DOCKET050005280500052905000530

SUBJECT: Forwards revised responses to recommendations contained inNRC 860910 itr re emergency operating procedures, per 870226meet ing.

DISTRIBUTION CODE: A003D COPIES RECEIVED: LTR ENCL SI ZE:TITLE: OR/Licensing Submittal: Suppl 1 to NUREQ-0737(Qeneric Ltr 82-33)

REGULATOR NFORNATIOI'J DISTRIBUTION TEN (R IDS)

ACCESSION NBR: 8704030051 DOC. DATE: 87/03/27 NOTARIZED: NOFACIL:STN-50-528 Palo Verde Nuclea'r Stations Unit ii Arizona Publi

STN-50-529 Palo Verde Nuclear Station> Unit 2> Arizona Pub liSTN-50-530 Palo Verde Nuclear Stationi Unit 3i Arizona Pub I i

AUTH. NAl'lE AUTHOR AFFILIATIONHAYNES> J. Q.. Arizona Nuclear Pouer Prospect (formerlg Arizona Public Serv

RECIP. NAME RECIPIENT AFFILIATIONDocument Control Branch (Document Control Desk)

NOTES: Standardized plant. N. Davis. NRR: 1Cg.Standardized plant. N. Davis> hiRR: iCg.Standardized plant. M, Davi s. ERR: iCg.

050005380500052905000530

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Arizona Nuclear Power ProjectP.O. BOX 52034 ~ PHOENIX, ARIZONA85072-2034

March 27, 1987161-00108-.JGH/RAB

U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555

Subject: Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2 and 3Docket Numbers: STN 50-528 (License No. NPF-41)

STN 50-529 (License No. NPF-51)STN 50-530

Additional Information on PVNGS Emergency Operating ProceduresFile: 87-A-056-026

Reference: Letter from G. W. Knighton (NRC) to E. E. Van Brunt, Jr. (ANPP)dated September 10, 1986. Subject: Review of Palo VerdeProcedures as Related to the July 12th Trip at Palo Verde Unit 1.

Dear Sirs:

During a meeting held in Bethesda, MD on February 26, 1987 to discuss PVNGS

Emergency Operating Procedures, ANPP provided handout material to the NRC

staff which identified our response to recommendations contained in thereferenced letter. As a result of discussions during the meeting, it becameevident that ANPP had done more than was indicated in the handout and in somecases prior to receiving the NRC's staff's recommendations. The NRC staffverbally requested that ANPP revise its responses to reflect these items andto formally submit them.

At the meeting, ANPP also provided to Mr. Michael Goodman of the NRC staff,responses to the "A" category items which resulted from the September, 1984audit.

The attachment to the letter provides the revised responses as requested.

8704039ocp 0500@op00S> 870~0S28

PopP

JGH/RAB/)leAttachment

Very truly yours,.

J. G. HaynesVice PresidentNucle'ar Production

cc: 0. M. De MicheleE. E. Van Brunt, Jr.G. W. KnightonE. A. LicitraR. P. ZimmermanJ. B. MartinA. C. Gehr

(all w/a)

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ATTACHMENT

NRC Recommendation: As a preliminary step before the staff determinesthe acceptability of the Licensee's approach, thelicensee should define clearly the conditionsunder which the FRP would be used and develop apolicy (and technical basis) for those situationswhere decision points are unclear or necessaryinformation is unavailable. The licensee'sdescription should also include a statementregarding how they addressed the "A" items thatresulted from the staff audit of the Palo VerdeEOP's, conducted in September 1984.

