ML17312A865
| ML17312A865 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/17/1996 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-03736-WLS-A, 102-3736-WLS-A, NUDOCS 9607240269 | |
| Download: ML17312A865 (31) | |
Text
CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9607240269 DOC.DATE: 96/07/17 NOTARIZED: NO DOCKET ACIL: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 STEWART,W.L.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 960621 ltr re violations noted in insp rept 50-528/529/530/96-07 on 960421-0601.C/A:engineering e
evaluation conducted to determine affects of exceeding 1540 psig on sys.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT Standardized plant.
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0 WILLIAML, STEWART EXECUTIVEVICE PRESIOENT NUCLEAR Arizona Public Service PALO VERDE NUCLEAR GENERATING STATION P.O. BOX 52034 PHOENIX, ARIZONA 85072-2034 102-03736-WLS/AKKRJH July 17, 1996 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units',2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notices of Violation 50-529/96-0?41 and 50-528/529/96-07-09 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/96-07 and the Notices of Violation (NOV) dated June 21, 1996.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
4 In response to the concerns identified in the first violation, APS believes that a combination of weak procedure controls, incorrect assumptions made by personnel in verifying proper system alignment and the lack of procedure use were all contributors to less than acceptable performance during routine operations tasks.
Although performance did not meet management expectations, neither of these events resulted in a compromise to nuclear safety.
In response to the concerns identified in the second violation, APS performed a review of the administrative controls and associated implementing procedures with regard to contamination control and radiological postings.
The review concluded that the program and associated requirements including expectations are well established and clearly defined to direct station personnel in posting and controlling radiological areas.
Continued emphasis willbe placed to improve the implementation of these controls and enhance worker knowledge and communication.
)I In summation, APS believes that the lessons learned from these events will heighten the awareness of plant personnel concerning the importance of following procedures are used and followed during routine and non-routine tasks.
In addition, procedure
- changes, enforcement of management expectations and personnel training on these events should ensure future compliance in this area.
9607240269 960717 PDR ADOCK 05000528 8
a
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notices of Violation 50-529/96-07-01 and 50-528/529/96-07-09 Page 2 4
Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421.
Sincerely, WLS/AKK/RJH/rv Enclosures cc:
L. J. Callan J. W. Clifford K E. Johnston K. E. Perkins
/
t e
ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-529/96-07-01 AND REPLY TO NOTICE OF VIOLATION50-529/96-07-01 NRC INSPECTION CONDUCTED April21, 1996 THROUGH June 1, 1996 INSPECTION REPORT Na. 50-528/529/530/96-07
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RESTATEMENT OF NOTICE OF VIOLATION50-529/96-07-01 During an NRC inspection conducted on April 21 through June 1, 1996, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
A.
Technical Specification 6.8.1 requires,'n part,'that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,
Revision 2,
- requires, in part written procedures for procedural adherence.
Procedure 01DP-OAP01, "Procedure Process,"
Revision 1, Step 6.2, requires, in part, that procedure users are responsible for adhering to the requirements of the procedure.
Contrary to the above, the inspectors identified two examples where licensee personnel, on different occasions, failed to adhere to the requirements of the procedure as evidenced by the following:
Procedure 40AL-9RK2B, "Panel B02B Alarm Responses,"
Revision 26, Window Number 2209B, page 3 of 12, Step 3, prescribes, in part, that ifthe indicated pressure on SIN-Pl-319 is greater than 1540 psig, then declare low pressure safety injection (LPSI) B inoperable; and page 7 of 12, Step 3, prescribes, in part, that if the indicated pressure on SIN-Pl-339 is greater than.1540 psig, then declare LPSI A inoperable.
On April 30, 1996, in Unit 2, when pressure on SIN-Pl-319 exceeded 1540 psig, operators failed to declare LPSI B inoperable, and when pressure on SIN-PI-339 exceeded 1540 psig, operators failed to declare LPSI A inoperable.
As a result, both trains of LPSI were inoperable for approximately 15 minutes.
Procedure 42OP-2SG03, "Operating the Steam Generator (SG) Blowdown System," Revision 21, Section 6.3, "Performing High Rate Blowdown on SG 1 to the Main Condenser," provides instructions for realigning the blowdown system to the blowdown flash tank.
On May 11, 1996, in Unit 2, the procedure was not used by an operator when realigning the blowdown system, and the system was left isolated.
