ML17303A635

Forwards Final Responses to Lessons Learned in NUREG-1275 & Executive Summary.Util Initiated Actions to Correct Equipment Deficiencies & to Promote Operating Plant Attitude in Util Staff

ML17303A635
Person / Time
Site:	Palo Verde
Issue date:	10/12/1987
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-NUREG-1275 161-00579-JGH-R, 161-579-JGH-R, NUDOCS 8710160076
Download: ML17303A635 (100)

Text

REGULATO INFORMATION DISTRIBUTION STEM '(BIDS>

I ACCESSION NBR: 8710160076, DOC. DATE: 87/10/12 NOTARIZED: NO DOCKET ¹ FACIL: STN-50-530 Palo Verde Nuclear Stations Unit 3i Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION VAN BRUNTi E. E. Arizona Nuclear Poeer Pro Ject (formerly *rizona Public Serv RECIP. NAME RECIPIENT AFFILI*TION Document Control Branch (Document Control Desk)

SUBJECT:

Foreards f inal responses to lessons learned in NUREG-1275 Zc executive summary. Util initiated actions to correct ~g.C equipment deficiencies 8c to promote operating plant attitude in util staff.

DIBTRIBUTION CODE: A001D TITLE: OR COPIEB RECEIVED: LTR Submittal: General Distribution g ENCL f SIZE:

NOTES: Standardized'lant. 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PDS,PD 5 5 LIC ITRAI E 1 1 DAVIS' 1 INTERNAL ACRS 6 6 ARM/DAF/LFMB 0 NRR/DEST/ADS 1 1 NRR/DEST/CEB 1 1 NRR/DEST/MTB 1 1 NRR/DEST/RSB 1 1 NRR/DOE*/TSB 1 RB 1 1 OGC /HDS1 1 0 Q 01 1 RES/DE/EIB 1 1 EXTERNAL: EQ8cQ BRUSKEi S 1 1 LPDR 1 1 NRC PDR 1 1 NSIC 1 NOTES:

TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 26

ih it Arizona Nuclear Power Project P.Q. BOX 52034 ~ PHOENIX. ARIZONA85072-2034 Docket No. STN 50-530 October 12, 1987 161-00579-JGH/RAB U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Responses to NUREG-1275 Lessons Learned File: 87-G-056-026 On October 2, 1987, a meeting was held in your offices in Bethesda, Md. to discuss our responses to the lessons learned in NUREG-1275 with members .of the NRC staff.

At that time, we presented a draft set of responses which formed the basis for the discussion. We requested that the draft responses be returned, and that we would provide a final version within two weeks. Attached, please 'find these responses and an executive summary, which we have prepared for your use in brief-ing the Commissioners prior to the Unit 3 full power license hearing.

It can be seen from these responses and the actions reported in the NUREG, that ANPP has profited from experiences in Units 1 and 2 and in other plants. We have initiated actions to correct equipment deficiencies and to promote an operating plant attitude in the ANPP staff. We believe that we are in an excellent position to successfully operate Unit 3 through the Power Ascension Phase and into commercial operation.

If you have any questions on this matter, please contact Mr. R. A. Bernier of my staff.

Very truly yours, 87goib007b 80500 PDR ADOCN, E E Van Brunt Jr

{ Executive Vice President Project Director F'EVB/RAB/rw Attachments cc: 0. M. De Michele J. B. Martin J. R. Ball (w/a) ,o(

A. C Gehr Meeting Attendees

l1 Executive Summary October 2, 1987 Meeting With The Palo Verde Unit 3 Licensee on NUREG 1275 A meeting was held on October 2, 1987'ith the Palo Verde Unit 3 licensee and NRR/AEOD/Region V personnel to discuss how the licensee has applied lessons learned from Palo Verde Unit 1 and 2 experiences and other applicable industry experiences into Palo Verde Unit 3. This meeting used NUREG 1275, Paragraphs 5.1.1, Management Lessons, and Paragraph 5.1.2, Equipment Lessons, as a basis for discussion. The licensee presented each lesson as written in the NUREG, briefly discussed what had been done on Palo Verde Unit 3, and responded to questions raised in the meeting.

Since Unit 3 is identical to Units 1 and 2, and senior operators have had some experience in these units, there has been ample time to establish an operating plant mentality at Palo Verde Unit 3. Unit 3 personnel have been responsible for the unit since all systems necessary were turned over to the Operations Department prior to Hot Functional Testing. All systems were turned over by January 31, 1987. 3hey are using the same proven procedures as were used on Units 1 and 2 and have used many of these procedures during'perator training. 1he preoperational testing program was well planned,, and it has applied lessons learned from Units 1 and 2. The post core testing program has also benefited'rom the lessons, learned in Units 1 and 2.

The technical specifications for Unit. 3 are virtually identical to the technical specifications for the first two units. Control of surveil-lance testing activities is the same for all three units with adequate controls established to preclude "wrong channel" testing. %he licensee has had engineers in the I&C Maintenance group for several years, as was suggested in the NUREG, and has identified surveillance procedures which pose a potential risk to trip the unit in order to provide special surveillance cautions. Ihe I&C staff has developed expertise and delegated responsibility for specific equipment and'ystems. Through the use of root cause analysis, other investigative progzams, and implementing corrective action, the licensee has been able to give high visibility to causes of reactoz scrams and to improve performance. The licensee presented graphs demonstrating the performance improvements mode in Units 1 and 2. %he licensee has a comprehensive experience feedback program which includes articles in a monthly newsletter directed exclusively to Palo Verde employees, as well as programs which elicit responses from responsible groups for corrective actions.

Training plays a very important role at Palo Verde for all segments of the onsite staff. The training program applies to all three units and incorporates the lessons learned concept. The Palo Verde simulator, which was put into operation in 1980, replicates the Palo Verde control rooms. It is currently completing the second year of a five-year upgrade program and will have improvements in the feedwater and reactor systems operational by next April. The staff indicated a concern that these are very important improvements, and they should be put in place very quickly.

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The licensee presented his program for scram reduction, failure data trending, reliability centered maintenance, and probabilistic risk assessment. The program takes into account BOP systems which may introduce scrams. The licensee stated that necessary test jacks, test circuitry, and bypass switches have been installed. Measures to reduce scrams have been prioritized and implemented based on industry and vendor experience as well as experience on Units 1 and 2. The licensee has experienced problems with EMI and RFI and has taken positi've steps to correct them in all three units.

The licensee presented special features which have been put into operation in Units 1, 2, and 3 to minimize unplanned scrams and unnecessary ESF actuations. The licensee will continue detailed evaluation of any first of a kind modifications proposed for the units.

Special scram prevention measures to minimize unnecessary scrams have been implemented in. all three units.,

Following the discussion it was evident that the licensee has a compre-hensive program which addresses the lessons in NUREG 1275. The staff encouraged the licensee to update the simulator to match plant responses, to carefully monitor and control the power escalation program, and to be aware of the high risk of scram in the early months after commercial operation. The staff also encouraged the licensee to insure that

'Operating ,and Licensing personnel understand the reasons for each technical specification.

