IR 05000528/2006001
| ML060610254 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/02/2006 |
| From: | Mallett B Region 4 Administrator |
| To: | James M. Levine Arizona Public Service Co |
| References | |
| IR-06-001 | |
| Download: ML060610254 (10) | |
Text
rch 2, 2006
SUBJECT:
ANNUAL ASSESSMENT LETTER - PALO VERDE NUCLEAR GENERATING STATION (NRC INSPECTION REPORT 05000528/2006001; 05000529/2006001; 05000530/2006001)
Dear Mr. Levine:
On February 8, 2006, the NRC staff completed its performance review of the Palo Verde Nuclear Generating Station. Our technical staff reviewed performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2005. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as Official Use Only - Security Related Information will include the physical protection review and resultant inspection plan.
Overall, Palo Verde Nuclear Generating Station, Units 1, 2, and 3, operated in a manner that preserved public health and safety and met all cornerstone objectives with moderate degradation in safety performance. Plant performance for the most recent quarter for all three units was within the Degraded Cornerstone column of the NRCs Action Matrix based on one Yellow finding in the Mitigating Systems Cornerstone involving a significant section of containment sump safety injection piping that was void of water at all three Palo Verde Nuclear Generating Station units.
Our May 3, 2005, Assessment Follow-Up Letter identified that Palo Verde Nuclear Generating Station's performance was within the Degraded Cornerstone column of the NRCs Action Matrix.
On June 14, 2005, the Arizona Public Service Company requested postponement of the planned NRC supplemental inspection in order to allow sufficient time to complete the root cause evaluations and develop corrective actions. Accordingly, the NRC staff delayed the inspection until the fourth quarter of 2005. In December 2005, the NRC completed the implementation of Supplemental Inspection Procedure 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area." This supplemental inspection reviewed your root cause, extent of cause and condition, as well as, the corrective actions for: (1) the Yellow finding involving the failure to adequately control the design configuration of the containment sump safety injection suction piping of all three units; and
Arizona Public Service Company -2-(2) the Severity Level Ill violation for the failure to perform a 10 CFR 50.59 safety evaluation and receive prior NRC approval of a change to an emergency core cooling system (ECCS) leak test procedure. The results of the supplemental inspection were documented in NRC Inspection Report 05000528/2005012; 05000529/2005012; 05000530/2005012.
The NRC concluded that, while you performed an adequate root cause evaluation of the design control violation for the Yellow finding, certain corrective actions were incomplete at the time of the inspection. Specifically, for each of the root and contributing causes, not all corrective actions were sufficiently developed to ensure that the identified performance deficiencies were adequately addressed. Some of the corrective actions were narrowly focused, or the implementation of those actions was not fully effective at the time of the inspection.
Additionally, monitoring criteria and reviews were not fully established to ensure that corrective actions were effective in improving performance. Consequently, we did not have assurance that your planned corrective actions were sufficient to address the causes for the performance deficiencies associated with the violation. We request that you inform us in writing once you have completed steps to assure that your corrective actions are of sufficient scope and breadth to address the subject performance deficiencies. The NRC will then perform additional inspections as necessary to assess the effectiveness of your actions. Pending completion of this follow-up inspection activity, including an NRC assessment that your corrective actions are sufficient to address the performance deficiencies, the Yellow finding in the Mitigating Systems Cornerstone will remain open.
For the violation involving the NRC's identification of a failure to perform a 10 CFR 50.59 safety evaluation and receive prior NRC approval for a change of an ECCS leak test procedure, the NRC concluded that you performed an adequate evaluation and implemented corrective and followup actions necessary to reasonably prevent repetition of the 10 CFR 50.59 Severity Level III violation. Therefore, this violation was closed.
