Division 'of Reactor Safety and Projects, Region V
Thomas M. Novak, Assistant Director for Licensing, Division of Licensing, NRR George W. Knighton, Chief, Licensing Branch No. 3, Division of Licensing, NRR E. A. Licitra,'roject Manager, Licensing Branch No.
3 Division of Licensing, NRR SUBJECT'RR SALP INPUT FOR PALO VERDE, UNITS 1, 2 AND 3 FOR THE REPORT PERIOD FROM APRIL 1, 1984 THROUGH SEPTEMBER 30, 1985 The enclosed report provides NRR's input to the SALP Report for Palo Verde, Units 1, 2 and 3, covering ANPP licensing activities from April 1, 1984 through September 30, 1985.
The overall performance of ANPP in the functional area of licensing activities is at a Category 2 level, which is the same level given in the previous SALP report.
Enclosure:
As stated cc:
H. Denton D. Eisenhut H. Th'ompson F. Miraglia R. Bernero W. Russell J. Knight E. A. Licitra, Project Manager Licensing Branch No.
3 Division of Licensing, NRR 8511270291 85010112 8
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos.:
50-528, 50-529 and 50-530
Subject:
Facility:
Licensee:
NRR Input to SALP Report Palo Verde Nuclear Generating Station, Units 1, 2 and 3
Arizona Public Service Company (Arizona Nuclear Power Project)
Evaluation Period:
April 1, 1984 through September 30, 1985 NRR Project Manager:
E. A. Licitra, Licensing Branch No.
3 I.
INTRODUCTION This report presents the results of the Systematic Assessment of Licensee Performance (SALP) for the Arizona Nuclear Power Project (ANPP or licensee) in the functional area of licensing activities for Palo Verde, Units 1, 2
and 3.
It provides NRR's input to the SALP report, in accordance with NRC Manual Chapter 0516 and NRR Office Letter No. 34, for the evaluation period from April 1, 1984 through September 30, 1985.
Other functional areas are evaluated by Region V.
Most of the licensing activities during this evaluation period were associated with Palo Verde Unit 1.
However, this report is an evaluation of ANPP performance for all three units.
II.
CRITERIA AND
SUMMARY
NRC Manual Chapter 0516 identifies seven performance criteria with characteristic attributes.
- Although, some of these criteria are not directly applicable to the NRR evaluation of licensing activities, input is provided for all criteria.
More than 35 individual SALP inputs were prepared by reviewers for 18 specific licensing activities conducted during the evaluation period.
Based on these SALP inputs and an evaluation performed by NRR project management, the ANPP performance with respect to licensing activities is as follows for the seven performance criteria:
1.
Management Involvement and Control in Assuring guality Category 2
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Approach to Resolution of Technical Issues from a Safety Standpoint 3.
Responsiveness to NRC Initiatives 4.
Enforcement History 5.
Reporting and Analysis of Reportable Events 6.
Staffing
( Including Management) 7.
Training and gualification Effectiveness Category 2
Category 2
Category 2
Category 2
Category 2
Category 2
The overall ANPP performance in the functional area of licensing activities is rated at the Category 2 level.
This performance rating of ANPP is the same as for the last SALP reporting
" period (March 1, 1983 through March 31, 1984).
ANPP's continued performance at this level is attributed to the following; (1) the transition from construction to operation for Palo Verde Unit 1, (2)
ANPP is concurrently involved with operation of one unit and the construction and testing of two other units at the site, and (3) Palo Verde Unit 1 is the first CESSAR System 80 plant to operate and is ANPP's first nuclear facility.
NRR comments regarding the subject of housekeeping and control room behavior are provided in Part IV of this report.
III. PERFORMANCE ANALYSIS The NRC licensing activities during the evaluation period included the following actions:
Unit 1 Low,Power License NPF-34, December 31, 1984 Amendment No.
1 to NPF-34, May 10, 1985 Unit 1 Full Power License NPF-41, June 1,
1985 Amendment No.
1 to NPF-41, August 5, 1985 In support of these actions, the staff issued safety evaluations including the following three supplements to the Palo Verde SER for Unit 1 licensing:
SSER 6 - Low Power Licensing Matters (October 1984)
SSER 7 - Low Power Licensing Matters (December 1984)
SSER 8 - Full Power Licensing Matters (May 1985)
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~f I P IN The specific licensing activities covered by the evaluation period are listed bel ow:
1.