As a result, actual reactor power was slightly greater than indicated power and exceeded the licensed thermal limit by a small amount.
This is a Severity Level IVviolation (Supplement
- 1) applicable to Unit 2.
4
REPLY TO NOTICE OF VIOLATION50-529/96-07-01 aso 0
PVNGS accepts the violation.
(Condition One)
On 04/30/96, Unit 2 Operations was in the process of restoring the Safety Injection (SI) cold legs from shutdown cooling to the normal operating lineup when they discovered that the downstream Sl line pressure exceeded 1540 psig for approximately 15 minutes.
Operations procedures 40OP-9SI02 "Recovery
'rom Shutdown Cooling to Normal Operating Lineup," and 40AL-9RK28, "Panel 28098 Alarm Responses" were in use during this evolution.
40OP-9SI02 requires operations personnel to establish boration flow and to control pump discharge pressure between 1450 and 1500 psig with a procedure note that alerts the operator that an expected alarm for Sl check valve high pressure will be received.
40OP-9SI02 did not require operations personnel to acknowledge the alarm or use the alarm as a means to monitor system pressure.
When boration flowwas terminated and the system alignment was restored, Operations personnel referenced the alarm response procedure 40AL-9RK28 to acknowledge the alarm.
40AL-9RK28 states that the Low Pressure Safety Injection (LPSI) pumps are inoperable ifthe system line pressure is greater than 1540 psig.
Control room personnel evaluated this condition, consulted with the Site Shift Manager and Licensing, and determined that the controlling procedure (40OP-9SI02) for this evolution did not impact LPSI operability and subsequently did not declare LPSI valves inoperable as required by 40AL-9RK28.
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(Condition One)
The root cause of this event can be attributed to weak procedure guidance in that 40OP-9SI02 did not contain sufficient guidance regarding impact to LPSI operability, and that operations personnel did not conservatively follow procedures.
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SO e V'ol (Condition Two)
On May 11, Unit 2 operator personnel reduced reactor power and performed a high rate steam generator blowdown to the main condenser.
Once the blowdown evolution was completed, an auxiliary operator was dispatched to realign the steam generator blowdown system for normal blowdown to the blowdown flash tank.
The realignment was completed, and reactor power was returned to 100 percent.
On May 13, a reactor operator questioned a difference between reactor power calculated from primary plant parameters and reactor power calculated from secondary plant parameters.
Further investigation of the event found that the blowdown system from one of the steam generators to the blowdown flash tank was isolated.
The isolation of the system resulted in actual reactor power being greater than indicated reactor power by approximately 0.28 percent for a period of 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br />.
The highest rolling 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> average of actual reactor power was determined to be 100.27 percent.
An evaluation of this condition was performed including a Human Performance Investigation (HPES).
The evaluation determined that the AO did not meet management expectations for performing the blowdown valve manipulations by not using the procedures as required for performing such an evolution.
The opportunity for the control room operators to verify system response was not adequately performed by checking the blowdown flash tank (BFT) pressure and vent flow readings following adjustments to control valve and comparing the readings with previous values in that system lineup.
The evaluation also identified that control room supervision did not adequately ensure operation expectations were being met with regard to procedure adherence.
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The root cause of this event was determined to be:
1.
Written communications were not taken out in the field due to over confidence by the Area Operator.
2.
A wrong assumption was made by control operators by believing that the BFT indication response was caused by the change in the blowdown valve stroke resulting in isolation of the normal blowdown flow path to the BFT for steam generator ¹I.
The control room staff did not enforce management expectations regarding procedure use.
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Been Ta en a Resu s
chieved
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(Condition One) 1.
(On May 14,
- 1996, an Engineering evaluation was conducted to determine the affects of exceeding 1540 psig on the system.
The evaluation included a review of minimum voltages required to operate the motor for the valve actuator and concluded that minimum voltages could be increased to 409
- VAC, resulting in an increased pressure (approximately 1900 psid) that the LPSI valves would be able to operate against.
The evaluation concluded that the LPSI cold leg injection valves would have been able to operate properly during the April 30th condition based on the highest system pressure reading of 1700 psig.
The system design parameters, safety limits, and operability requirements were maintained well within the specified requirements during this I
condition.
3.
On May 17, '1996, procedure 40AL-9RK2B was revised to reflect the new pressure value.
