ML20204D720
| ML20204D720 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/19/1987 |
| From: | Licitra E Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8703250550 | |
| Download: ML20204D720 (8) | |
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umTEo STATES I'
8 NUCLEAR REGULATORY COMMISSICN b
b PeASNetteTON, D. C. 20005 t-MARCH 19, 1987 t
Docket Nos.: 50-528, 50-529 L'
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LICENSEE:
Arizona Public Service Company',
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t FACILITY: Palo Verde. Units 1,-2 and 3
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SUBJECT:
SUMARY OF MEETING REGARDING EMERGENCY OPERATING PROCfDURES I
E A meeting was held with the licensee on February 26,(EOPT. The p'.rpose regarding Palo Verde Emergency Operating Precedures meeting was to discuss the resolution of staff coments on t*.e Palo Verde E0Ps r
provided in a letter dated September 10,.1$36.
U Attendees for the meeting are listed in Enclosure 1 and the r.eeting is sumar-ized as follows:
t Sumary y
The staff comments provided'in the Septeder 10, 1986 htter were generated as a result of its review of the licensee's respo'ise to an ever.t wliith occurred at Palo Verde. Unit 1 on July 12, 1986. At the meetingi the licensee ) resented 1
an overview of its philosoptiy regarding the gr.neration and use nf tie plant E0Ps.
The E0Ps are based on the Palo Verde plant specific guidelines which, in turn, are based on the generic guidelines in CEN-352 for Cembustion Encineering plants.
The licensee stated that it had appropriately considered the staf' coments included in the September 10, 1986 letter and is preparing a response for submittal to the staff. At the meetina, a draft of-the response (included as )wasdiscussedwiththestaff. The draft did not' cover how "A" items from the staff audit of September 1984 wery 3ddressed since these would be discussed at another time.
The staff provided a number of coments on tho, draft. As a result, the licensee will revise the response prior to making a formal submittal.
The staff concluded that the presentation by the licentee provided a clearer T-
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asthelicensee'sphilosophyregardingthegenerationanduseofE0Ps.
a,),p As a result, several staff concerns were resolved.
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1" E. A. Licitra, Project Manager PWR Project Directorate No. 7 Division of PWR Licensing-B
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Enclosures:
N As stated
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cc: See next page s
Yi Distribution DocketNo(s): 50-528, 50-529 50-530
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pWPM3 f.ocal PDR c'
PBD-7 P.eading JPartlow T (tT 4
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GWKnighton BGrimes ACRS(10)
EJordan Attorney, OGC EAlicitra PED 7 g[
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EAlicitta GKr1ghton 3// /87 3//p,/87 i-
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Mr. E. E. Van Brunt, Jr.
Arizona Nuclear Power Project Palo Verde cc:
Arthur C. Gehr, Esq.
Kenneth Berlin, Esq.
Snell & Wilmer Winston & Strawn 31001 Valley Center Suite 500 Phoenix, Arizona 85073 2550 M Street, NW Washington, DC 20037 Mr. Janes M. Flenner, Chief Counsel e
Arizona Corporation Commission Ms. Lynne Bernabei 1200 West Washington Government Accountability Project Phoenix, Arizona 85007 of the Institute for Policy Studies 1901 Que Street, NW Charles R. Kocher, Esq. Assistant Washington, DC 20009 Council James A. Boeletto, Esq.
Southern California Edison Company Mr. Ron Rayner P. O. Box 800 2
P. O. Box 1509 Rosemead, California 91770 Goodyear, AZ 85338 Mr. Mark Ginsberg Mr. Chdrles B. Brinkman, Manager Energy Director Washington Nuclear Operations Office of. Economic Planning Combustion Engineering, Inc.
and Development 7910 Woodmont Avenue Suite 1310 1700 West Washington - 5th Floor Bethesda, Maryland 20814 Phoenix, Arizona 85007 Mr. Wayne Shirley Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Mr. Roy Zimmerman U.S. Nuclear Regulatory Commission P. O. Box 239 Arlington, Arizona 85322 Ms. Patricia Lee Hourihan 6413 S. 26th Street Phoenix, Arizona 85040 Regional Administrator, Region V U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 1
Walnut Creek, California 94596
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Enclosure I l
Attendees For E0P Meeting for Palo Verde (2/26/87)
NAME Affiliation Manny Licitra NRC/NRR/PBD7 George'W. Knighton NRC/NRR/PBD7
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Mike Goodman NRC/NRR/PWRB/FSB Bill Regan NRC/NRR/PWRB/F0B Tom Greene NRC/NRR/PWRB/ FOB Bill Quinn ANPP MGR Licensing Lee Clyde ANPP STA Supervisor Richard Bernier ANPP Lead Licensing Engineer n
Larry Speight ANPP Assistant Shift Supervisor Frank Buckingham ANPP OPS Support Supervisor Jim Clifford NRC/NRR Gerald Sowers ANPP Operations Engineering MGR Mike Davis NRC/NRR/PWRB/PBD7 Jim Bongarra NRC/NRR/0HFT/HFIB 5
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MEETING
SUMMARY
DISTRIBUTION DocketNo(s):
NRC PDR Local PDR PBD-7 Reading J. Partlow GWKnighton BGrimes e
ACRS(10)
E. Jordan Attorney, OGC Pro,iect Manager:
E. A. Licitra NRC PARTICIPANTS Manny Licitra George W. Knighton Mike Goodman Bill Regan Tom Greene Jim Clifford Mike Davis Jim Bongarra i
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m NRC Recommendation As a preliminary step before the staff determines the acceptability of the licensee's approach, the licensee should define clearly the conditions under which the FRP would be used and develop a policy (and technical basis) for those situations where decision points are unclear or necessary information.is unavailable. The licensee's description should also include a statement regarding how-they addressed the "A" items that resulted from the staff audit of the Palo Verde E0P's, conducted in September 1984.
