ML17300A713

Forwards Revised Responses to Recommendations Contained in NRC Re Emergency Operating Procedures,Per 870226 Meeting

ML17300A713
Person / Time
Site:	Palo Verde
Issue date:	03/27/1987
From:	Haynes J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
161-00108-JGH-R, 161-108-JGH-R, NUDOCS 8704030051
Download: ML17300A713 (16)

Text

DOCKET 05000528 05000529 05000530

SUBJECT:

Forwards revised responses to recommendations contained in NRC 860910 itr re emergency operating procedures, per 870226 meet ing.

DISTRIBUTION CODE:

A003D COPIES RECEIVED: LTR ENCL SI ZE:

TITLE: OR/Licensing Submittal:

Suppl 1 to NUREQ-0737(Qeneric Ltr 82-33)

REGULATOR NFORNATIOI'J DISTRIBUTION TEN (R IDS)

ACCESSION NBR: 8704030051 DOC. DATE: 87/03/27 NOTARIZED:

NO FACIL:STN-50-528 Palo Verde Nuclea'r Stations Unit ii Arizona Publi STN-50-529 Palo Verde Nuclear Station>

Unit 2> Arizona Pub li STN-50-530 Palo Verde Nuclear Stationi Unit 3i Arizona Pub Ii AUTH. NAl'lE AUTHOR AFFILIATION HAYNES> J. Q..

Arizona Nuclear Pouer Prospect (formerlg Arizona Public Serv RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

NOTES: Standardized plant. N. Davis. NRR: 1Cg.

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Standardized plant. M, Davi s. ERR: iCg.

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Arizona Nuclear Power Project P.O. BOX 52034

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PHOENIX, ARIZONA85072-2034 March 27, 1987 161-00108-.JGH/RAB U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.

20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Numbers:

STN 50-528 (License No. NPF-41)

STN 50-529 (License No. NPF-51)

STN 50-530 Additional Information on PVNGS Emergency Operating Procedures File:

87-A-056-026

Reference:

Letter from G.

W. Knighton (NRC) to E.

E.

Van Brunt, Jr.

(ANPP) dated September 10, 1986.

Subject:

Review of Palo Verde Procedures as Related to the July 12th Trip at Palo Verde Unit 1.

Dear Sirs:

During a meeting held in Bethesda, MD on February 26, 1987 to discuss PVNGS Emergency Operating Procedures, ANPP provided handout material to the NRC staff which identified our response to recommendations contained in the referenced letter.

As a result of discussions during the meeting, it became evident that ANPP had done more than was indicated in the handout and in some cases prior to receiving the NRC's staff's recommendations.

The NRC staff verbally requested that ANPP revise its responses to reflect these items and to formally submit them.

At the meeting, ANPP also provided to Mr. Michael Goodman of the NRC staff, responses to the "A" category items which resulted from the September, 1984 audit.

The attachment to the letter provides the revised responses as requested.

8704039ocp 0500@op 00S> 870~0S28 Pop P

JGH/RAB/)le Attachment Very truly yours,.

J.

G. Haynes Vice President Nucle'ar Production cc:

0. M. De Michele E. E. Van Brunt, Jr.

G.

W. Knighton E. A. Licitra R. P.

Zimmerman J. B. Martin A. C. Gehr (all w/a)

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11

ATTACHMENT NRC Recommendation:

As a preliminary step before the staff determines the acceptability of the Licensee's

approach, the licensee should define clearly the conditions under which the FRP would be used and develop a

policy (and technical basis) for those situations where decision points are unclear or necessary information is unavailable.

The licensee's description should also include a

statement regarding how they addressed the "A" items that resulted from the staff audit of the Palo Verde EOP's, conducted in September 1984.

APS Response:

In order to more clearly define when the Functional Recovery Procedure is to be

used, a

change was implemented to the Emergency Operations Procedure and the Functional Recovery Procedure.

The procedure

change, using CEN-152 as a technical basis, is worded in the following manner:

If any of the following conditions

exist, THEN evaluate the need to implement the Functional Recovery Procedure, 41RO-1ZZ10

1. If a diagnosis is not possible.

or 2.

