ML17303A401
| ML17303A401 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/04/1987 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-00323-EEVB, 102-323-EEVB, NUDOCS 8704150494 | |
| Download: ML17303A401 (9) | |
Text
REGULATORY INFORiNATIQN DISTRIBUTION SYSTEN (R IDS)
ACCESSION NBR: 8704150494 DQC. DATh.: 87/Oi/04 NOTARIZED:
NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station>
Unit 1> Arizona Publi 05000528 TH. NANE AUTHOR AFFILIATION BRUNT> E. E.
Arizona Nuclear PoIuer Prospect
< formerl g Arizona Public'erv IP. NhiNF-REC IP IENT AFFILl*TION Document Control Branch (Document Control DesP
)
SUBJECT:
Responds to NRC 870220 ltr re violations noted in lnsp Rept 50-528/87-01. Corrective actions:procedure changes made to appropriate Unit 1
8c Unit 2> Vade 3 5 4 surveillance test proc ed Ures.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR g ENCL j SIZE:
TITLE: General
<50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Standardized plant. N. Davis>,"!wRi 1Cg.
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INTERNAL:
RECIPIENT ID CODE/NhiNE PD5 LA LICITRA E ACRS AEOD ENF LIEBERNAN NRR ROE> iI. L NRR/DOEA DIR NRR/DREP/RPB NR~JPNBS/ILRB FA.-
RGN5 FILE 01 COPIES LTTR ENCL 0
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1 RECIPIENT ID CODE/NANE PD5 PD DAVlS> N ACRS NYLIE DEDRO IE/DI/ORPB NRR/ADT NRR/DREP/EPB NRR/DRIS DIR OQC/HDSl RES SPEIS> T COP IES LTTR ENCL 1
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EXTERNAL: LPDR NSIC 1
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TOTAL NUiNBER OF COPIES REQUIRED:
LTTR 27 ENCL 26
Arizona Nuclear Power Project P.O. BOX 52034
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PHOENIX, ARI2ONA85072-20i34 102-00323-EEVB/TDS April 4, 1987 NRC Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station Unit 1
Docket No.
STN 50-528 (License NPF-41)
Notice of Violation:
50-528/87-01-02, 50-528/87-01-03 File:
87-001-493
Reference:
Letter from J.
B. Martin (NRC) to E. E.
Van Brunt, Jr.
(ANPP),
dated March 13,
- 1987, NRC Inspection Reports 50-528/87-01, 50-529/87-01 and 50-530/87-02.
This letter is provided in response to the inspection conducted by Messrs.
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R.
Zimmerman, C. Bosted, G. Fiorelli, J. Ball and K. Ivey of the NRC Staff on January 5, through February 20, 1987.
Based on the results of the inspection, two (2) violations of NRC requirements were identified.
The violations are discussed in Appendix A of the referenced letter.
The violations and ANPP's response are provided in Attachment A.
Very truly yours EEVB/TDS/cld Attachments E. E.
Van Brunt, Jr.
Executive Vice President Project Director cc:
J.
G.
Haynes L. F. Miller R.
P.
Zimmerman E.
A. Licitria A. C. Gehr J.
B. Martin (w/attachment)
(w/attachment)
(w/attachment)
(w/attachment)
(w/o attachment)
(w/attachment) 704150494 870404 PDR ADOCK 05000528 6
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5
~ Jl NRC Document Control Desk Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS Page 1 of 7 ATTAQBKNT A NOTICE OF VIOLATION Arizona Nuclear Power Project Post Office Box 52034 Docket No. 50-528 License No.
NPF-41 As a result of the inspection conducted on January 5,
1987 February 20, 1987 and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violations were identified:
A.
Technical Specification 1.5 states, "A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This 0
determination shall include...
comparison of the channel indication... with other indications... derived from independent instrument channels measuring the same parameter."
r Technical Specification 4.3.1.1 requires in part, that with the plant in Modes 1-3, a CHANNEL CHECK of the four high logarithmic power level reactor protective instruments be performed at least once per 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.
Contrary to the above, with the plant in Modes 1-3 from 10:20 PM, January 9
through ll:15 AM, January 11,
- 1987, a period greater than 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, CHANNEL CHECKS of the four high logarithmic power level reactor protective instruments were not performed, in that a qualitative assessment of channel behavior by the comparison of each channel indication with other indications derived from independent channels measuring the same parameter was not performed.
tpJ NRC Document Control Desk
.Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS Page 2 of 7 THE CORRECTIVE STEPS MECH HAVE BEEN TAKEN AND THE RESULTS AQKEVED On January ll, 1987, ANPP Management was informed that the method of accomplishing the log power reactor protective instrumentation channel
- checks, specifically the acceptance
- criteria, did not satisfy the Technical Specification definition of a h
channel check based upon the fact that the evaluation was performed without reference to qualitative acceptance criteria.
A thorough review of the event was performed with the following remedial corrective steps taken:
I.
Procedure changes have been made to the appropriate Unit 1 and Unit 2 Mode 3 and 4 Surveillance Test Procedures.
These procedure changes establish both the proper parameter (deviation between channels) and the necessary acceptance criteria to satisfy the definition of a CHANNEL CHECK with respect to the log power channels.
Additionally, guidance has been provided to specifically address the known discrepancies which occur at low power levels (less than 10 E-5) due to the proximity of the A and D log power channel detectors to the installed start-up neutron sources.
Also, guidance has been provided for situations where insufficient channels are available to satisfy the minimum channels operable requirement and/or to perform the "deviation between channels" check.