Pressure Temperature Limits 2.
Instrumentation and Control 3.
ICCI System 4.
Technical Specifications 5.
Core Protection Calculator 6.
Equipment gualification 7.
Shift Staffing 8.
Accident Analyses 9.
Spray Pond Corrosion l0.
Core Performance 11.
SALEM ATWS 12.
Containment Systems 13.
Fire Protection 14.
Control Room Design 15.
PASS 16.
Auxiliary Spray System 17.
Licensee gualification 18.
Chemistry Control The above licensing activities vary with respect to their safety significance and the amount of staff and licensee effort associated with each activity during the evaluation period.
These factors were taken into consideration when evaluating the licensee with respect to the performance criteria.
Present below is the NRR detailed evaluation of licensing activities with respect to the applicable criteria from NRC Manual Chapter 0516.
(I)
Manaqement Involvement and Control in Assuring Oualit Management involvement and control in assuring quality for licensing activities was evident in a number of areas.
ANPP management was aware of the importance of such programs as development of technical specifications and environmental qualification, and took steps to assure that issues were satisfactorily resolved.
Management was also involved in resolving issues relating to fire protection.
- However, a number of those issues were submitted for staff review within the last two month period proceeding the issuance of a low power license for Palo Verde Unit 1.
Management participation and involvement were evident in various meetings with the staff and during several site visits by NRR management, the ACRS and the Commissioners.
Decision making for licensing activities was usually done at a level that ensures adequate management review and these reviews were generally timely, thorough and technically sound.
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After licensing of Palo Verde Unit 1, two issues arose which appear to indicate a lack of proper management attention.
One concerns the operability of the post accident sampling system (PASS) under postulated accident conditions.
Although ANPP had installed and declared the system operable for that purpose, there was little evidence that ANPP had evaluated the capability for obtaining a sample at the installed location for a projected high radiation environment.
Upon further evaluation, it was determined that the ability to take a sample within the dose guidelines of GDC 19 at the installed location was questionable.
As a result, ANPP has recently submitted a proposed FSAR change to correct this deficiency.
The second issue concerns the design classification of the pressurizer auxiliary spray system.
ANPP had stated in two letters dated November 3, 1983 and July 28, 1984 that the auxiliary spray system was a safety grade system.
However, during an unsuccessful loss-of-load test at Palo Verde Unit I on September 12, 1985, the resulting plant performance showed that not all components of the system are safety grade and that the system is vulnerable to single failure.
The staff's acceptance of the auxiliary spray system design was based, in part, on its understanding that the system was safety grade.
As a result, the staff has issued a 50.54(f) letter to ANPP requesting the licensee to submit a program and schedule for bringing the auxiliary spray system into conformance with its licensing basis.
In conclusion, ANPP management involvement and control in assuring quality with respect to the functional area of licensing activities is rated at the Category 2 level.
(2)
A roach to Resolution of Technical Issues The licensee's approaches to resolution of issues were technically sound and generally conservative.
With regard to the resolution of issues dealing with fire protection, technical specifications and equipment qualification, the licensee exhibited a clear understanding of the matters involved and provided a sound and thorough approach.
For most issues, ANPP demonstrated an adequate understanding of the issues, and provided a generally sound and reasonable approach to resolution.
Some issues, such as containment
- systems, control room design, accident analyses and
- PASS, required repeated submittals to reach resolution.
For the issue of chemistry control, the licensee's initial submittal lacked thoroughness and depth.
In addition, as discussed above in the evaluation of management involvement, an issue arose late in the reporting period which has raised questions regarding ANPP s approach to providing a reliable pressurizer auxiliary spray system.
In summary, the licensee's overall approach to the resolution of technical issues is rated at the Category 2 level.
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(3)
Res onsiveness to NRC Initiatives ANPP's responses to the various technical issues have generally been timely and were usually sound and thorough.
However, the licensee took an extended amount of time and repeated submittals to respond to a number of issues, such as control room design, accident analyses, shift staffing and chemistry control.
In addition, just prior to issuance of a low power license on Palo Verde Unit I, ANPP submitted a large number of proposed FSAR changes which required staff review.
Prior to a decision on a low power license for Unit 2, ANPP submitted additional proposed changes but to a lesser degree.
The licensee's overall responsiveness to NRC initiatives during the evaluation period is rated at the Category 2 level.
