ML20127A819
| ML20127A819 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/05/1993 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9301120085 | |
| Download: ML20127A819 (3) | |
See also: IR 05000528/1992031
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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1450 MARIA LANE
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WALNUT CREEK. CAUFORNIA 94596-5368
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JJAM - E 1933
' Docket Nos.
50-528, 50-529, 50-530'
Arizona Public Service Company-
P.O. Box 53999,-Sta. 9012
Phoenix, Arizona _ - 85072-3999
Attention:
Mr. W. F. Conway
Executive Vice President, Nuclear
Gentlemen:
Thank you for your letter of December 1,1992, in response to our Notice of
-Violation'and Inspection ~ Report No. 50-528/92-31, 529/92-31 and 530/92-31,-
dated November 3, 1992, informing us of the steps you have taken to correct
the items which we brought to your attention.
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We re-emphasize the need for operators to-respond correctly to annunciators-to-
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evaluate and correct or investigate plant events.
Your corrective actions
will be verified during a future inspection.-
Your cooperation-with us is appreciated.
Sincerely,
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-S.-A. Richards,-Deputy Director
Division.of Reactor Safety and Projects-
cc:
Mr. O. Mark DeMichele, APS
Mr. James M. Levine, APS
Mr. R. Stevens, APS
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Mr.-E. C.-Simpson, APS
Mr. S. Guthrie, APS
Mr. Thomas R. Bradish, APS
.Mr. Robert W. Page, APS
Ms. Nancy C. Loftin, Esq., APS
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Mr.;Al Gutterman, Newman & Holtzinger P.C.
- Mr. James A. Booletto, Esq., Assistant Counsel, SCE Company
' Mr. Charles B. Brinkman,_ Combustion Engineering, Inc.
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Mr. Aubrey V. Godwin, Director, Arizona.Radiatton Regulatory Agency
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Chairman, Maricopa County Board-of Supervisors-
Mr. Steve M. Olea, Chief Engineer, _ Arizona Corporation Commission
Mr. Curtis Hoskins, El Paso Electric Company
Roy P. _ Lessey, Jr., Esq., Akin, Gump. Strauss, Hauer and Feld
Bradley W. Jones, Esq., Akin, Gump,' Strauss, Hauer and Feld
,Mr. Jack R. Newman, Esq., (Newman & Holtzinger)
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Docket Nos.-
50-528, 50-529, 50-530
Arizona'Public Service Company
P.O. Box 53999, Sta. 9012
Phoenix, Arizona 85072-3999
Attention:
Mr. W. F. Conway
Executive Vice President, Nuclear
Gentlemen:
Thank you for your letter of December 1,1992, in response to our Notice of
Violation and Inspection Report No. 50-528/92-31, 529/92-31 and 530/92-31,
dated November 3,1992, informing us of the steps you have taken to correct
the items which we trought to your attention.
We re-emphasize the need for operators to respond correctly to annunciators to
evaluate and correct or investigate plant events. Your corrective actions
will be verified during a future inspection.
Your cooperation with us is appreciated.
Sinc 3 rely,
S. A. Richards, Deputy Director
Division of Reactor Safety and Projects
cc:
-Mr. O. Mark DeMichele, APS
Mr. James M. Levine, APS
Mr. R. Stevens, APS
Mr. E. C. Simpson, APS
Mr. S. Guthrlo, APS
Mr. Thomas R. Bradish, APS
Mr. Robert W. Page, APS
Ms. Nancy C. Loftin, Esq., APS
Mr. Al Gutterman, Newman & Holtzinger P.C.
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Mr. James A. Beoletto, Esq., Assistant Counsel, SCE Company
Mr. Charles B. Brinkman, Combustion Engineering, Inc.
Mr. Aubrey V. Godwin, Director, Arizona Radiation Regulatory _ Agency
Chairman, Maricopa County Board of Supervisors
Mr. Steve M. Olea, Chief Engineer, Arizona Corporation Commission
Mr. -Curtis Hoskins, El Paso Electric Company
Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld
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Bradley W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld
Mr. Jack R. Newman, Esq., (Newman & Holtzinger)
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bcc w/ copy of letter dated December 1,1992:
' Docket' File
Resident Inspector-
' Project Inspecter
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J. Martin
J. Zollicoffer
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December 1, 1992
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Station P1-37
Washington, DC 20555
Reference:
Letter dated November 3,1992, from S. A. Richards, Deputy Director
Division of Reactor Safety and Projects, NRC, to W. F. Conway, Executive
Vice President, Nuclear, APS
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Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3
Docket Nos. STN 50 528/529/530
Notice of Violation 50-529/92 31-02
File: 92 070-026
Arizona Public Service Company (APS) has reviewed NRC Inspection Report
50-528/529/530/92-31, and the Notice of Violation, dated November 3,1992. Pursuant
to the provisions of 10 CFR 2.201, APS' response is provided as Enclosure 1. Appendix
A to this letter is a restatement of the Notice of Violation.
In the cover letter transmitting the Inspection Re,oort, rGrence was made to a similar
violation of operator response to an annunciator.