2.
An additional concern was identified as a result of this event with regard to the performance of CHANNEL CHECKS on PPS instrument channels being restored,to "operability" following removal from service for surveillance testing or I
maintenance.
Initial corrective action with respect to this concern has been the issuance of a Night Order to both Unit 1 and Unit 2, alerting the Control Room Staff of the requirement to maintain surveillances current when returning
4
.NRC Document Control Desk Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS Page 3 of 7 PPS instrument channels to service (removing from bypass).
The proper documentation of any additional CHANNEL CHECKS required is also addressed by the Night Order.
II.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COHPLIANCE During the review of this event it was determined that the cause of not performing the shiftly channel check in accordance with Technical Specifications, was due to inadequate procedural guidance as to what constitutes a qualitative assessment.
As such, the procedural changes described above will serve to prevent the recurrence of the specific event identified.
As: additional action the following corrective measures will be taken:
A The appropriate Unit 3 Surveillance Test Procedures (43ST-3ZZ30 and 43ST-3ZZ31) will be changed to conform to the Unit 1 and 2 procedures.
A procedure change will be implemented to 40AC-9ZZ02, "Conduct of Shift Operations" (common to all three units).
The change to this administrative control procedure will provide the necessary guidance for deviation acceptance criteria when only one channel is available for qualitative assessment and for instruments reading off-scale due to the prevailing plant conditions.
In addition, this, change will assign direct responsibility to the Nuclear Operator (III) ensuring that the surveillance requirements are current when returning PPS instrument channels to service (prior to removing the channel from bypass).
To ensure that required channel checks of other instruments are receiving a qualitative
JlRC Document Control Desk Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS age4of 7
assessment, as defined in Technical Specifications, the following actions will be taken:
1.
A review of surveillance tests required to be performed shiftly by operations personnel will be conducted to ensure channel checks acceptance criteria contains a qualitative assessment.
2.
Procedural
- changes, as necessary, will be made based on the results of the review.
III.
THE DATE WHEN FULL COMPLIANCE WILL BE AGKEV1?3 The Unit 3 Surveillance Test procedures will be revised prior to initial entry into Mode 5.
The Administrative Control procedure (40AC-9ZZ02) change is expected to be mpleted by April 30, 1987.
The review of the shiftly surveillance tests and necessary procedural changes is expected to be completed by May 15, 1987.
'NRC Document Control Desk Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS age 5 of 7 ATTACHMENT A CONTIRHH)
B.
10 CFR 20.202 (b) (2) defines radiation area as any area, accessible to personnel, in which there exists radiation, originating in whole or in part within licensed
- material, at such levels that a major portion of the body could receive in any one hour a dose in excess of five millirems, or in any five consecutive days a dose in excess of 100 millirems.
10 CFR 20.203 (b) states that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
"Caution Radiation Area".
Contrary to the above, on January 21,
- 1987, door T-104, which allowed entry into a radiation area at the 100'levation of the Turbine Building of 20 millirem per hour, general
- area, was not posted with the required signs and warning.
NRC Document Control Desk
'Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS Page 6 of 7 I.
THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On January 21,
- 1987, ANPP Management was notified of the insufficient posting in the 100'levation of the Turbine Building.
Reactor Protection (RP) Supervision immediately dispatched a
RP technician to the area to verify the entrances were properly posted.
The technician found that door T-104 was not posted.
The door was posted with the required sign and documented on the applicable survey record.
In order to ensure full compliance was achieved a detailed review of the survey was conducted.
Each area was evaluated and dispositioned as necessary.
These actions returned the radiation area (Turbine Building) to full compliance with the requirements of 10 CFR Part 20.
As additional corrective action, RP Technicians have been'nstructed by memo o ensure required radiation area postings are properly completed.
II.
THE C01UUKHVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NON-COMPLIANCE A review of the event has determined that the cause of the deficiency was due to personnel oversight of this door as an entrance to the Turbine Building during the initial posting evolution.
A contributory cause to the oversight
- however, was the unusual nature of the event.
The Turbine Building had never been posted as a radiation area prior to January 20, 1987.
Thus the unfamiliarity of the area, and all possible entrances, contributed to the unposted door.
RP Super'vision normally tours the plant to ensure area postings are correct and that all facets of the RP Program are being properly implemented.
As stated in the inspection report, the initial posting had been accomplished on the previous mid-shift.
At 0900 on January 21,
- 1987, the tour of the Turbine Building by the RP
NRC,Document Control Desk Palo Verde Nuclear Generating Station 102-00323-EEVB/TDS Page 7 of 7 Lead Technician had not been completed.
ANPP is confident that the posting error would have been found and corrected prior to the end of the day shift since an RP Lead Technician was designated as responsible for the Turbine Building and would have toured the building.
Based on the above, no further corrective actions for this specific event are deemed necessary.
Although not resulting directly from this event, ANPP management believes the corrective action taken in response to the March 11,
- 1987, meeting with you at the Region V offices will serve to assist in preventing this type of event from recurring.
Specifically, the unusual nature of this event (Turbine Building posted as a radiation area) would fall into the situation where personnel have now been 1
directed to contact higher levels of management prior to proceeding with an unfamiliar evolution.
Generally, the management practice to formulate well thought out plans and methodologies, and ensure that personnel are familiar with their assigned tasks prior to implementation has been reinforced to supervisory personnel.
III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEIG9)
Full compliance was achieved on January 21, 1987," when the door was correctly posted.