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ANPP RESPONSES TO IMPROVEMENT LESSONS IN NUREG-1275 87lol60076 October 12', 1987

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MANAGEMENT LESSONS, l1 Ik 0

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1) Establish an operating plant mentality well prior to initial criticality.

NUREG-1275 Lesson Ensure 'that plant operations personnel have the responsibility for operating all equipment as early as possible in the construction completion process. Take early, complete control of the transition from construction to operation. (OL)

ANPP Res onse The operating philosophy at the Palo Verde Nuclear Generating Station (PVNGS) has always been that permanent plant personnel should be involved in plant startup as early as possible. As a result, all three units were manned by members of the Operating Department on an around-the-clock basis before the electrical busses were energized from the startup transformers. In Unit 1 this occurred during the fourth quarter of 1981, Unit 2 was manned in the 1st quarter of 1983, and Unit 3 operating personnel began around-the-clock startup support during the first quarter of 1985.

4 Unit 3 plant operating personnel have been involved with system and integrated system. testing throughout the startup program. All systems necessary for the pre-core hot functional test were under the control of the operating organization prior to the test. Many of the operations personnel in Unit 3 received prior experience in either Unit 1 or Unit 2, in fact, 12 of the licensed personnel meet the hot experience requirements. Hot experience is defined as at least six months of hot experience on a same type plant, including at least six months at power levels greater than 20X of full power and startup and shutdown experience. The average time spent in the control room, with power level greater than 20X, for the Unit 3 SROs is 6.8 months.

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NUREG-1275 Lesson Have personnel who will be responsible for maintenance and testing of plant systems after licensing begin these activities using post-licensing procedures before fuel load. This lets procedures get debugged, and the plant staff gains experience in working under licensed conditions. '(OL)

ANPP Res onse The philosophy of the maintenance groups at PVNGS is similar to that of the operating organization, i.e., to become involved in the day-to-day activities as early in plant life as possible. During the startup of Units 1 and 2, the maintenance groups assumed responsibility for procedures and maintaining plant equipment after the turnover from the .construction organization to the startup organization had occurred. Experience on Units 1 and 2 had shown that this was a good practice, and the same approach was taken in Unit 3. Unit 3 also benefitted from the experiences in the other units, since the foreman for the Unit 3 maintenance crews were

,promoted from the ranks in the other units. This has provided Unit 3 with a strong, experience base on which to build.

Since the operating organization assumed control of the systems in Unit 3, as was done in Units 1 and 2, the Palo Verde maintenance and engineering organizations have been responsible for maintaining and testing the systems and equipment in the unit. Maintenance and testing activiti'es are accomplished through the use of approved procedures which have been proven by use in Uni'ts 1 and 2. The Palo Verde I&C Department also. provided personnel throughout the startup program for initial calibration and'esting of plant instruments. Again, established plant procedures were used whenever possible.

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NUREG-1275 Lesson Stress the ,importance of details, the need for discipline in following procedures, the need for awareness of plant conditions and the regulatory requirements associated with these coordination throughout the plant staff, and the need for conditions'ight expedited resolution of problems. (OR)

ANPP Res onse ANPP has experienced problems with personnel deviating from established procedures in the past.. Below is a summary of activities and actions taken to prevent further incidents.

April 1982 Falsification of electrical termination cards by Bechtel Construction personnel.

Turley Tape I Attention to detail individual responsibility for complete and proper documentation.

November 1984 Turley Tape II Fitness for Duty Verbatim Compliance with Procedures.

April 1985 Van Brunt Tape I Safety and Quality Attention to Detail Know and Follow Procedures.

January 1986 Published article in "Reactor" Dealing with Seabrook Event.

February 1986 Quality Talks Fraud and Falsification Individual Responsibilities.

March 1986 Quality Talks NRC Perspective of Falsification Discussed Seabrook Event.

June 1986 Memo from J. M. Allen to the Unit 1 and Unit 2 Superintendents concerning Tech. Spec. violations.

July 1986 Memo from J. R. Bynum to all PVNGS personnel concerning prevention of personnel errors.

December 1986 Radiation Protection Technicians Falsification of Surveil'lance Plan.

Sampled RP, Fire Protection, Operator Logs and Compared Against ACAD Transactions.

Published Article in "Reactor",' This Event and Seabrook Event.

Quality Talks issued on Seabrook Event Emphasizing Individual Responsibility.

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Personnel Department Evaluation Conducted to Determine if Human Factors such as Morale, Working Conditions could be contributory cause.

May 1987 Security Guard 'Ealsification of Rounds.

I Reviewed signi'ficant sample of security logs and ACAD transactions.

.May '1987 Rad'iati'on Protection Technician Falsified Sample Plow Verification.

,Van 'Brunt Letter reiterating falsification seriousness.

Reviewed sample of RP logs and ACAD transactions.

Evaluation -by Compliance of other actions to minimize falsifications.

June 1987 Memo from J. M. Allen to the Unit Superintendents and the Operations Support Supervisor concerning adverse trends in performance indicators.

July 1987 Memo from J. R. Bynum to all PVNGS personnel concerning radiation work practices.

Corrective actions taken for specific events were appropriate.

A11 personnel recognize seriousness of falsification.

Additionally, during the annual requalification for maintaining, unescorted access to the PVNGS site, adherence to procedures is discussed', and a video tape on fitness for duty, featuring Mr. Van Brunt is presented. Initial training for new employeesp includes these two subjects, as well as a presentation of the two Turley tapes and the Van Brunt Tape I.

ib NUREG-1275 Lesson Minimize continued'onstruction activities for fuel load that may have an adverse impact on plant operations.. Reduce plant staff to operational size, remove construction equipment, and establish housecleaning programs. Bring AE,, NSSS vendor key personnel onsite so that problems can be resolved'romptly when discovered. (OL)

ANPP Res onse Construction activities are complete in Unit 3 and construction equipment has been removed. The last system .was turned over to the operating organization in January 1987, and fuel loading was completed in April 1987. The unit is currently staffed to the levels needed to operate and complete the power ascension test program. With .the exception of a few NSSS vendor technicians and engineers, the staff consists of permanent plant personnel.

Permanent plant procedures are i'n effect for the unit including those for housekeeping, maintenance and operation. When problems have developed, ANPP has made use of vendors, e.g., diesel generator, Unit 1 LPSI pump problems, and'nit 1 circulating water system valve failure., The status of construction and testing at PVNGS Unit 3 were the subject of two letters to the NRC written earlier this year. They are:

1) Letter from J. G. Haynes (ANPP) to J. B. Martin (NRC) .dated January 30, 1987.

Subject:

Construction Status and Operational Readiness Report.

2) Letter from E. E. Van Brunt, Jr. (ANPP) to Dr. Harold R..

