ML20128D290

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-528/92-31,50-529/92-31 & 50-530/92-31.Corrective Actions: Event Described in Previous Insp Rept Will Be Included as Discussion in Operator Requalification Training Plan

ML20128D290
Person / Time
Site:	Palo Verde
Issue date:	12/01/1992
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02362-WFC-T, 102-2362-WFC-T, NUDOCS 9212070211
Download: ML20128D290 (8)

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Arizona Public Service Company n o noum. nwm muu eseum 102-02362-WFC/TRB/Jun EcEUf,78$7o December 1, 1992 w,o v u U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Reference:

Letter datuJ '!ovember 3,1992, from S. A. Richards, Deputy Director Division of Reactor Safety and Projects, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS

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

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File: 92-070-023 l

Arizona Public Service Company (APS) has reviewed NRC inspection heport 1

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 Report, reference was made to a similar violation of operator response to an annunciator.

Enclor 2 provides additional information regarding these two violations.

If you shoulc nave any questions, please call Thomas R. Bradish at (602) 393-5421.

)

Sincerely, WFC/TRB/JJN/pmm

Enclosures:

1.

Appendix A - Restatement of Notice of Violation

2. - Reply to the Notice of Violation

3. - Additional Information Regarding the Violation cc:

J. B. Martin J. A. Sloan 9212c70211 921201 PDR ADoCK 0500 g 8 f

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1 APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION 50-529/92-31-02 I

NRC INSPECTION CONDUCTED AUGUST 25,1902 -l SEPTEMBER 30,1992

.i INSPECTION. REPORT NOS. 50-528/529/530/92-31 y

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BESTATEMENT OF NOTICE OF VIOLATION 50-529/92-31-02 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, 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 recommended in Appendix A of Regulatory Go'de 1.33, Revision 2, February, 1978."

Appendix A of Regulatory Guide 1.33, Revision 2, recommends procedures for safe operation and shutdown.

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 shitt 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 false 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) applicable to Unit 2.

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1 ENCLOSURE 1 i

REPLY TO NOTICE OF VIOLATION 529/92-31-02 NRC INSPECTION CONDUCTED AUGUST 5,- 1992 THROUGH SEPTEMBER 30,-1992 INSPECTION REPORT NOS. 50-528/529/530/92-31 P-m ir,

,L REPLY TO NOTICE OF VIOLATION 50-529/92 31

• Beason For The Violatlgn The reason for the violation was a personnel error. When the Hi Hi/Lo Lo alarm for the Non-ESF (Engineered Safety Features) eump 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 pump 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 rnemorandum 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.

Corregtive Steos That Will Be Teken to Avoid Further Violations TH avent 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 1 of 2

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a reemphasize management's expectation that operators are responsibb for being aware of plant status and properly responding to abnormal plant conditions.

Date When Full Compjlance Will Be Achieved 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 u

i ADDITIONAL INFORMATION REGARDING THE VIOLATION d

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t' ADDITIONAL INFORMATION REGARDING THE VIOLATION-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 tak.en as described in Enclosua 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 understanding 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 procedure 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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