In our Annual Assessment letter, dated March 2, 2005, and our midcycle assessment letter, dated August 30, 2005, we advised you of substantive crosscutting issues in the areas of human performance and problem identification and resolution. During this assessment period, we continued to identify findings with the same causes and common themes in both crosscutting areas. There were 16 Green findings with crosscutting aspects in the area of human performance. Our assessment indicates that your actions to date have not completely corrected the root causes associated with procedural compliance, procedural adequacy, and the interactions between engineering and operations personnel when assessing degraded and nonconforming conditions. Additionally, there were 12 Green and Severity Level IV findings with crosscutting aspects in the area of problem identification and resolution. Our assessment indicates that your actions to date have not completely corrected the root causes associated with the identification of non-conforming conditions, the evaluation of conditions adverse to quality, particularly by engineering and operations personnel, and the implementation of effective corrective actions for deficient conditions.
During the assessment period, the NRC performed periodic reviews of your corrective actions associated with both crosscutting areas. Following the issuance of the August 30, 2005, midcycle assessment letter, you completed re-analyses of the human performance and problem identification and resolution concerns. You also approved the Performance Improvement Plan in November 2005 and began briefing station personnel on improvement initiatives in
Arizona Public Service Company -3-January 2006. Nevertheless, as of the end of the period, the implementation of the improvement initiatives had not completely addressed the original causes of the issues identified in our previous letters and discussed during public meetings conducted in April, May, and August 2005.
A meeting has been scheduled for March 30, 2006, in Arlington, Texas, to discuss the Performance Improvement Plan and corrective actions taken or planned to improve performance relative to these substantive crosscutting issues. You are requested to address these two issues during the Annual Assessment Meeting on April 5, 2006, in Tonopah, Arizona.
Additionally, you are requested to provide a written response within 30 days of the date of this letter to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; and the NRC Resident Inspector at the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility. Specifically, your written response should identify the probable causes, corrective actions you have taken or plan to take, and the estimated corrective action completion dates for performance deficiencies associated with: (1) the failure of personnel to follow procedures, (2) the use of inadequate procedures, (3) ineffective interactions between engineering and operations personnel when assessing degraded and nonconforming conditions, (4) inadequate identification of nonconforming conditions, (5) inadequate evaluation of conditions adverse to quality by engineering and operations personnel, and (6) inadequate and ineffective corrective actions.
Our midcycle assessment letter, dated August 30, 2005, also discussed the August 18, 2005, public meeting, in which your staff informed us of the results of the site-wide employee survey.
The survey results included some conflicting results (e.g., positive statistical results of survey questions relative to negative write-in comments), and your staff discussed the need for further actions. The NRC focused on safety conscious work environment issues, including actions taken in response to the survey, as part of our routine baseline inspection activities and during the January 2006 problem identification and resolution inspection. No instances were identified in which plant personnel would not raise safety concerns. However, several personnel indicated that they did not believe management would resolve minor concerns when identified.