Denton, dated March 13,, 1987.

Subject:

Certification Regarding, the Design, Construction, and Pre-Operational Testing of Palo Verde Nuclear Generating Station Unit 3.

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NUREG-1275 Lesson Conduct a deliberate, evenly paced, thorough and well-planned pre-operational and startup test program.

Conduct thorough reviews and dry runs for planned testing and allow time for additional testing during either the pre-operational or startup testing program. Emphasize planning to reduce the frequency of unplanned scrams and unnecessary ESF actuations. 'A detailed review of operational experience of similar plants should be a principal guide to the areas needing additional attention. (OL)

Minimize .the number of deficiencies and outstanding items carried forward. Establish a policy of complete resolution before proceeding. (OL)

ANPP Res onse PVNGS Pre arations for Startu Testin At PVNGS there have been extensive preparations for the Post OL Startup Test Programs conducted on all three units. Naturally, the preparations for testing on Unit 1 relied on lessons learned from the recent startups of similar plants. Because the PVNGS units are replicate the preparations for Unit 3 startup have concentrated more on utilizing the experience and the practices that have been developed in previous testing at Unit 1 and Unit 2.

Preparations for Unit 1 Post OL Testing began as early as 1980, about five years before fuel load, when ANPP engineers began making trips to observe the startup test programs at simimlar CE plants (Arkansas Nuclear One-Unit 2, SONGS, and Calvert Cliffs). Prior to the completion of the Unit 1 startup testing, at least 12 ANPP Engineering Department personnel made these trips, and incorporated their lessons learned into the planning for the Unit 1 startup. In parallel with these efforts, a relatively large number of experienced contract startup engineers, including NSSS vendor personnel, were brought on-site to help in the preparations for testing. In each case these engineers were brought in to help train the permanent ANPP engineering staff as well as to work directly on the Unit 1 testing. Fifteen (75X) of these startup engineers have been retained for Unit 2 and now for Unit 3 startup testing.

Many special preparations were made for the Unit 1 startup tests.

There were comprehensive training programs for all the Engineers and techs who would perform the tests, and for the Unit 1 Operations staff. This began with classroom training lead by the Engineers who were assigned to direct the individual tests. In addition, selected tests were "drymun" on the PVNGS simulator, using the actual test. procedures performed by the test engineers

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and the Unit 1 operating crews. As the actual testing program began there were detailed pre-test briefings held on each test, agai'n with both the test engineers and the operating crew participating. For some of the more involved tests, such as the Natural Circulation Test, more classroom training was given approximately a week before the test performance.

For Unit 2, and now for Unit 3, the emphasis for test preparation

.has changed'omewhat to an emphasis on the following:

continued use of previously proven test procedures which are reviewed for any "lessons-learned" improvements that can be applied (but generally no changes to the proven test method).

use of test and operations personnel,who have experience from previous PVNGS test programs.

The test program and the test procedures for Unit 3 are essentially the same as for Unit 2, with minor reductions in scope. The test program for Unit 1 was. a fifty week task due to "first of a kind" testing. The Unit 2 program lasted approximately 35 weeks, and the Unit 3 program is scheduled for 27 weeks. All the licensed operators on Unit 3 have previous operating experience on either Unit 1 or Unit 2, and the majority of licensed operators have experience during a PVNGS startup test program. Nearly all of the engineers who will direct the Unit 3 tests have previous PVNGS test experience.

For Unit 3, like Unit 2, there will be detailed pre-test briefings on the individual tests. A1so, as was done in the other units, the Test Results Review Group (TRRG) will look at the results of all

'ests performed at- each plateau. The review is directed at the results and ',the 'acceptance criteria with 'mphasis placed on any Test Exception Reports. This review is completed and the results deemed to be satisfactory before management allows a power increase to the next, plateau.

Resolution of Carr over Test Items

.PVNGS h'as .' ,'ystematic approach to identifying and resolving "carryover" test items from .the preoperational through the power ascension test phases. This program, which is described below, has proven successful on Units 1 and 2.

Beginning with the preoperational test program, all identified test deficiencies are documented and reviewed by the Startup Test review group (see FSARChapter 14). Open carryover items are defined to the Engineering Department for resolution. For each of the three PVNGS uni'ts there have been about 400 open items identified (from about 100 preoperational tests)'. The assigned engineer reviews the open items under his system (or test)'esponsibility and recommends a resolution. Usually the resolution is for a retest to be performed after corrective work has been completed. Along with the

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recommended resolution, the .assigned engineer defines a MODE restraint or .power plateau restraint when the carryover resolution must be completed (work done and tested). Prior to ascension to each new mode and,each new power plateau during the initial .startup test program, the list of carryovers is reviewed in detail to assure that all restraints related to carryover items are satisfied for that ascension.

In a similar manner, any. open test item that arises during Post OL, startup testing is identified on a "Test Exception Report". These are also reviewed in detail, and closed out if they are identi'fied as restraints, prior to each ascension to a new mode .or power plateau.

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>l NUREG-1275 Lesson Organize .the IGC staff to establish accountability for specific equipment. (OR) ANPP Res onse The engineers assigned'o the I&C'epartment are responsible for specific systems or subsystems. This responsibility includes-developing "the maintenance and surveillance test procedures as well as assisting the troubleshooting process. At ,the technician level, individual technicians have been trained" to become experts in specific areas. These areas include: 1), Rad'iati'on monitoring ') Meteorological instrument systems

3) Metrology

4) Component rework

5) Ancillary Building Pire Detection Systems Additionally,, the on-site computer operations group has developed'ystem experts whose responsibilities include:

system design, maintenance activities, .procedure development, field engineering of system level problems, troubleshooting assistance, and operations support. This system level expertise has been developed for all computer based .process systems, ,with specific attention directed to the plant security system, the emergency response facility data acquisition and display system (ERFDADS), the plant multiplex system (PMUX), the core protection calculators (CPC)., and the plant monitoring and core monitoring system (PMS). If ~ II I If Le

5) NUREG-1275 Lesson Give, high visibility to the sources (i.e., organizational element) of unplanned scrams (and other unplanned events) caused by human error and establish performance goals. (OR)

ANPP Res onse ANPP has four programs by which events are analyzed, causes determined, and recommendations are made. The first is the Plant Trip Review (PTR) which is implemented when there is a plant trip. The PTR determines the cause of a trip, evaluates plant and equipment responses, determines if personnel responses it ,were provides for ,adequate, makes recommendations for management; and management review and approval of a plant restart. The second of these processes is the Event Evaluation which is implemented for events which do not cause a plant trip, e.g., a reactor power cutback. The process includes many of the same elements as the PTR, but it does not require a team to be assembled. The Root Cause of Pailure Analysis which is:the third of these programs has developed over a period of time into a very rigorous process that is implemented 1) if a component failure has caused entry into a T.S. action statement or would have if the plant had been in the applicable mode, 2) if the maintenance planner coordinators note .that two or more failures of the same component have occurred, or

3) if the Nuclear Reliability group has noted that failures exceed industry average or,a predetermined number of failures. The final program, Interdepartmental Event Investi'gation, is specifically concerned with personnel related events, and it is a management review. The Plant Manager and his direct reports interview the affected personnel, detexmine the facts, and formulate a resolution.