A reactor trip and unusual concurrent

symptoms, with no immediately apparent diagnosis or cause.

or 3.

Any condition, or pattern of

symptoms, which the operator considers

serious, and for which abnormal or 'mergency guidance cannot be identified.

or 4.

Actions taken in a

Recovery Operations Procedure are not satisfying Safety Functions.

To further clarify when the Functional Recovery Procedure should be entered a

meeting was conducted between License Training and Operations to ensure that simulator exercises include events which lead to the Functional Recovery Procedure in both License Training and Requalification

f

Training.

There will also be an increased interface between the Operations procedure group and the License Training Department to clarify Operations philosophy on use of all Emergency Operations Procedures as well the Diagnostic Flow Chart.

2 ~

NRC Recommendation:

Palo Verde performs an analysis of the Diagnostic Procedure to determine if trending of Steam Generator Pressure should be incorporated in the Flow Chart to help diagnose ESD events.

In addition to use of parameter trending for diagnosing other events should be considered.

APS Response:

The trending of Steam Generator pressures in the diagnostic flow chart was evaluated and several models were drawn up.

Attempts to trend Steam Generator pressure on the diagnostic resulted in several additional groups of decision block

matrices, which made the diagnostic much more difficult to follow.

After evaluation, the decision was made to include guidance in the Emergency Procedure regarding the importance of trending Steam Generator pressure and the availability of using fast closure of the Main Steam Isolation Valves to terminate an Excessive Steam Demand Event.

License Training has always included special emphasis on trending key parameters such as Pressurizer and Steam Generator pressure and

level, and this emphasis will be enhanced in the future in both License Training and Requalification Training.

3 ~

NRC Recommendation:

CEN-152 be changed to explicitly state that parameter trending should be used in diagnosing an event.

APS Response:

This has been addressed to the GEOG Subcommittee, trending is already addressed in Appendix D of the Emergency Operations Procedure.

4 ~

NRC Recommendation:

Parameters and instrumentation that are key variables, especially those that are needed in the early stages of an event, be powered from a more reliable power supply.

APS Response:

The loss of key instrumentation was recognized as a concern in the post trip review performed after the July 12, 1986 trip.

Engineering Evaluation Requests were initiated, and the diagnostic decision blocks were analyzed.

Design Change Packages are being developed to provide class IE

I J

power to the Containment Temperature and Humidity Detectors, the Radiation Monitoring System mini-computer (for control room indication),

the Containment,Radwaste Sump level indication and key radiation monitors which are used in the diagnostic flow chart.

Additionally, guidance has been added to the Emergency Procedure and the diagnostic to provide alternate means of acquiring information to answer decision blocks.

5 ~

NRC Recommendation:

CEN-152 be revised to include statements to have reliable power supply for key parameters that are used in the early stage of an

accident, i.e.,

event diagnosis.

APS Response:

This has been addressed to the GEOG Subcommittee and has been addressed for PVNGS in the above referenced Design Change Packages.

6.

NRC Recommendation:

Palo Verde Diagnostic Flow Chart be changed to include logic statements and success paths that will direct the operator to a statement that will send him to the Functional Recovery Procedure or define in the Flow Chart the conditions under which the Functional Recovery Procedure should be used.

APS Response:

The Emergency Operations Procedure provides guidance for when the Functional Recovery Procedure should be entered.

This guidance will be emphasized during training.

Additionally the immediate operator actions following a

trip involve maintaining safety functions in a

functionally oriented manner similar to the Functional Recovery Procedure.

Placing decision blocks and criteria for entering the Functional in the Diagnostic would make the Diagnostic unwieldy and would create the impression that those are the only times the Functional should be entered.

7 ~

NRC Recommendation:

The Diagnostic Flow Chart, delete the requirement to trip reactor coolant pumps.

This would make the Flow Chart compatible with the SBLOCA procedure and the trip strategy incorporated in CEN-152.