Your 2005 Business Plan and Performance Improvement Plan include actions to address safety conscious work environment issues at the Palo Verde Nuclear Generating Station. We will continue to focus on your initiatives in this area as part of our baseline inspection program to monitor your corrective actions for these issues.
The August 30, 2005, midcycle assessment letter also discussed a Severity Level Ill violation issued on June 27, 2005. The violation involved the NRC's identification of a change to the Palo Verde Nuclear Generating Station Emergency Plan without prior Commission approval, which decreased the plan's effectiveness. The NRC staff conducted an inspection of your root cause analyses and corrective actions as part of the January 2006 problem identification and resolution inspection. The results of this inspection will be documented in NRC Inspection Report 05000528/2006008; 05000529/2006008; 05000530/2006008.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through September 30, 2007. In addition to the baseline inspections, NRC will be implementing Inspection Procedure 50001, "Steam Generator Replacement
Arizona Public Service Company -4-Inspection," relative to the planned replacement of the Unit 3 steam generators. We will conduct a follow-up Supplemental Inspection Procedure 95002 after receiving notification from you that the corrective actions for the Yellow finding are of sufficient scope and breadth (including the establishment of appropriate effectiveness measures) to address the subject performance deficiencies. We also plan to perform an additional problem identification and resolution inspection in early 2007 to further evaluate the effectiveness of your corrective actions in resolving the substantive crosscutting issues. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the midcycle review.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Troy W. Pruett at (817) 860-8173 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Bruce S. Mallett Regional Administrator Dockets: 50-528 50-529 50-530 Licenses: NPF-41 NPF-51 NPF-74 Enclosure:
Palo Verde Nuclear Generating Station Inspection/Activity Plan
Arizona Public Service Company -5-cc w/enclosure:
Louis Trammell, Director The Honorable Phil Gordon Arizona Division of Emergency Mayor of Phoenix Management Phoenix City Hall 5636 East McDowell Road 200 West Washington Building 101 Phoenix, AZ 85007 Phoenix, AZ 85008-3495 The Honorable Joan Shafer Karen E. Armes, Acting Regional Director Mayor of Surprise Federal Emergency Management Agency 12425 West Bell Road Region IX Surprise, AZ 85374 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 The Honorable Adolfo Gamez Mayor of Tolleson The Honorable Marie Lopez-Rogers 9555 West Van Buren Street Mayor of Avondale Tolleson, AZ 85353 11465 W. Civic Center Drive, Suite 280 Avondale, AZ 85323 The Honorable Bryan Hackbarth Mayor of Youngtown The Honorable Dustin Hull 12030 Clubhouse Square Mayor of Buckeye Youngtown, AZ 85363 100 North Apache Road Buckeye, AZ 85326 Robin Berry Palo Verde School District The Honorable Fred Waterman P.O. Box 108 Mayor of El Mirage Palo Verde, AZ 85343 P.O. Box 26 El Mirage, AZ 85335 Chad Turner, Superintendent Arlington Elementary The Honorable Elaine Scruggs School District Mayor of Glendale 9410 S. 355th Avenue 5850 West Glendale Avenue Arlington, AZ 85322 Glendale, AZ 85301 Carter Gable The Honorable Jim Cavanaugh Arlington Canal Company Mayor of Goodyear P.O. Box 150 119 North Litchfield Road Arlington, AZ 85322 Goodyear, AZ 85338 Doris Heisler The Honorable J. Woodfin Thomas Tonopah Valley Association Mayor of Litchfield 3002 N. 423rd Avenue 244 West Wigwam Blvd. Tonopah, AZ 85354 Litchfield Park, AZ 85340 Lyle King The Honorable John Keegan Buckeye Farmer Mayor of Peoria P.O. Box 713 8401 West Monroe Street Buckeye, AZ 85326 Peoria, AZ 85345