PVNGS has established a performance indicator program which meets the INPO criteria. In addition, a trending program, which is illustrated by the attached graphs (data is through 9-30-87) is maintained by the Compliance Department. The Compliance Manager periodically briefs executive management on the program results. When unfavorable trends begin to develop, remedial programs are developed, and the results observed to determine if they are satisfactory. Positive results are then factored into plant programs to keep unfavorable trends from developing. 0 0 LER's PER UNIT PER QUARTER 25 25 25 (TS-18) (TS-11) (ST-5) (ST-3) (TS-15) 22 19 (ST-9) (TS-15) (TS-9) 20 (ST-6) (ST-5) 20 (TS-4) (ST-3) 17 (TS-10) 15 (ST-5) 15 Vl 0 rr(TS-7) 14 (TS-6) (ST-1) \ 11 (TS-9) t)) I 12 (ST-2) (ST-3) 9 (TS-6) 10 /I (TS 6) (ST-3) (ST-4) z I I lI I 7 1 (TS-4) r (TS-4) \ (ST-1) 5 (ST-2) 5 4h'~ 'tTS S) 1 (TS-1) (TS-1) (TS 3) (ST-2) . (ST-1) (TS 0) (ST-O) (TS-0) (ST-0) ( S 0) go ~ ~ ~ ~ ~ ~ ~ o+ (TS 1 ) ST-1) 1st 2nd 3rd 4th 1986 1st 2nd 3rd 4th 1987 1st 2nd '3rd 1985 QTR QTR QTR QTR ~ QTR QTR QTR QTR QTR QTR QTR UNIT 1 UNIT 2 a~mma QUARTERS SINCE THE ISSUANCE OF THE OPERATING LICENSE TS- Technical Specification Violations UNIT 3 ~ ~ ~ ~ ~ ~ ~ ~ ~ ST- Surveillance Test Deficiencies Partial 0 II II UNIT COMPARISON LER's PER COMPLETE QUARTER SINCE ISSUANCE OF OPERATING LICENSE U 25 25 25 (TS-18) (TS-11) (ST-5) (ST-3) (TS-15) . 22 (ST-9) (TS-15) 20 20. 19 (ST-6) (TS-9) (TS-4) g (ST-5) (ST;3),. \ 17 \ (TS-10) '5 I (ST-5) 15 ~A >4 (TS-6) 0 r~ (TS-7) 11 12 6'ST-2) . (ST-1) (TS-9) (ST-3) (TS-6) (TS-6) 10 (ST-3) (ST-4) R \ r r 7 7 (TS-4) ~~'5 (TS-4) (ST-2) (ST-1) 1 4 - (TS-5) 43 (TS-0) 4 (ST-2) (TS-3) (TS-1) 3 (ST-0) .. (ST-2) (ST-1) (TS-1) .( ST-1) ~ ~ ~ ~ 1st '2nd 3rd 4th = 5th 6th '7th 8th 9th 10th 11th QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR UNIT 't UNIT 2 COMPLETE QUARTERS SINCE OPERATING LICENSE TS Technical Specification Violations UNIT 3 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ST- Surveillance Test Deficiencies 'Partial Cl OCCURRENCES INVOLVINGPERSONNEL PER UNIT 25 20 (12) 20 19 (8) 19 (3) 0 z K 15 D 0 '0 13 (8) 0 11 (6) 0 11 (2) 10 (7) 10 9 (5) 8 (7) D Z I r I I 6 (4) I 4 (3) 4(2 r 4 (3) 3 (1) ~2(2) 2 (2) 3 (3) 2 (2) >(1) 1st 2nd 3rd 4th 1986 1st . 2nd 3rd 4th 1st 2nd "3rCI 1985 1987 QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR UNIT 1 UNIT 2 = ~ UNll;"T 3 '~~ NO QUARTERS SINCE THE ISSUANCE OF THE OPERATING LICENSE OCCURRENCES ( ) Procedure Violations "PARTIAL 0 UNIT 1/UNIT 2 COMPARISON ~ OCCURRENCES INVOLVING PERSONNEL PER COMPLETE QUARTER SINCE ISSUANCE OF OPERATING LICENSE 25 20 (12) z'3 20 19 (8) 19 (3) O z 15 D O 0 (8) 0 0 l1 (2) 10 (7) 11 (6) g 10 9 (5) 8 (7) D 6 (4) 4 (2) 3 (1)+~~ ~er rrA~ 4 (3) ' 3 (3) 4 (3) 2 (2) 2 (2) 2nd 3rd 4th 5th 6th *7th 8th 9th 10th "11th QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR COMPLETE QUARTERS SINCE OPERATING LICENSE UNIT I . UNIT 2 aw~mw Procedure Violations 'Partial ( ) UNIT 3 --NO OCCURRENCES 0 i1 il UNPLANNED REACTOR TRIPS PER UNIT 6 6 6 I I-0I-5 II 0 I \ 4' 4 I I K 3 D II ,2 2 Z 2 P l' 1 II 1h pl I imp j l 1 p 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd ".3rd QTR QTR OTR QTR" OTR OTR OTR OTR'TR OTR QTR QUARTERS SINCE ISSUANCE OF THE'OPERATING LICENSE ~ 'i "PARTIAL UNIT 1 UNIT 2" 0 II UNIT 1/UNIT 2 COMPARISON UNPLANNED REACTOR TRIPS PER COMPLETE QUARTER SINCE ISSUANCE OF OPERATING LICENSE 6 K llll 0I-5 lI 0 I fll K 4 I 0 II LU 3$ 3 D Il z lII 2 / lIl f 6 lI Pl'0 1st 2nd 3rd 4th 5th 6th *7th 8th 9th 10th *11th QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR COMPLETE QUARTERS SINCE OPERATING LICENSE UNIT 1 *PARTIAL UNIT 2 ~ h, II 0 4l ESF EVENT REPORTS PER UNIT (Includes RpS Actuations) 20 17 16 CO I- 15 CC 0CL 14 UJ 13 lZ Z 12 0 Ln 11 (Q 4'~ D 10 I- gl 0 9 8 0 K 7l \ ill 7 IQ D z r 6 '3 2 2 2 2 1 b. Qospo ~~ e ~ ~ ~ ~ ., ~ 0 .1 "~ ~ . 1st 2nd 3rd 4th ~986 1st 2nd 3rd 4th 1987 1st 2nd *3rd QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR QTR UNIT 1 UNIT 2 ~ QUARTERS SINCE THE ISSUANCE OF THE OPERATING LICENSE ,*PARTIAL UNIT 3 s ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 0 UNIT CO PARISON TOTAL ESF EVENT REPORTS (includes FtPS Actuations) 20 PER COMPLETE QUARTER SINCE ISSUANCE OF OPERATING LICENSE l6-P 15 14 13 12 0 11 10 9 O 9 8 0 cc 7 ~At fQ (y,W D 6 6 5 4 2 -.2 2 8., ~ ~ o~ r 1st 2nd 3rd 4th 5th 6th *7th 8th 9th 10th *11th QTR QTR QTR QTR . ~ QTR QTR 'TR QTR QTR QTR QTR COMPLETE QUARTERS SINCE OPERATING LICENSE UNIT 0 . *PARTIAL UNIT 2 so~~~~ UNIT 3 e ~ ~ ~ ~ ~ ~ ~ ~ 0 0 il NUREG-1275 Lesson Ensure that operating experience feedback programs: (a) combine internal events and relevant events from similar plants, (b) communicate them directly to the appropriate first level supervisors and working, level staff at the plant on a periodic basis, and (c), address preventive measures.. For example, segregate the trip and'SP actuations data involving human errors 'from recent plant startups into the specific positions, organizational or functional element, working activity,. systems and components, time of day, etc. Feed this information ba'ck at the lowest levels so that the experience of others, the complexity of what is being done, and the ramifications of errors can be seen and appreciated. (OR) ANPP Response PVNGS has developed feedback programs by, which informati'on is passed downward as well .as upward. The Operating Department Event Report (ODER) is an example of a system by which information from events at PVNGS or other plants is passed to all operators as well as the Training Department. Additionally, the 'ODER is used'o pass on information contained in Plant Trip Review, Reports and special investigations. , Whenever an event occurs which dictates an immediate need for information,, night orders are written in all of the,.units. An example of systems in which feedback is requested from lower evels. is '>>the procedure feedback system. Employees are encouraged to provide feedback to .the groups preparing procedures whenever improvements, are needed or .desired. The procedure feedback system proyid'es for . a. response to the originator so that he knows, his suggestion has 'been reviewed.. Whenever the review of operating events indicates that a particul~ group appears to be responsible for several similar events, an analysis is done to determine and what it if additional training is necessary should consist of. :Reviews of procedures would also be done to determine if any procedural deficiencies are the cause. In the past, this kind of revi'ew has determined that both procedure changes and additional training were needed, e.g., feedwater control system events. Operating experience at other nuclear power plants is. sent to ANPP by the NRC, industry, organizations (INPO,, EPRI,. etc.) and various vendors The types of information range from problems associated with components to describing an improved method to perform a certain task. Nuclear Licensing and the Independent Safety and Engineering Group each use a proceduralized program to distribute operating experience information internally and track the documents to their final closure upon receipt of sufficient response information. 0