APS Response In order to more clearly define when the Functional Recovery Procedure is to be used, a change was implemented to the Emergency Operations Procedure as well as the Functional Recovery Procedure (FRP). This was accomplished by PCN 03 to the Emergency Operating Procedure and PCN 01 to the FRP.
In these PCNs, the verbatim wording from CEN-152 revision 02 was used to describe when the FRP was to be implemented.
NRC Recommendation Palo Verde performs an analysis of the Diagnostic Procedure to determine if trending of Steam Generator Pressure should be incorporated in the Flow Chart to help diagnose ESD events.
In addition to use of parameter trending for diagnosing other events should be considered.
APS Response Guidance has been placed in the Emergency Operations Procedure in Appendix D, to stress the importance of trending of all plant parameters. To emphasize the importance of trending, the Recovery Operations Procedures look at trending for a second check and verification that the proper procedure is in use.
NRC Recommendation CEN-152 be changed to explicitly state that parameter trending should be used in diagnosing an event.
APS Response This will be addressed to the CEOG Subcommittee, trending is already addressed in Appendix D of the Emergency Operations Procedure.
NRC Recommendation Parameters and instrumentation that are key var.iables, especially those that are needed in the early stages of~
an event, be powered from a more reliable power supply.
APS Response
.The following letters were written to request that " key parameters" be powered from a more reliable power supply: ANPM-00435-JMA-95.52 Reliable Power Supply to Containment Temperature and Humidity Detectors ANPM-00436-JMA-95.52 Reliable Power Supply to the RMS Mini Computer Used in Units 1, 2, and 3 Control Rooms ANPM-00437-JMA-95.52 Reliable Power Supply to Containment Radwaste Sump Level Indication.
NRC Recommendation CEN-152 be revised to include statements to have reliable power supply for key parameters that are used in the early stage of an accident, i.e.,
event diagnosis.
APS Response This will be addressed to the CEOG Subcommittee and has been addressed for PVNGS in the above referenced letters.
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NRC Recommendation Palo Verde Diagnostic Flow Chart be changed to include logic statements and success paths that will direct the operator to a statement that will send him to the Functional Recovery Procedure or define in the Flow Chart the conditions under which the Functional Recovery Procedure should be used.
APS Response The Emergency Operations Procedure provides the guidance g
for when the FRP should be entered. St(ps presently exist in all the Recovery Operations that give the Control Room Supervisor the option to use the Functional Recovery Procedure.
Placing decision blocks and criteria for entering the FRP in the Diagnostic, would make the Diagnostic unwieldly, and would give the appearance that
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those are the only times that the FRP should be entered.
NRC Recommendation The Diagnostic Flow Chart, delete the requirement to trip j
reactor coolant pumps. This would make the Flow Chart compatible with the SBLOCA procedure and the trip strategy incorporated in CEN-152.
APS Response The blocks that require tripping all RCPs prior to entering the Small LOCA Procedure have been deleted from the Diagnostic. This provides consistency with SBLOCA procedure and CEN-152 revision 02.
- L NRC Recommendation Palo Verde reexamine the need for all other sta.tements in the Diagnostic Flow Chart that require operator actions and delete them if possible. This would eliminate action statements in the Flow Chart that could be inconsistent with the selected recovery procedure, and leave the Diagnostic Flow Chart.as purely a diagnostic which is consistent with the philosophy of CEN-152.
APS Response The Diagnostic is divided into two portions, one portion serves as a second check to ensure that safety functions are being maintained, and the other portion serves to diagnose the event. The second check of safety functions is where most of the action statements occur. These actions that might be taken, serve to maintain safety functions by ensuring required ESFAS actuations, and will not interfere with the ability of the CRS to diagnose an event should be actions taken " mask" the cause of an event. The second check capabilities of the Diagnostic provide a valuable aid to the control room staff and it would not be prudent to delete those action steps.
Within the diagnosis section of the Diagnostic, the only actions required are those actions that manually initiate an ESFAS actuation when a setpoint has been exceeded or those actions that manually trip all RCPs prior to entering the LOCA procedures.
NRC Recommendation The Diagnostic Aides Section of CEN-152 be revised to eliminate the vagueness as to what should be included in the E0Ps. Words which can be construed to mean utilities j_
do not have to comply with the section, should be deleted so deviations will be identified by utilities referencing CEN-152.
APS Response CEN-152 offers the utilities the flexibility to implement a diagnosis process that works the best for their own individual staffs.
If the vagueness is taken away then the diagnostic process in CEN-152 becomes must less generic and therefore much less applicable to the diverse utilities.
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