APS Response:

The deletion of the requirement to trip all RCPs prior to entering the SBLOCA had already been identified by ANPP prior to the July 12th event, and was scheduled to be included in the next revision to the Emergency Procedure which is now complete.

Additionally License Training

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emphasizes the desirabili.ty of maintaining forced flow in events in which 28 F

subcooling can be maintained.

NRC Recommendation:

Palo Verde reexamine the need for all other statements in the Diagnostic Flow Chart that require operator actions and delete them if possible.

This would eliminate action statements in the Flow Chart that could be inconsistent with the selected recovery procedure, and leave the Diagnostic Flow Chart as purely a diagnostic which is consistent with the philosophy of CEN-152.

APS Response:

The Diagnostic is divided into two sections, one section serves as a second check to ensure safety functions are being maintained and the other portion serves to diagnose the event.

The following list indicates 17 points on the diagnostic chart.

Shown next to each point are the manual actions

required, e.g., trip reactor, followed by the safety function being maintained, e.g., reactivity control.

l. All CEAS inserted Trip Reactor Reactivity Control.

2. Greater than 1

CEA Not Full in Emergency Borate Reactivity Control.

3. Reactor Power Decreasing Emergency Borate Reactivity Control.

4.

RCS Press Greater than SIAS Verify SIAS/CIAS Inventory Control and Containment Integrity.

5. Pressurizer level on scale Initiate SIAS Inventory Control.

6.

RCS Subcool Greater than 28 F Verify SIAS Inventory Control and Heat Removal.

7.

CTMT Press.

less than 3

PSIG Verify SIAS,

CIAS, MSIS

Containment Integrity, Heat Removal, Inventory Control.

8.

CTMT Press.

less than 8.5 psig Verify CSAS Containment Integrity.

9.

SG Press.

greater than MSIS Verify MSIS Containment Integrity, Heat Removal.

ll f

I II,

(

10.

SG Level greater than 26X WR Verify AFAS Heat Removal.

ll. SBCS Available Use Atmos.

Dump Heat Removal.

12.

TG Tripped Trip Turbine Generator Heat

Removal, Maintenance of Vital Auxiliaries.

13.

CTMT RAD less than set Initiate CIAS Containment Integrity.

14.

Rad Monitor less than Alarm Set Evaluate Alarm Indirect Radioactive Release.

15.

RVLMS Indicates Core Is Covered Verify SIAS Heat Removal, Inventory Control.

16.

Power Supply Alarm Degraded Electrical Power Procedure Maintenance of Vital Auxiliaries.

17.

CW, PW, TC, NC Available Restore Flow per Abnormal Operating Procedure

Maintains Condenser as Heat Sink for Heat Removal and RCPs support systems for forced circulation.

These operators actions are necessary for maintenance of safety functions and are consistent with the recovery.

Events requiring tripping of RCPs will be discussed separately.

This completes the Actions required in the Safety Function verification section.

The diagnostic section contains similar statements where Essential Safeguards System Actuations are verified.

Tri in of RCPs The Palo Verde philosophy of tripping 2

RCPs following a

RCS depressurization is consistent with CEN-152 and is carried out in the diagnostic whenever a

Safety Injection plant specific

setpoint, is called for.

In

addition, the tripping of all RCPs is required on entry to the Large Break LOCA procedure and is consequently called for in the Diagnostic.

The chance of misdiagnosis of an event leading to the unnecessary tripping of all RCPs is minimized

because, in order to reach a block which requires

l I

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all RCPs to be

tripped, a

decision block concerning Containment Pressure being greater than 3 psig must be answered affirmatively.

Palo Verde administratively maintains Containment Pressure less than 1.5 psig during normal operation.

Consequently, a

large loss of either Steam Generator or RCS inventory would be required to raise containment pressure to 3.0 psig.

NRC Recommendation:

The Diagnostic Aides Section of CEN-152 be revised to eliminate the vagueness as to what should be included in the EOPs.

Words which can be construed to mean utilities do not have to comply with the section, should be deleted so deviations will be identified by utilities referencing CEN-152.

APS Response:

This has been addressed to the CE Owners Group.

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