7) A number of improvement lessons are directed at training as follows:

a. NUREG-1275 Lesson Establish as a major goal an increased commitment to training in performing surveillance testing, calibration, and troubleshooting activities well prior to operations. I&C training initiatives, such as repeated practice for those surveillance testing activities that could cause a transient and which should be conducted on actual in-plant equipment on live systems prior to operations, should be emphasized. An additional action to improve surveillance testing suggested by licensee staffs was training for I&C personnel in valving instrumentation in and out of service. (OL/OR)

ANPP Res onse PVNGS maintenance personnel receive training according to their respective disciplines. They receive theoretical training, but the emphasis is on practical training in a training laboratory. The training lab concept allows for the use of hands on training on actual equipment using plant specific procedures. Training lab equipment includes such things as plant protection system panels, process instruments,, full size steam generator primary head, multiple stud tensioner, motor operated valves, circuit breakers, and an inverter. Additional equipment is being purchased to allow training on additional plant equipment. The Mechanical, Electrical, and I&C Maintenance groups have established a goal to have all skilled personnel complete the respective maintenance traini'ng programs, within 2 years of receiving accreditation from INPO.

Prior to implementing the surveillance test program in each unit, the'ead ILC Maintenance Engineer conducted training on surveillance testing for the I&C technicians. The training covered the administrative controls associated with surveillance testing; sections of the Facility Operating License, including the Technical Specifications; the surveillance test procedures, and the responsibilities associated with surveillance testing.

I&C Department staff meetings have been used to discuss instrument calibration philosophy and analytic troubleshooting. Personnel have raised questions during these meetings, and answers were provided at the time or were disseminated when the answers were known. During these meetings, the subject of valving instruments in and out was discussed. As a result of these discussions, labeling was provided on instruments which identifies the reference leg. The labeling was done by using a prominent orange placard. i1 T These discussions also resulted in the addition of independent verificati'on steps to procedures:. for valve ,manipulations upon completion of work. Caution notes have also been added to procedures which address .work on common legged transmitters. 4 tl ,I 4i NUREG-1275 Lesson Emphasize training for routine operations involving power level changes and the associated communications among shift ,personnel (i.e., feed'low and'-turbine evolutions) that have historically'aused 'rips. Accelerated programs/efforts appear appropriate for newly licensed plants regarding steam generator level control. Emphasize the need for site specific simulators to include, prior to startup, the best achievable fidelity of the simulator to the plant regarding feedwater effects (lead/lag characteristics of level indication and control methods) and include provisions to continue to improve fidelity as the startup progresses. (OR) ANPP Res onse ANPP decided in 1975 to acquire a plant specific simulator to be used to train operators for the Palo Verde units. The simulator, which was state of the art, was placed in operation in October 1980, long before actual plant data was available, and much sooner than it was known what would be As data became needed to implement post-TMI requirements. available from the Unit 1 startup, changes were made in the software to upgrade simulator fidelity, however, some fidelity improvements defied simple software changes. The fidelity problem proved to be inherent in the modeling scheme of the Simulator and as a result, an aggressive multi-million dollar program was established to upgrade the simulator. ANPP plans to spend approximately 46 million over 5 years, 52.5 million have already been committed. The upgrade program includes a new computer which will add 50X more computing capability. The computer is being supplied by the manufacturer of the original computer, and it is similar to the present equipment. The additional computing capability will allow new RCS'nd reactor models in which two phase conditions can be modeled. A1so improved steam generator modeling will allow more accurate feedwater control and natural circulation simulation. Presently, the hardware is scheduled for delivery in mid-October, 1987, and the modeling to be completed in Mid-April 1988. Throughout the simulator portion of the licensed operator training program, teamwork and communication is stressed. The same subjects are also stressed in the requalification training. The PVNGS Emergency Operating Procedure has discrete steps which require the operators to communicate certain information to the control room supervisor. IL'i h c., NUREG-'1275 Lesson i Establish extensive, detailed training for all segments of the onsite plant staff, including IGC'echnicians, maintenance mechanics, security staff, operations, and management. (OR) This training would emphasize: (a) the applicability o'f the various TSs to the changing plant modes of operation and associated schedules, (b) the relationship of the TSs to the plant procedures, (c) the 'NRC requirements for reportability of violations,, and (d) the basis for the TSs and discussion of LCO requirements. ANPP Res onse Due: to the experience on Units 1 and 2, we have recognized the need to place more emphasis on technical specificat'ion requirements and overall training. t The Technical 'Specifications (TS) and procedures are extensively covered in RO/SRO training. During requal training, amendments to the TSs are discussed, as are changes to procedures. Other disciplines conduct training on TSs in their OJT programs, appropriate to. their needs. Technical staff training also deals with the appropriate sections of the TSs and procedures. The Security Department is responsible for training of the security staff, and their training includes reportability requirements for violations. Besides training, ANPP has learned'hat the detailed completeness of procedures implementing work activities is equally important. As a result of lessons learned, we have additional reviews of those procedures implementing technical specification requirements to assure their accuracy and completeness. Also,, a master procedure which crossmeferences the technical specification surveill'ance requirements with implementing procedures was developed as a second check fror completeness. We have improved our training programs. As an example, training program improvements resulted in gob/task analysis that develop learning objectives which support job needs. In addition, ANPP is participating in the INPO training accreditation program. ! 4 If 4 44 <<R ~ I ~ 4! II PVNGS has 5 programs which have been accredited by INPO; they are: Non-Licensed Operator,, Reactor Operator, Seni'or Reactor Operator/Shift Supervisor,, Shift Technical Advisor,, and Technical Staff training programs. The remaining '5 programs should be accredited in early December 1987.; these are: Mechanical Maintenance, Electrical Maintenance, IGC Maintenance, Chemistry, and Radiation Protection programs. We have made all necessary submittals and have completed the team visit. The accreditation of training programs has resulted in job/task analysis that develop learning. objectives which support job needs. ~c -c II 0 0 EQUIPMENT LESSONS Cl il