Arizona Public Service Company -6-Chris Larson Office of U.S. Senator John McCain Arlington CATS Club 5353 North 16th Street, Suite 105 P.O. Box 194 Phoenix, AZ 85016 Arlington, AZ 85322 Ruben H. Reyes, District Director Grace Molina Office of U.S. Congressman Raul Grijalva Arlington Hispanic Community 810 E. 22nd Street, Suite 102 P.O. Box 131 Tucson, AZ 85713 Arlington, AZ 85322 Sheriff Joe Arpaio Les Meredith 100 West Washington, Suite 1900 Arlington Lions Club Phoenix, AZ 85003 P.O. Box 69 Arlington, AZ 85322 Fulton Brock, Supervisor, District 1 Board of Supervisors Pam Miller 301 W. Jefferson HC03 Box 85 Phoenix, AZ 85003 Palo Verde, AZ 85343 Don Stapley, Supervisor, District 2 Neil Peters Board of Supervisors P.O. Box 57 301 W. Jefferson Arlington, AZ 85322 Phoenix, AZ 85003 Paul Roetto Andrew Kunasek, Supervisor, District 3 Friends of Saddle Mountain Board of Supervisors 3708 N. 339th Avenue 301 W. Jefferson Tonopah, AZ 85354 Phoenix, AZ 85003 Roxanne Morris Max W. Wilson, Supervisor, District 4 Ruth Fisher Unified School District Board of Supervisors 38201 W. Indian School Road 301 W. Jefferson Tonopah, AZ 85354 Phoenix, AZ 85003 Judy Shaw Mary Rose Wilcox, Supervisor, District 5 20 N. 350th Avenue Board of Supervisors Tonopah, AZ 85354 301 W. Jefferson Phoenix, AZ 85003 Robert Hathaway TVCC Steve Olea 37705 W. Buckeye Road Arizona Corporation Commission Tonopah, AZ 85354 1200 W. Washington Street Phoenix, AZ 85007 Andy Jacobs Office of U.S. Senator Jon Kyl Douglas K. Porter, Senior Counsel 2200 E. Camelback Road, Suite 120 Southern California Edison Company Phoenix, AZ 85016 Law Department, Generation Resources P.O. Box 800 Carlos Sierra Rosemead, CA 91770
Arizona Public Service Company -7-Chairman Salt River Project Maricopa County Board of Supervisors 6504 East Thomas Road 301 W. Jefferson, 10th Floor Scottsdale, AZ 85251 Phoenix, AZ 85003 Brian Almon Aubrey V. Godwin, Director Public Utility Commission Arizona Radiation Regulatory Agency William B. Travis Building 4814 South 40 Street P.O. Box 13326 Phoenix, AZ 85040 1701 North Congress Avenue Austin, TX 78701-3326 Craig K. Seaman, General Manager Regulatory Affairs and Karen O'Regan Performance Improvement Environmental Program Manager Palo Verde Nuclear Generating Station City of Phoenix Mail Station 7636 Office of Environmental Programs P.O. Box 52034 200 West Washington Street Phoenix, AZ 85072-2034 Phoenix, AZ 85003 Hector R. Puente Institute of Nuclear Power Operations (INPO)
Vice President, Power Generation Records Center El Paso Electric Company 700 Galleria Parkway SE, Suite 100 310 E. Palm Lane, Suite 310 Atlanta, GA 30339 Phoenix, AZ 85004 Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901 John W. Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Thomas D. Champ Southern California Edison Company 5000 Pacific Coast Hwy, Bldg. D1B San Clemente, CA 92672 Robert Henry
Arizona Public Service Company -8-Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
DRS Deputy Director (RJC1)
Senior Resident Inspector (GXW2)
Branch Chief, DRP/D (TWP)
Senior Project Engineer, DRP/D (GEW)
Team Leader, DRP/TSS (RLN1)
RITS Coordinator (KEG)
V. Dricks, PAO (VLD)
W. Maier, RSLO (WAM)
C. Gordon (CJG)
DRS Branch Chiefs (JAC, ATG, LJS, MPS1)
T. Bergman, Chief, TRPS, OEDO (TAB)
S. Richards, Deputy Director, DIRS, NRR (SAR)
C. Holden, Deputy Director, DORL, NRR (CFH)
C. Haney, Director, DORL, NRR (CXH)
D. Terao, Chief, LPLG, DORL, NRR (DXT)
M. Fields, NRR Project Manager (MBF1)
RidsNrrDirslpab SUNSI Review Completed: _twp__ ADAMS: : Yes G No Initials: __twp__
- Publicly Available G Non-Publicly Available G Sensitive : Non-Sensitive S:\DRP\DRPDIR\EOC 05\Assessment Letters\PV.wpd RIV:C:DRP/D D:DRS D:DRP DRA RA TWPruett;mjs DDChamberlain ATHowell III TPGwynn BSMallett
/RA/ /RA/ /RA/ BSMallett for /RA/