APS Response: In order to more clearly define when theFunctional Recovery Procedure is to be used, achange was implemented to the Emergency OperationsProcedure and the Functional Recovery Procedure.The procedure change, using CEN-152 as a technicalbasis, is worded in the following manner:

If any of the following conditions exist, THENevaluate the need to implement the FunctionalRecovery Procedure, 41RO-1ZZ10

1. If a diagnosis is not possible.

or

2. A reactor trip and unusual concurrentsymptoms, with no immediately apparentdiagnosis or cause.

or

3. Any condition, or pattern of symptoms, whichthe operator considers serious, and for whichabnormal or 'mergency guidance cannot beidentified.

or

4. Actions taken in a Recovery OperationsProcedure are not satisfying Safety Functions.

To further clarify when the Functional RecoveryProcedure should be entered a meeting wasconducted between License Training and Operationsto ensure that simulator exercises include eventswhich lead to the Functional Recovery Procedure inboth License Training and Requalification

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Training. There will also be an increasedinterface between the Operations procedure groupand the License Training Department to clarifyOperations philosophy on use of all EmergencyOperations Procedures as well the Diagnostic FlowChart.

2 ~ NRC Recommendation: Palo Verde performs an analysis of the DiagnosticProcedure to determine if trending of SteamGenerator Pressure should be incorporated in theFlow Chart to help diagnose ESD events. Inaddition to use of parameter trending fordiagnosing other events should be considered.

APS Response: The trending of Steam Generator pressures in thediagnostic flow chart was evaluated and severalmodels were drawn up. Attempts to trend SteamGenerator pressure on the diagnostic resulted inseveral additional groups of decision blockmatrices, which made the diagnostic much moredifficult to follow. After evaluation, thedecision was made to include guidance in theEmergency Procedure regarding the importance oftrending Steam Generator pressure and theavailability of using fast closure of the MainSteam Isolation Valves to terminate an ExcessiveSteam Demand Event. License Training has alwaysincluded special emphasis on trending keyparameters such as Pressurizer and Steam Generatorpressure and level, and this emphasis will beenhanced in the future in both License Trainingand Requalification Training.

3 ~ NRC Recommendation: CEN-152 be changed to explicitly state thatparameter trending should be used in diagnosing anevent.

APS Response: This has been addressed to the GEOG Subcommittee,trending is already addressed in Appendix D of theEmergency Operations Procedure.

4 ~ NRC Recommendation: Parameters and instrumentation that are keyvariables, especially those that are needed in theearly stages of an event, be powered from a morereliable power supply.

APS Response: The loss of key instrumentation was recognized asa concern in the post trip review performed afterthe July 12, 1986 trip. Engineering EvaluationRequests were initiated, and the diagnosticdecision blocks were analyzed. Design ChangePackages are being developed to provide class IE

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power to the Containment Temperature and HumidityDetectors, the Radiation Monitoring Systemmini-computer (for control room indication), theContainment,Radwaste Sump level indication and keyradiation monitors which are used in thediagnostic flow chart. Additionally, guidance hasbeen added to the Emergency Procedure and thediagnostic to provide alternate means of acquiringinformation to answer decision blocks.

5 ~ NRC Recommendation: CEN-152 be revised to include statements to havereliable power supply for key parameters that areused in the early stage of an accident, i.e.,event diagnosis.

APS Response: This has been addressed to the GEOG Subcommitteeand has been addressed for PVNGS in the abovereferenced Design Change Packages.

6. NRC Recommendation: Palo Verde Diagnostic Flow Chart be changed toinclude logic statements and success paths thatwill direct the operator to a statement that willsend him to the Functional Recovery Procedure ordefine in the Flow Chart the conditions underwhich the Functional Recovery Procedure should beused.

APS Response: The Emergency Operations Procedure providesguidance for when the Functional RecoveryProcedure should be entered. This guidance willbe emphasized during training. Additionally theimmediate operator actions following a tripinvolve maintaining safety functions in afunctionally oriented manner similar to theFunctional Recovery Procedure. Placing decisionblocks and criteria for entering the Functional inthe Diagnostic would make the Diagnostic unwieldyand would create the impression that those are theonly times the Functional should be entered.

7 ~ NRC Recommendation: The Diagnostic Flow Chart, delete the requirementto trip reactor coolant pumps. This would makethe Flow Chart compatible with the SBLOCAprocedure and the trip strategy incorporated inCEN-152.