(4)
Enforcement Histor During the reporting period there were several violations, one of which was a
major violation concerning the PASS (see discussion under Management Involve-ment and Control in Assuring guality) that indicates a programmatic breakdown.
The licensee has also indentified, in LERs, violations in performing required Technical Specification surveillances within the scheduled time.
Furthermore, the licensee has been cited for excessive use of overtime in performing these surveillances.
Based on the above, NRR's evaluation of enforcement history, as it relates to licensing activities, rates this criterion at the Category 2 level.
(5)
Re ortin and Anal sis of Re ortable Events ANPP received an operating license on Palo Verde Unit I midway through the reporting period.
During the nine month period that the license was held, the licensee reported 51 non-security events, a few of which involved Unit 2.
Three of the events have involved reactor trips that reflects a trip rate which is near average for new plants.
The most significant event during the reporting period was the September 12, 1985 event (also discussed under Management Involvement and Control in Assuring guality) involving an unplanned loss of forced reactor coolant system flow, a reactor trip, safety injection, containment isolation, and a loss of charging flow.
The licensee's reporting and analysis of this event were incomplete and lacking information.
Specifically, the licensee did not recognize the safety significance of losing the charging pumps as they relate to the operability of the auxiliary pressurizer spray system.
In addition, the post-trip review process did not focus on the importance of the auxiliary spray system for mitigating a steam generator tube rupture accident, nor did it assess how the plant performed in the natural circulation cooldown mode that resulted during the event.
The licensee's performance on reporting and analyzing events during the evaluation period is rated at, the Category 2 level.
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Staffin (Includin Mana ement)
There was only a limited input upon which to evaluate the staffing of ANPP for licensing activities.
The licensee appears to be adequately staffed with key positions identified and filed in a reasonable time.
During the evaluation period, the licensee filled two key positions with people having experience with operating nuclear facilities, i.e., Vice President for Nuclear Production and the Director of Technical Services.
The filling of the position of Vice President for Nuclear Production provided corporate management with nuclear operating experience where previously there was none.
Staffing of ANPP for the evaluation period is rate'd at the Category 2 level.
(7)
Trainin and gualification Effectiveness There was an observation made during the evaluation period which relates to training effectiveness.
In December 1984, while performing a simulator exercise for NRR management during a site visit, it was noted that the operators'erformance was not at an optimum level.
As a result, ANPP took various actions to enhance operator preparedness for conducting the low power physics testing and power ascension testing.
Training and qualification effectiveness during the evaluation period is rated at the Category 2 level.
testing.
IV.
HOUSEKEEPING AND CONTROL ROOM BEHAVIOR Housekeeping and control room behavior are not directly related to the functional area of licensing activities.
However, there is a continuing interest in this
- area, since good housekeeping practices and formal control room behavior can be indicative that a licensee and the operators take pride in their facility and in their job.
In several visits to the Palo Verde site during the evaluation period, good housekeeping practices were evident.
The various plant areas that were visited looked clean.
Where work was in progress, there was no undue amount of materials and tools to perform the task.
Control room behavior was also observed during the various site visits.
At the July 1984 management meeting for Palo Verde Unit I plant readiness, control room demeanor was cited as requiring improvement in preparation for plant operation.
During subsequent visits improvements in this area were noted.
A more formal environment in the control room appears to be appropriate.
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RECOMMENDATIONS ANPP management should devote more attention to licensing activities so that
- problems, such as those which occurred with the auxiliary spray system and
- PASS, do not recur.
In addition, ANPP management should take steps to assure that submittals are timely and that the need for making additional submittals is kept to a minimum.
Shortly after the end of the reporting period, several unusual events occurred at Palo Verde Unit 1 during October 1985 which affected the performance of plant systems, such as offsite power systems, the turbine control systems and the reactor power runback system.
These events reflected that the plant did not perform as expected.
In addition these events, coupled with other events during the reporting period, appeared to reflect, in some instances, that there was insufficient thought in the preparation of test procedures and in system design (e.g., ele'ctrical distribution reliability).
Therefore, additional management attention is also warrented to understand such events, including root causes, and to establish effective corrective actions to prevent similar occurrences.
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Attachment No. I IV.
Performance Anal sis 10.
Licensin Activities l.
A~nal sis During the current SALP assessment period, there were 18 separate licensing actions for which more than 35 specific inputs were provided to the assessment.