1) NUREG-1275 Lesson Focus on the BOP prior to operation and early in life appears to provide a high return regarding the reduction of unplanned scrams and Within this area, attention could be given to: ESF'ctuations.

Conducting additional reviews of feedwater and turbine control and bypass systems to identify sensitivities and plant-specific characteristics that could'ontribute to transients or the ability of the system to cope with expected transients. (OR). Conducting a systematic review of equipment-protective logics and setpoints on components such as pumps '(suction trip, time delay, vibration trip) or power supplies to identify,. areas where .a time delay or additional channels for coincidence could reduce the potential for unnecessary transients or spurious actuations. ,give special attention to first-of-a-kind features not incorporated in earlier designs. Additional examples obtained from the plants visited include the main steam reheater drain high level trip and other turbine protective trips. .(OR) ANPP Res onse ANPP has established a group of engineers within the Nuclear Engineering Department to,perform. studies and analyses which .have the potential to increase plant reliability and availability. The Nuclear Reliability Group has initiated various programs to improve plant availability and reduce the number of unplanned scrams. Examples of programs which have been initiated to improve plant availability and/or to reduce the number of plant challenges to plant safety systems include: (1) Failure Data Trending Program (2) Centered Maintenance Program 'eliability (3) Scram Reduction'Program, (4) Probabilistic Risk Assessment A description 'of each of these programs follows: l I. Scram Reduction Program The Scram Reduction Program was initiated in late 1986 to proactively identify single failure Scram vulnerabilities. Major program emphasis between late 1986 and mid 1987 .was'o identify single failure vulnerabilities, in BOP Control Systems. As part of this effort, detailed Failure Modes and Effects Analysis (FMEA's) were performed on the following systems: (1)'2) Feedwater Control System Steam Bypass Control System (3) Reactor Regulating System (4) Pressurizer Level Control System (5) Pressurizer Pressure Control .System ~. ~ - i. I ~ il 1 1 4 I il~ As a result of this analysis, numerous single failure vulnerabilities were identified in the Feedwater Control System, and engineering evaluations initiated to evaluate the feasibility of plant upgrades. As a result of this program, Plant 'Change Requests have been initiated to improve the reliability of system nest'ower ,supplies. Add'itional engineering evaluations are ongoing.'n 'nalysis was also performed to identify potential trip vulnerabilities due '-to interactions between point control systems and plant monitoring systems. A systematic analysis of over 4000 plant monitoring, system data interface points was conducted. As a result of ,this analysis, engineering evaluations are being initiated to evaluate the feasibility of reducing trip vulnerabilities which were i'dentified'uring the course of this analysi's. A separate program has been initiated to identify mechanical and electrical component failures. which may result in reactor Scram. The major emphasis of this program to date has .been the: development of a balance of plant computer simulation model. The goal of this program is to develop a balance of plant {BOP) simulation model by mid 1988, such that the effect of BOP electrical and mechanical failures can be reliably predicted. Failure Data Trending Program Arizona Nuclear Power Project recognizes that the failure of a plant .component is a very useful source of information .to identify areas of plant design or maintenance which warrant additional attention. As part of the root cause identification program, ANPP has initiated a significant effort to provide a computerized. data base of component failures, which can be easily accessed in an interactive mode by system engineers to identify failure trends. This system will be used to automatically initiate quarterly Root Cause Analysis requests when PVNGS components exceed threshold failure criteria. 'By this, process, component failure information can be efficiently used to identify modification which will extend component life and/or improve the reliability of plant components. This ,process. will be used, .both to reduce the number of safety system demands,, and to improve the reliability of plant safety systems. ANPP participated in the INPO Safety System Unavailability Monitoring pi'lot program which started in 1986. We have incorporated this program into the present Failure Data Trending Program. The Failure Data Trending Program is an ongoing program which is scheduled to be operational in the 4th quarter of 1987. II II c vI III. Reliability Centered Maintenance Program: a~ Brief Description The Reliability Centered Maintenance (RCM) Program is plant specific, and it provides a systematic process of function, equipment for considering system functions, loss safety, personnel safety, and economics to identify applicable and effective PM tasks. The result is a systematic set of PM tasks to counter specific and probable failure of equipment and system functions. The new approach shifts away from an emphasis on attempting to restore equipment to an ideal state, to a focus on maintaining function. Thus, there is a diversion from performing what may often be aribtrary or vendor specified time-directed procedures. This will require identification of measurable changes that can be correlated to functional failure. RCM consists of the following steps: Collection/Compilation of relevant system information. 2~ Definition of system elements, boundaries and interfaces. 3~ Definition of system functions.

4. Definition of system functionalI failures.

Identification of dominant failure modes for functional failures. 8'dentification o', cause

6. and effect of the failure modes.

7~ RCM decision logic. Identification and selection of applicable PM tasks.