All Units'perations crews have reviewed the procedure change.
4.
Operations management has briefed all Unit's operations
- crews, reinforcing expectations regarding procedure use and adherence.
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e (Condition Two) 1.
Operations procedure 4XOP-XSG03 "Operating the Steam Generator Blowdown System," was revised on May 15, 1996, to include Independent verification for manipulation of blowdown isolation valves.
Expectations for procedure usage were addressed with each operations supervisor and associated crew which was completed on May 17, 1996.
3.
The reactor operator and area operator were counseled on management's expectation for procedure usage on May 17, 1996.
4.
A night order was issued on May 28, 1996, describing the procedure change to 4XOP-XSG03 requiring independent verification of blowdown valves.
The night order also discusses the expectations for performing independent verification of blowdown constants and control of documentation for independent verification.
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(Condition One) v u her Violations An evaluation of similar plant procedures was conducted on May 14, 1996, to determine if this condition was transportable.
The evaluation identified three other procedures that reference alarm usage and could have a potential on impact on LPSI operability.
All identified procedures will be revised to include guidance on expected alarm response and the affect on system pressures by the end of October 1996.
There were no previous operability concerns regarding exceeding LPSI system pressure using these procedures.
Operations Industry Events training will included a detailed event description and operations personnel will complete the training by the end of September 1996.
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(Condition Two)
This event will be covered in Industry Events Training for operations personnel discussing the expected response of BFT pressure and,vent flow for different scenarios.
Training will also be given to highlight other verification techniques used by operators such as comparing indicators and turbine load set p'rior to and
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after blowdown alignments are made.
This training is expected to be completed by the end of August 1996.
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ev (Condition One)
Full compliance was achieved on April 30, 1996, when the LPSI system pressure was returned to its normal operating specification.
(Condition Two)
Full compliance was achieved on May 13, 1996, when the turbine generator was backed down and normal blowdown lineup was restored and reactor power were was returned to 100%.
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ENCLOSURE 2 RESTATEMENT OF NOTICE OF VIOLATION50-528/529/96-07-.09 AND REPLY TO NOTICE OF VIOLATION50-528/529/96-07-09 NRC INSPECTION CONDUCTED April 21, 1996 THROUGH June 1, 1996 INSPECTION REPORT No. 50-528/529/530/96-07
0 RESTATEMENT OF NOTICE OF VIOLATION50-528/529/96-07-09 During an NRC inspection conducted on April 21 through June 1, 1996, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
B.
- requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Revision 2, requires, in part, written radiation protection procedures for contamination control.
Procedure 75RP-ORP01, "Radiological Posting,"
Revision 13, Step 3.4.1,
- requires, in part, that areas identified as having contamination levels greater than 1000 disintegrations per minute per 100 square centimeters shall be posted with radiological warning sign(s) bearing the words "caution, contaminated area."
Contrary to the
- above, the inspectors identified three areas as having contamination levels greater than-1000 disintegrations per minute per 100 square centimeters that were not posted with radiological warning signs bearing the words "caution, contamination area." The examples were the following:
On May 9, 1996, the floor under Unit 2 valve SIA-UV-655 had contamination levels as high as 15,000 disintegrations per minute per 100 square centimeters.
On May 9, 1996, the floor under Unit 2 drain valve SIB-V555 had contamination levels as high as 70,000 disintegrations per minute per 100 square centimeters.
In addition, the pipe cap downstream of valve SIB-V555 had contamination levels as high as 30,000 disintegrations per minute per 100 square centimeters.
On May 16, 1996, the floor under Unit 1 valve SIA-UV-655 had contamination levels as high as 40,000 disintegrations per minute per 100 square centimeters.
This is a Severity Level IVviolation (Supplement IV) applicable to Units 1 and 2.
e REPLY TO NOTICE OF VIOLATION50-528/529/96-07-09 easo o T eVo io APS accepts the violation.
During the month of May 1996, NRC Inspectors conducted tours of radiological controlled areas in all three units.
During the tours, the irispectors Identified locations in Unit's 1 and 2 safety injection system where contamination control postings were either not present or did not fullyencompass the entire contaminated area.
The inspection results concluded that three examples of improper posting and inadequate contamination control reflected poor performance of the licensee's program for the control of contaminated areas in that routine tours by RP, maintenance, and operations personnel had not been effective in identifying leaking components which had inadequate contamination controls.