2/23/06 2/24/06 2/27/06 2/27/06 2/27/06 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Page 1 of 2 Palo Verde 03/01/2006 08:32:03 Inspection / Activity Plan Report 22 03/01/2006 - 09/30/2007 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type EB1-08P - U3-ISI 2 3 IP 7111108P Inservice Inspection Activities - PWR 04/10/2006 04/14/2006 Baseline Inspections 3 IP 7111108P Inservice Inspection Activities - PWR 04/24/2006 04/28/2006 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1, 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 04/10/2006 04/14/2006 Baseline Inspections 1, 2, 3 IP 7112102 ALARA Planning and Controls 04/10/2006 04/14/2006 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 04/10/2006 04/14/2006 Baseline Inspections EB2-07B - HX PERFORMANCE 1 1, 2, 3 IP 7111107B Heat Sink Performance 06/05/2006 06/09/2006 Baseline Inspections EB1-21 - CDB 8 1, 2, 3 IP 7111121 Component Design Bases Inspection 07/31/2006 08/04/2006 Baseline Inspections 1, 2, 3 IP 7111121 Component Design Bases Inspection 08/14/2006 08/25/2006 Baseline Inspections OB-RQ - PV REQUALIFICATION INSP 2 1, 2, 3 IP 7111111B Licensed Operator Requalification Program 09/18/2006 09/22/2006 Baseline Inspections EB1-08P - ISI U2 1 2 IP 7111108P Inservice Inspection Activities - PWR 10/16/2006 10/20/2006 Baseline Inspections 2 IP 7111108P Inservice Inspection Activities - PWR 10/30/2006 11/03/2006 Baseline Inspections SG REP - U3 SG REPLACEMENT ACTIVITIES 1 3 IP 50001 Steam Generator Replacement Inspection 01/01/2007 12/31/2007 Other Routine RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1, 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 01/08/2007 01/12/2007 Baseline Inspections 1, 2, 3 IP 7112102 ALARA Planning and Controls 01/08/2007 01/12/2007 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 01/08/2007 01/12/2007 Baseline Inspections EB2-12B - MAINTENANCE RULE INSPECTION 2 1, 2 IP 7111112B Maintenance Effectiveness 01/22/2007 01/26/2007 Baseline Inspections PIR - PIR INSPECTION 1 1, 2, 3 IP 71152B Identification and Resolution of Problems 01/22/2007 01/26/2007 Baseline Inspections 1, 2, 3 IP 71152B Identification and Resolution of Problems 02/05/2007 02/09/2007 Baseline Inspections RP TEAM - RADIATION SAFETY TEAM 5 1, 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 01/29/2007 02/02/2007 Baseline Inspections 1, 2, 3 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 01/29/2007 02/02/2007 Baseline Inspections 1, 2, 3 IP 7112202 Radioactive Material Processing and Transportation 01/29/2007 02/02/2007 Baseline Inspections 1, 2, 3 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 01/29/2007 02/02/2007 Baseline Inspections EP1 - PV EP EXERCISE 3 1, 2, 3 IP 7111401 Exercise Evaluation 03/05/2007 03/09/2007 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Palo Verde 03/01/2006 08:32:03 Inspection / Activity Plan Report 22 03/01/2006 - 09/30/2007 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type EP1 - PV EP EXERCISE 3 1, 2, 3 IP 7111404 Emergency Action Level and Emergency Plan Changes 03/05/2007 03/09/2007 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 03/05/2007 03/09/2007 Baseline Inspections EB1-08P - ISI U1 1 1 IP 7111108P Inservice Inspection Activities - PWR 04/02/2007 04/13/2007 Baseline Inspections RP-ORS - OCCUPATIONAL RADIATION SAFETY 1 1, 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 04/09/2007 04/09/2007 Baseline Inspections 1, 2, 3 IP 7112102 ALARA Planning and Controls 04/09/2007 04/09/2007 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 04/09/2007 04/09/2007 Baseline Inspections EXAM - INITIAL EXAM 3 1 X02351 PV UNIT 1 - INITIAL EXAM (08/07) 07/09/2007 07/13/2007 Not Applicable 2 X02352 PV UNIT 2 - INITIAL EXAM (08/07) 07/09/2007 07/13/2007 Not Applicable 3 X02353 PV UNIT 3 - INITIAL EXAM (08/07) 07/09/2007 07/13/2007 Not Applicable 1 X02351 PV UNIT 1 - INITIAL EXAM (08/07) 07/30/2007 08/03/2007 Not Applicable 2 X02352 PV UNIT 2 - INITIAL EXAM (08/07) 07/30/2007 08/03/2007 Not Applicable 3 X02353 PV UNIT 3 - INITIAL EXAM (08/07) 07/30/2007 08/03/2007 Not Applicable EB2-05T - TRIENNIAL FIRE PROTECTION 4 1, 2, 3 IP 7111105T Fire Protection [Triennial] 07/23/2007 07/27/2007 Baseline Inspections 1, 2, 3 IP 7111105T Fire Protection [Triennial] 08/13/2007 08/17/2007 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.