Enclosure 2 provides additional
information regarding these two violations.
If you should have any questions, please call Thomas R. Bradish at (602) 393 5421.
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Sincerely,
WFC/TRB/JJN/pmm
Enclosures:
1.
Appendix A
Restatement of Notice of Violation
2.
Enclosure 1 - Rep!y to the Notice of Violation
3.
Enclosure 2 AdditionalInformation Regarding the Violation
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J. A. Sloan.
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APPENDIX ' A -
RESTATEMENT OF NOTICE OF VIOLATION
50 529/92-31-02
NRC INSPECTION CONDUCTED
AUGUST 25,1992 - SEPTEMBER 30,1992
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INSPECTION. REPORT NOS. 50-528/529/530/92-31
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BESTATEMENT OF NOTICE _OF VIOLATION 50 529/92-31-02
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During an NRC inspection conducted on August 5,1992, through September 30,1992,
a violation of NRC requirements was identified,
in accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2,
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Appendix C, the violation is listed below:
Unit 2 Technical Specification 6.8.1 states in part: Written procedures shall be
established, implemented, and maintained covering the activities
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recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,
1978."
Appendix A of Regulatory Guide 1.33. Revision 2, recommends procedures for
safe operation and shutdown.
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Procedure 40AC 90P02, " Conduct of Shift Operations " step 3.2.2.8, which
implements in part the operations procedures recommendation of Regulatory
Guide 1.33, requires that "On shift personnel shall be aware of and responsible for
plant status. . . They shall be attentive to instrumentation and respond to abnormal
indications until corrected or verified to be falso by other instrumentation."
Contrary to the above, on September 3,1992, Unit 2 control room personnel were
not attentive to plant instrumentation and failed to respond to an abnormal alarm
indication caused by high levelin the non ESF sump in the Auxiliary Building which
later resulted in flooding of the Auxiliary Building.
This is a Severity Level IV violation (Supplement I) apphcable to Unit 2.
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ENCLOSURE 1
REPLY TO NOTICE OF VIOLATION
50-529/92-31-02
NRC INSPECTION CONDUCTED
AUGUST 5,1992 THROUGH SEPTEME2R 30,1992
INSPECTION REPORT NOS. 50-528/529/530/92-31
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REPLY TO NOTICE OF VIOLATION 50-529/92 31 02
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Reason For The Violation
The reason for the violation was a personnel error. When the Hi Hi/Lo Lo alarm
for the Non-ESF (Digineered Safety Features) sump annunciated, the Operator did not
respond to the alarm in accordance with the alarm response procedure. The Operator
believed that the alarm was a result of the running sump pump being out of service and
that the standby pump would start and subsequently clear the alarm. However, the sump
punip was in service, and the Operator did not verify the condition of the sump pump.
Corrective Steps That Have Been Taken And Results Achieved
The Operator was counseled about the importance of responding to each alarm
and the requirement to follow procedures.
The General Manager of Plant Support has issued a memorandum to the Unit
Plant Managers, Assistant Plant Managers, and Operations Managers providing additional
guidance regarding control room tours performed as part of the continuing Operations
Observation Program. The memorandum discusses this event and the previous event
involving improper response to a control room annunciator. The memorandum advises
management personnel on the need to question control room personnel when alarm
response procedures are not immediately referenced.
. Corrective Steps That Will Be Taken to Avoid Further Violations
This event and a previous event described in inspection Report 91-49 involving
improper response to a control room annunciator will be included as discussion in the
Operator Requalification Training Cycle starting in January,1993.
This training will
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reemphasize management's expectation th'at operators are responsible for being aware
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of plant status and properly responding to abnormal plant conditions.
Date When Full Compliance Will Be Achieved
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Full compliance was achieved on September 3,1992, when actions were taken to -
mitigate this event in accordance with the alarm response procedure.
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ENCLOSURE 2
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ADDITIONAL INFORMATION REGARDING THE VIOLATION
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ADDITIONAL INFORMATION REGARDING THE VIOLATION
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in the cover letter transmitting Inspection Report 50 528/529/530/92-31, reference was
made to a similar violation of operator response to an annunciator. in both instances, the
operators' responses did not meet APS' standards or practices. As a result, several
actions were taken as described in Enclosure 1.
Although these instances resulted in operators improperly responding to alarms, the
causes of each instance are distinctly different.
In the first instance, the operator
acknowledged the alarm, prioritized the alarm with ongoing activities, but forgot to
follow-up on the alarm. In the second instance, the operator recognized the alarm but
incorrectly decided that no further action was required based on his u.iderstanding of
plant conditions. Other control room instrumentation would not have aided the operator
in validating the operator's assumption.
APS procedures permit an operator to
acknowledge an alarm without referencing the alarm response proceduto if the alarm is
an expected occurrence as a result of plant conditions. As discussed above, the
operator incorrectly took no further action based on his understanding of plant
conditions.
APS expects its operators to understand plant conditions, verify plant
conditions as appropriate, and take action utilizing approved procedures.
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