Management involvement and control in assuring quality for licensing activities was evident in a number of areas.
Decision making for licensing activities was usually done at a level that ensures adequate management review and these reviews were generally timely, thorough and technically sound.
After licensing of Palo Verde Unit I, two issues arose which appear to indicate a lack of proper management attention.
One concerns the operability of the post accident sampling system (PASS) under postulated accident conditions.
Although ANPP had installed and declared the system operable for that purpose, there was little evidence that ANPP had evaluated the capability for obtaining a sample at the installed location for a projected high radiation environment.
Upon further evaluation, it was determined that the ability to take a sample within the dose guidelines of GDC 19 at the installed location was questionable.
As a result, ANPP has recently submitted a proposed FSAR change to correct this deficiency.
The second issue concerns the design classification of the pressurizer auxiliary spray system.
ANPP had stated in two letters dated November 3, 1983 and July 28, 1984 that the auxiliary spray system was a safety grade system.
However, during an unsuccessful loss-of-load test at Palo Verde Unit I on September 12, 1985, the resulting plant performance showed that not all components of the system are safety grade and that the system is vulnerable to single failure.
The staff's acceptance of the auxiliary spray system design was based, in part, on its understanding that the system was safety grade.
As a result, the staff has issued a 50.54(f) letter to ANPP requesting the licensee to submit a program and schedule for bringing the auxiliary spray system into conformance with its licensing basis.
In addition, the licensee's reporting and analysis of the above event were incomplete and lacking information.
Specifically, the licensee did not recognize the safety significance of losing the char ging pumps as they relate to the operability of the auxiliary pressurizer spray system.
In addition, the post-trip review process did not focus on the importance of the auxiliary spray system for mitigating a steam generator tube rupture accident, nor did it assess how the plant performed in the natural circulation cooldown mode that resulted during the event.
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The licensee's approaches to resolution of issues were technically sound and generally conservative.
For most issues, ANPP demonstrated an adequate understanding of the issues, and provided a generally sound and reasonable approach to resolution.
Some issues, such as containment
- systems, control room design, accident analyses and PASS, required repeated submittals to reach resolution.
For the issue of chemistry control, the licensee's initial submittal lacked thoroughness and depth.
ANPP's responses to the various technical issues have generally been timely and were usually sound and thorough.
However, the licensee took an extended amount of time and repeated submittals to respond to a number of issues',
such as control room design, accident analyses, shift staffing and chemistry control.
In addition, just prior to issuance of a low power license on Palo Verde Unit I, ANPP submitted a large number of proposed FSAR changes which required staff review.
Prior to a decision on a low power license for Unit 2, ANPP submitted additional proposed changes but to a lesser degree.
There was only a limited input upon which to evaluate the staffing of ANPP for licensing activities.
The licensee appears to be adequately staffed with key positions identified and filed in a reasonable time.
During the evaluation period, the licensee filled two key positions with people having experience with operating nuclear facilities, i.e., Vice President for Nuclear Production and the Director of Technical Services.
The filling of the position of Vice President for Nuclear Production provided corporate management with nuclear operating experience where previously there was none.
2.
Conclusion Overall, the licensee's performance in the area of licensing activities was generally sound and responsive to NRC requirements.
- However, due to (I) the two issues (PASS and the auxiliary pressurizer spray system) which appear to indicate a lack of proper management attention, (2) the extended amount of time required to resolve issues and the large number of last minute FSAR changes before licensing, and (3) the imcomplete reporting of the September 12, 1985 event, this area is evaluated a Category 2.
3.
Board Recommendation ANPP management should devote more attention to licensing activities so that problems, such as those which occurred with the auxiliary spray system and
- PASS, do not recur.
In addition, ANPP management should take steps to assure that submittals are timely and that the need for making additional submittals is kept to a, minimum.
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Shortly after the end of the reporting period, several unusual events occurred at Palo Verde Unit 1 during October 1985 which affected the performance of plant systems, such as offsite power
- systems, the turbine control systems and the reactor power runback system.
These events reflected that the plant did not perform as expected.
In addition these
- events, coupled with other events during the reporting period, appeared to reflect, in some instances, that there was insufficient thought in the preparation of test procedures and in system design (e.g., electrical distribution reliability).
Therefore, additional management attention is also warrented to understand such events, including root causes, and to establish effective corrective actions to prevent similar occurrences.
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