APS Response: The deletion of the requirement to trip all RCPs

prior to entering the SBLOCA had already beenidentified by ANPP prior to the July 12th event,and was scheduled to be included in the nextrevision to the Emergency Procedure which is nowcomplete. Additionally License Training

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emphasizes the desirabili.ty of maintaining forcedflow in events in which 28 F subcooling can bemaintained.

NRC Recommendation: Palo Verde reexamine the need for all otherstatements in the Diagnostic Flow Chart thatrequire operator actions and delete them ifpossible. This would eliminate action statementsin the Flow Chart that could be inconsistent withthe selected recovery procedure, and leave theDiagnostic Flow Chart as purely a diagnostic whichis consistent with the philosophy of CEN-152.

APS Response: The Diagnostic is divided into two sections, onesection serves as a second check to ensure safetyfunctions are being maintained and the otherportion serves to diagnose the event. Thefollowing list indicates 17 points on thediagnostic chart. Shown next to each point arethe manual actions required, e.g., trip reactor,followed by the safety function being maintained,e.g., reactivity control.

l. All CEAS inserted — Trip Reactor — ReactivityControl.

2. Greater than 1 CEA Not Full in — EmergencyBorate —Reactivity Control.

3. Reactor Power Decreasing — Emergency BorateReactivity Control.

4. RCS Press Greater than SIAS — Verify SIAS/CIAS— Inventory Control and Containment Integrity.

5. Pressurizer level on scale — Initiate SIASInventory Control.

6. RCS Subcool Greater than 28 F — Verify SIASInventory Control and Heat Removal.

7. CTMT Press. less than 3 PSIG — Verify SIAS,CIAS, MSIS — Containment Integrity, HeatRemoval, Inventory Control.

8. CTMT Press. less than 8.5 psig — Verify CSAS

Containment Integrity.

9. SG Press. greater than MSIS — Verify MSISContainment Integrity, Heat Removal.

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10. SG Level greater than 26X WR — Verify AFASHeat Removal.

ll. SBCS Available — Use Atmos. Dump — HeatRemoval.

12. TG Tripped — Trip Turbine Generator — HeatRemoval, Maintenance of Vital Auxiliaries.

13. CTMT RAD less than set — Initiate CIASContainment Integrity.

14. Rad Monitor less than Alarm Set — EvaluateAlarm — Indirect Radioactive Release.

15. RVLMS Indicates Core Is Covered — Verify SIAS— Heat Removal, Inventory Control.

16. Power Supply Alarm — Degraded Electrical PowerProcedure —Maintenance of Vital Auxiliaries.

17. CW, PW, TC, NC Available — Restore Flow perAbnormal Operating Procedure — MaintainsCondenser as Heat Sink for Heat Removal andRCPs support systems for forced circulation.

These operators actions are necessary formaintenance of safety functions and areconsistent with the recovery.

Events requiring tripping of RCPs will bediscussed separately.

This completes the Actions required in the SafetyFunction verification section. The diagnosticsection contains similar statements whereEssential Safeguards System Actuations areverified.

Tri in of RCPs

The Palo Verde philosophy of tripping 2 RCPsfollowing a RCS depressurization is consistentwith CEN-152 and is carried out in the diagnosticwhenever a Safety Injection plant specificsetpoint, is called for. In addition, thetripping of all RCPs is required on entry to theLarge Break LOCA procedure and is consequentlycalled for in the Diagnostic. The chance ofmisdiagnosis of an event leading to theunnecessary tripping of all RCPs is minimizedbecause, in order to reach a block which requires

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all RCPs to be tripped, a decision blockconcerning Containment Pressure being greater than3 psig must be answered affirmatively. Palo Verdeadministratively maintains Containment Pressureless than 1.5 psig during normal operation.Consequently, a large loss of either SteamGenerator or RCS inventory would be required toraise containment pressure to 3.0 psig.

NRC Recommendation: The Diagnostic Aides Section of CEN-152 be revisedto eliminate the vagueness as to what should beincluded in the EOPs. Words which can beconstrued to mean utilities do not have to complywith the section, should be deleted so deviationswill be identified by utilities referencingCEN-152.

APS Response: This has been addressed to the CE Owners Group.

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