9. Establish PM. task intervals.

10. Identify potential design modifications.

ll. Two RCM functional FMEA generic modules. The initial, program involved the development of RCM analysis and support documentation for the Nuclear Cooling Water and Diesel Generator Systems. The Nuclear Reliability, section participated in the development of the fault trees, logic trees to prioritize functional failures and modes. SAIC was selected as the prime contractor with ERIN engineering as a support contractor. The Project was co-funded by EPRI and by the Maintenance department and Nuclear Reliability group within ANPP. The Nuclear Reliability section will work with the Maintenance and Plant Standards and Control Departments to prioritize additional systems that would benefit from RCM analysis. Further RCM work cou1d be done in house or contracted as needed. F, ~O 4 4 (L L I' L I r I I I 'll 4 I r II 'I Il I-

b. Expected Benefits The RCM program will allow maintenance workload to be managed such .that plant availability and plant safety is maximized.

In conjunction with the Availability improvement program, RCM has the potential to ,provide substant'ial cost savings and improved system reliability for ANPP. The,maj'or benefits include: A significant reduction in the manhours 'spent during unnecessary preventive maintenance. A,potential increase in system reliability., A reduction in expenditures for parts replaced in preventive maintenance activities using condition directed maintenance where possible. ! f An improvement in plant availability due to a better awareness by maintenance personnel and program -focused on component failures and their relationship to plant safety and availability. A,potential reduction,in, manrem exposure to maintenance personnel.. A methodology for reducing existing maintenance backlogs, without compromising system reliability. IV. Probabilistic Risk Assessment A level 1 Probabilistic Risk Assessment is being developed for the Palo Verde units to identify potential accident sequences. Although the primary focus of the PRA is to identify methods to reduce plant risk rather than the number of safety system demands, the PRA effort does include a major effort to identify BOP initiators which contribute significantly .to plant risk. BOP initiators identified as contributing significantly to plant risk will be evaluated to determine if plant changes are project is intended to meet the generi'c IPE requirements of ,warranted'his the Severe Accident Policy. The PRA for PVNGS is presently ,scheduled for completion in December 1988. In summary, Arizona Nuclear Power Project has and is continuing to allocate significant resources to identify potential Scram vulnerabilities. Additionally, when corrective action has been shown to be cost beneficial the project has aggressively pursued appropriate corrective action. 'l l f 1 '\ 0 I' a L. L. "J l '," gc P 1 4 L.C I tk; ~ W . 4 F I )It ~ ) II ~ li,)a'I E a 'I li'g>'

2) NUREG-1275 Lesson Install test jacks and bypass switches at appropriate points in actuation circuitry. (OR)

ANPP Repsonse Test jacks, test circuitry, and bypass switches have been installed at PVNGS and no new ones have been identified as being required. An engineering evaluation is 'being done at the present time to determine the feasibility of adding bypass devices to the Steam Generator Low Pressure trip and ESF actuation system. This change in conjunction with a change to the Techni'cal Specification appears to be desirable at this time. 4 a >Its L A 'l$ 8 ~ ~ ~i" A I t I

3) NUREG-1275 Lesson Implement on a priority basis vendor or licensee trip reduction measures. Licensee trip reduction .programs should focus on safety-related equipment as well as on BOP equipment. (OL)

ANPP'es onse ANPP endorses actions to reduce causes for unit trips, please see response to Equipment Lesson 81. In addition to those programs, which are being developed, ANPP has implemented specific trip reduction programs on safety related and'OP equipment. Since most safetymelated equipment is related to accident mitigation and post accident operab'ility, as opposed to power generation and unit tripping, the major benefit can, be gained on the BOP sid'e. Several examples - of these measures are as follows: A. Fast Bus Transfer Scheme Modification During ,the Unit 1 Power Ascension Test Program, the fast bus transfer was usually accompanied by a reactor trip and the loss of some station loads. The fast bus transfer is designed to transfer the non-class IE station service busses from the Auxiliary Transformer to the Startup Transformer without causing a reactor trip and the loss. of loads. An engineering investigation determined that ,the original syne-check relay, an electromagnetic induction type, was not suitable for high speed bus transfer application because of slow speed characteristics when used in that mode. Additionally, it was determined that a solid state undervoltage relay with a setpoint of 95.6X could'ause load shedding due to, a short term grid (500KV) disturbance. The synch-check relay was replaced'ith a high speed soli'd state device and the undervoltage relay setting was changed to 90X. Even though this increased the speed of the bus transfer and stopped the load shedding,, reactor trips still occurred. The reactor ,trips occurred due 'to a flow projected'NBR'-trip from .the Core Protection Calculator (CPC). The brief time that the bus was de-energized (3-4 cycles) was sufficient to cause the RCPs to slowdown enough to be detected by the 'CPC. A software change to eliminate the flow projected DNBR trip has been implemented; during the interim the units were operated with one unit on the startup transformer and One unit on its auxiliary transformer. As a result of the actions 'taken, reactor trips from this cause have been eliminated. t' r. II d

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C / , i(~ -.'-, > . Jk 0 '1 I ~ .; ~ t Subs nchronous Oscillation (SSO) Rela Mod Due to long transmission lines and series compensation on the. transmission system, generating units in the western states are susceptible to subsynchronous- resonance (SSR) effects. SSR occurs when the natural frequenci'es of the electrical transmission system and ,the mechanical turbine/generator become "on-tune". During ."on-tune" operation, oscillations'in the generator shaft torque can damage the shaft in seconds, or even cycles. 'Since this problem was identified as a result of incidents in 1970 and 1971 at a fossil"unit in Cali'forni'a, ANPP decided to provide protection for the;turbine generator. The SSO Relays (two per unit) protect the main turbine generator shafts from torsional oscillations by separating the generator, which transforms torsional frequencies from the transmission system into torsional oscillations, in the shafts, from the transmission system when shaft resonant frequencies are present. PVNGS Unit 1 experienced one trip from. this protection system. An engineering evaluati'on, including assistance from the relay vendor, determined that .the voltage sensing :circuit of the SSO relays had the potential of initiating. false trips. As result of this incident, each of the 'SSO'elays were modified, bench tested, and'ield tested (in a monitoring mode for 30 days) and then placed into normal service. Spurious trips from this system have been limited to,the one event in Unit 1. Reactor Power Cutback S stem, This system functions to rapidly reduce reactor power during loss of load and loss of feedwater pump transients by dropping, selected contxol rods into the reactor core. This feature was included in the original specifications for the design of the PVNGS units and has performed effectively to prevent reactor trips on in Palo Verde Units 1 and 2. The system has been several'ccasions installed in -Unit 3 as well. Hi h Ca acit Steam B ass S stem A high capacity steam bypass (to ,the condenser) ,system was purchased for Palo Verde,, also, as a result of the original design specifications for the PVNGS units. This non-safety related system functions during large load rejection in conjunction with the reactor power cutback system (see above) to prevent reactor trips. This .system has demonstrated its effectiveness during several events on Palo Verde Units 1 and 2, and is. installed in Unit 3 as well. tp II a P I p ~ r I r, C "f,, I I' Il A '-' W rr w r- If l W I J fl; r '~ 'f I II I 'l *l V I ~ If f I 'I 0 Core Protection Calculator Im rovement Pro ram As a result of participation in CE Owner's Group (GEOG) activities concerning Core Protection Calculators (CPC), ANPP has planned several improvements to the CPCs to be implemented at the first refueling outage for each unit. The changes are being made for several reasons including 1): prevention of unnecessary reactor trips, 2) improve operating flexibility, and 3) simplifying reload analysis. The changes to be made include: a) Addition of variable overpower trip. b) Revision to asymetric steam generator transient algorithm. c) Incipient CEA misoperation detection and CEAC desensitization to spurious signals. d) Deviation penalty factor simplification. e) Simplified flow calculation., f) Removal of flow projected DNBR calculation. g) Spline function selection algorithm improvement. h) Addition of ASI dependent parameters. i) Low power ASI display. g) Elimination of the augmentation factor array. These changes have either been implemented by the other plants with CPCs or are under consideration. Further information about these changes may be found in two submittals previously furnished by ANPP. They are: a) Letter ANPP-39452 from J. G. Haynes to G. M. Knighton, dated December 19, 1986.