The Radiation Protection Department conducted an evaluation of the contamination control program.
The evaluation concluded that program administrative controls and associated department procedure requirements for controlling contamination were satisfactory.
In addition, management expectations for performing surveys at the required frequency were also satisfactory.
Although contamination control procedure requirements for posting and surveys met management performance expectations, walkdowns and tours of radiological areas by Operations, Radiation Protection, and Maintenance departments should have identified these areas in a more timely manner.
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Further evaluation of these particular locations in the safety injection system revealed that these areas are not normally accessed by plant personnel and specific P
evolutions conducted in these
- areas, other than general tours, would have prompted more detailed work area surveys.
Previous personnel contamination reports were reviewed to determine if survey frequencies for these areas should be increased based on increased contamination events.
The review indicated that there were no other contaminations during routine (non-outage) power operations in the 77'enetration rooms or LPSI pump rooms in all three units this year.. Radiological conditions in these areas are relatively stable during normal plant operations.
During plant outages and startup periods, conditions are more dynamic, and zone inspection frequencies are increased.
Walkdowns and tours of these areas are normally performed by Radiation Protection, Facilities Maintenance, and Operations during normal plant operations.
Independent evaluations of the effectiveness of these walkdowns were conducted by Nuclear Assurance.
The evaluation results identified that improvements were necessary in communications between work groups, improved documentation of problem areas was necessary, and resolution of problems were not timely.
Radiation Protection management elected to take the lead and established a Management Level 1 to place an appropriate priority for resolution and increase management awareness.
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Correc ive S e s at ave Bee aken a d
s c 'eve
- 1. The Unit 2 safety injection valve, 2JSIAUV-0655 was immediately posted as "caution, contaminated area" on May 9, 1996, and the floor area and accessible areas of 2JSIAUV-0655 were subsequently decontaminated.
In addition, a drip catch was installed under 2JSIAUV-0655 as an interim measure and a Work Request (¹652137) was generated to stop the leak as a final corrective action.
- 2. The Unit 2 safety injection valve, SIBUV-0555 was immediately decontaminated to less than 1000 dpm/100cm2 on May 9, 1996, and a drip catch was installed (as interim corrective action) as a precaution for possible future leaks.
The source of the leak was identified to be a leaking end cap, which was adjusted.
The drip catch was removed, and no further packing leaks were evident.
- 3. The Unit 1
safety injection
- valve, JSIAUV-0655 was immediately
- posted, decontaminated, and a drip catch installed on May 16, 1996.
However, on May 22,
- 1996, Nuclear Assurance inspection of 2JSIAUV-0655 identified the need for an improved drip catch which was upgraded and installed.
This area was evaluated as part of a followup walkdown and appears to be satisfactory.to date.
- 4. The Radiation Protection Department issued a
RP Night Order on "Establishment/Removal of Drip Catches/Containment devices" (Night Order ¹ 9-009) on May 24, 1996, as an Interim action in response to the large number of problems identified with leaking valves, pipe caps, and drip catches which have been identified in subsequent walkdowns..
This Night Order was subsequently terminated on June 26, 1996, and replaced with enhancements to RP Guideline (RPG: 9-37).
This guideline defines the various levels of system leakage that may or may not need
- control, management expectations for controlling leakage, and expectations for walkdowns and tours and specifically requires an RP Lead Technician's approval for the removal of any drip catch device.
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Correct ve S e s a W' Be aken To Avoid Further Violatio s The Radiation Protection Department is in the process of developing a generic guideline with cross-organizational responsibilities to enhance communications between work groups, clearly define expectations for walkdown and tour frequencies, and further define what to look for during walkdowns including expectations for consistent documentation and followup for problems identified during the walkdowns.
The generic guideline will be completed by the end of August 1996.
The Radiation Protection and Utility Maintenance groups will receive training to upgrade observation techniques related to identification of potential problems during walkdowns.
This training will be completed by the end of August 1996.
Da e When Full Com liance Will Be Achieved Full compliance was achieved on May 9, 1996, when the Unit 2 safety injection system valves, 2JSIAUV-0655, and 2PSIBV-0555 were posted and decontaminated in accordance with the radiological administrative controls procedures.
Full compliance was achieved for Unit 1, 1JSIAUV-0655, on May 16, 1996, when the valve was posted and decontaminated and an improved drip catch was installed.
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