ML17304B155

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Forwards Emergency Operating Procedures Insp Repts 50-528/89-08,50-529/89-08 & 50-530/89-08 on 890313-17. Response to Concerns Re Useability of Procedures Requested within 30 Days
ML17304B155
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/28/1989
From: Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Karner D
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML17304B156 List:
References
NUDOCS 8905150351
Download: ML17304B155 (8)


See also: IR 05000528/1989008

Text

AC CELE P>TED

I'lFTKBt'7l ON

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SYSTEM

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:8905150351

DOC.DATE: 89/04/28

NOTARIZED: NO

DOCKET

CIL:STN-50-528 Palo Verde Nuclear Station,

Unit, 1, Arizona Publi

05000528

STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi

05000529

STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi

05000530

AUTH.NAME

AUTHOR AFFILIATION

ZIMMERMAN,R.P.

Region 5, Ofc of the Director

RECIP.NAME

.

RECIPIENT AFFILIATION

R

KARNER,D.

Arizona Nuclear Power Project (formerly Arizona.,Public Serv

1

SUBJECT:

Forwards Special Insp Repts 50-528/89-08,50-529/89-08

&

50-530/89-08

on 890313-17.Violations

noted.

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DISTRIBUTION CODE:

IE35D

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TITLE: Emergency Preparedness-Appraisal/Confirm

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14

V

Arizona Nuclear

Power Project

Post Office Box 52034

Phoenix,. Arizona

85072-2304

Attn:

Mr.

D. Karner

Executive Vice President

Dear Mr. Karner:

SUBJECT:

EMERGENCY OPERATING

PROCEDURES

INSPECTION AT PALO VERDE

This letter forwards the results

and conclusions

of a special

team inspection

conducted

by

NRC Region

V and the Office of Nuclear Reactor

Regulation of

activities authorized

by

NRC Operating

License

Nos.

NPF-41,

NPF-51,

and

NPF-74 for Palo Verde Units 1, 2,

and

3.

The inspection

was conducted

on

March 13,

1989 through. March 17,

1989.

At the conclusion of the inspection,

the findings were discussed

with Mr. Haynes

and other

members of your staff

identified in the enclosed

inspection report.

The purpose of this inspection

was to verify that your Emergency Operating

Procedures

(EOPs)

are technically correct; that their specified actions

can

be

meaningfully accomplished

using existing equipment,

controls,

and

instrumentation;

and that the available

procedures

have the useability

necessary

to provide the operator with an effective tool to manage

and

mitigate potential

accidents.

The areas

examined during the inspection

are

identified in the attached

inspection report.

The inspection consisted

of a

selective

examination of procedures,

simulated

emergencies

exercised

on your

plant specific simulator, procedure

walkthroughs in the plant with operations

personnel,

and interviews with a broad selection of your operations,

procedure

writing, and training staffs.

Through direct observation of the performance

of selected

procedures

during

the simulator, exercises,

and through plant walkthroughs of selected

procedures,

we have concluded that your operating staff can utilize the

EOPs

to manage

and mitigate serious

operational

events.

However, the

EOP

procedures

have significant useability concerns.

Chiefly, the

EOPs

as they

are

now constituted

are overly complex and

have

numerous

inconsistencies.

These

problems

are of a

human factors nature

and are detailed in the report.

This inspection

was the third time your

EOPs were inspected.

The findings of

this inspection

are similar to the findings of past inspections,

indicating

that the fundamental

problems affecting quality and useability of your

procedures

have not been corrected.

The concerns

regarding the quality and

useability of your

EOPs appear equally applicable to your Abnormal

and

Normal Operating

Procedures.

Further,

the

team found additional

evidence

that the simulator does

not adequately

replicate certain plant conditions,

creating the potential for negative operator training.

In addition, the

team found evidence of a poor professional

relationship

between

the

raining and operations

organizations.

Compounding these

concerns,

the

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team found that the operators

recognized

the procedure

problems

and were not

satisfied with the quality and useability of procedures

used during simulator

scenarios.

The above concerns

provide further evidence that the management

of

activities at your facility needs significant improvement.

During the course of the inspection your staff outlined the program that was

in place to completely revise the

EOPs.

The inspection

team expressed

a

concern that the resources

being utilized to produce the

EOP procedure

revision within the time frame of implementation

by July of 1990

may not be

adequate.

The concern centers

on assuring that the

EOP procedure

revision

does

not repeat

the concerns

associated

with the current

EOPs.

To this end

the inspection

team

recommended

that the revision effort include

a

multi-disciplinary approach

emphasizi ng human factors,

a well defined

verifi,cation and validation program,

and adherence

to a full scope writers

guide.

We request that you formally transmit to the

NRC your plans for corrective

actions related to the findings in the enclosed

inspection report within 30

days of receipt of this letter.

Your response

should address

specifically

.what corrective actions

you plan on taking concerning the current

EOPs,

and

how those corrective actions

wi 11

be addressed

in the future revision of the

EOPs.

In accordance

with 10 CFR 2.790(a),

a copy of this letter

and the enclosures

will be placed in the

NRC Public Document

Room.

The response

requested

by this letter and its enclosures

are not subject to

the clearance

procedures

of the Office of Management

and Budget

as required

by

the Paperwork

Reduction Act of 1980,

Pub.

L.

No.96-511.

Should you have

any questions

concerning this inspection,

we will be pleased

to discuss

them with you.

Sincerely,

/. ~/lj'?u~~'h<C'>]

Roy P.

Zimmerman, Director

Division of Reactor Safety

and Projects

Enclosures:

.

l.

Inspection

Report 50-528/89-08,

50-529/89-08,

50-530/89-08

2.

Appendix

A to Report 50-528/89-08,

50-529/89-08,

50-530/89-08

f-:PR 2 8

1989

-3"

cc w/enclosures

J.

G.

Haynes,

ANPP

W.'. quinn,

ANPP

L. Souza,

ANPP

T.

D. Shriver,

ANPP

C.

N.

Russo,

ANPP

D.

Canady,

ANPP

L. Bernabei,

GAP

T.

Hogan,

ACC

A.

C.

Gehr,

Esq.,

Snell

and

bcc w/enclosures:

G. Lapinsky,

NRR

Docket File

Project Inspector

Resident

Inspector

G.

Cook

B. Faulkenber ry

J. Martin

R.

Nease,

NRR

State of Arizona

bcc w/o enclosures:

M. Smith

J. Zollicoffer

REGION V/jg.,

GJohnston

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TMeadows/

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Wi lmer

SRichards

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RZimmerman

/ /aP'89

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YES /

NO

HAYES /

NO

YES

. /

NO

fVES /

NO

YES /

END TO

PDR

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YES /

NO