Subject:

PVNGS 'Cycle 1 Core Protection Calculator (CPC) Software Modifications.

b) Letter 161-00321 from J. G. Haynes to USNRC Document Control Desk, dated June 29, 1987.

Subject:

Submittal of the Reload Analysis Report for Unit 1 Cycle 2.

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4) NUREQ-1275 Lesson Pay attention to the design and installation of equipment located in the vicinity of radiation monitors and associated cabling to ensure that adequate groundings of equipment, cable shielding, etc., are provided 'to prevent the occurrence of EMI, which can trigger this extremely sensitive instrumentation. (OR)

ANPP Res onse We believe that our previous noise probl'ems were a result of EHI. A new RMS grounding design incorporated in Unit I has significantly stabilized the RMS response. Material availability problems have hampered the commencement of work in Unit II, and completion of work is expected by the end of the first refueling outage. Construction installation of the grounding system. is complete in Unit III and monitors are now being connected to the grounding'. system. Additionally, general maintenance activities conducted on other:plan't systems with attention to grounding of electronic circuits appears to have reduced the overall EMI related

',sensitivity of, the RMS system.

I Placards have been installed in various locations to warn individuals of radio frequency sensitive equipment in the area.

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5) NUREG-1275 Lesson Thoroughly test new or unique plant features, such as new RPS systems, electrical systems, etc , prior to fuel load to reduce unanticipated failures or unexpected erratic behavior. Emphasize planning to reduce the frequency of unplanned scrams and unnecessary ESP actuations. (OL)

ANPP Res onse Several unique plant features have been built into the PVNGS units (see item (3) above). These feature include:

1. Past bus transfer.

2. Subsynchronous Oscillation (SSO) monitoring.

3. Reactor power cutback system.

4. High capacity system bypass system.

5. Extended range feedwater control system.

6. Solid ptate load sequencer.

t Each of these systems or features was thoroughly tested during the startup program .and,some will undergo further testing during the power ascension testing. program. These systems were previously tested during the start-up and operation of Units 1 and 2, and problems were corrected or modifications were made to ensure that these systems operate as required in Unit 3', As an example, the fast bus transfer feature was extensively tested in Unit 1 during the power ascension and early commercial operation periods. A -number of problems were found and corrected and the modifications have been incorporated into Unit 3. The testing being performed in Unit 3 will further demonstrate that this feature performs as required. In this way unplanned scrams and unnecessary ESF actuations will be avoided.

Another example is the BOP diesel generator load sequencer. During the design and construction of this system questions were raised concerning the potential for "sneak circuit" problems in the microprocessor circuitry of this equipment. An extensive test program was undertaken prior to equipment delivery which identified some minor problems "sneak that were corrected in the factory prior to shipment. Although no circuits" were identified this additional testing helped to prevent unnecessary ESP actuations which could have resulted from these problems. In addition, all of the problems identified in the start-up programs for Units 1 and 2 have been corrected in the sequencer for Unit 3~

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6)'UREG-1275 Lesson For future designs or major plant modifications, preference for proven designs and'tandardization of design in plant feedwater and turbine systems appears )ustified. Conduct further analyses of any first of a kind, one of a kind, and state-of-the-art features, since they have generated a large number of problems during plant startups. (Examples of remedial actions are more extensive preoperational testing, reexamination of actuation logic to better achieve reliable indicati'on and actuation; for example, reanalysis .of actuation .on a single input or loss of a single input.) (OR)

ANPP Res onse As ANPP performs modification to the plant, we will continue detailed evaluation of first of ,a kind state-of-the-art modification. This process will include:

Betterment process places extensive long range financial and technical controls on modifications to prevent new equipment problems from being introduced into plant operation before it has been thoroughly tested .and proven.

a. Design review check lists insure experiments learned during startup and power ascension are factored into designs'.

Equipment bidders are evaluated extensively on operating experience of proven equipment.

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c. In shop tests .of .major.. equipment is a preferred bidding option when possible.

d. Design engineers. can specify special test precautions to prevent problems when equipment is put into service using NED Instructi'on 7I414.01.12.

2~ APS gathers information from other utilities through such sources as INPO, EEI, NPRDS, and EPRI. This information sharing provides a large base of problems/solutions to be considered in new designs of equipment and to be possibly incorporated into startup testing procedures.

30 The ANPP turbine vendor provides a technical information letter whi'ch discusses industry concerns that are factored into new design and'esting.

4~ PVNGS has strongly supported the standardization of design and will continue this philosophy to prevent one of a kind designs in each unit.

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Significant major system testing during OL will be performed by the system engineers in Operations Engineering. This group is well experienced from power ascension testing of Units 1 and 2 and are aware of the status of their'ystems. The system engineer works closely on a day to day basis with the work groups that perform the hands on modifications and the operator who will perform the active configuration changes. Procedures, will provide all cautions that have been gained during these years of experience to adequately test for ,past problems. System, Engineers will normally assist these personnel during the testing.

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7) NUREG-1275 Lesson Incorporate scram prevention measures such as:

Develop a color coding scheme for single point scram components whose misoperation could'ause a scram (for example, pressure sensing lines). (OR)

Install cages or covers over switches or racks that could provide trip signals. '(OR)

ANPP Res onse The original PVNGS design included labels for components which were color coded according to train/channel. This scheme has been implemented for switches/controls on the main control board (MCB), instrument cabinets and equipment in the units. It is apparent, when looking at a label, whether the equipment is safety train related or not.

As a result of the Detailed Control Room Design Review, ANPP determined that the application of some human engineering principles could help guide the operators to the proper area of the MCB for operation of various components. A zoning scheme, combined with coloring,. was used to segregate controls associated with a particular component/system. The scheme was tested in the simulator prior to implementing in the units.

The PVNGS control boards have recessed or covered switches to prevent unwanted operation of critical components. The use of these devices was implemented in the original design,,and operation of the PVNGS units has not indicated any need for additional guards.

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