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
March 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 Arizona Division of Emergency Management 5636 East McDowell Road Building 101 Phoenix, AZ 85008-3495 Karen E. Armes, Acting Regional Director Federal Emergency Management Agency Region IX 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 The Honorable Marie Lopez-Rogers Mayor of Avondale 11465 W. Civic Center Drive, Suite 280 Avondale, AZ 85323 The Honorable Dustin Hull Mayor of Buckeye 100 North Apache Road Buckeye, AZ 85326 The Honorable Fred Waterman Mayor of El Mirage P.O. Box 26 El Mirage, AZ 85335 The Honorable Elaine Scruggs Mayor of Glendale 5850 West Glendale Avenue Glendale, AZ 85301 The Honorable Jim Cavanaugh Mayor of Goodyear 119 North Litchfield Road Goodyear, AZ 85338 The Honorable J. Woodfin Thomas Mayor of Litchfield 244 West Wigwam Blvd.
Litchfield Park, AZ 85340 The Honorable John Keegan Mayor of Peoria 8401 West Monroe Street Peoria, AZ 85345 The Honorable Phil Gordon Mayor of Phoenix Phoenix City Hall 200 West Washington Phoenix, AZ 85007 The Honorable Joan Shafer Mayor of Surprise 12425 West Bell Road Surprise, AZ 85374 The Honorable Adolfo Gamez Mayor of Tolleson 9555 West Van Buren Street Tolleson, AZ 85353 The Honorable Bryan Hackbarth Mayor of Youngtown 12030 Clubhouse Square Youngtown, AZ 85363 Robin Berry Palo Verde School District P.O. Box 108 Palo Verde, AZ 85343 Chad Turner, Superintendent Arlington Elementary School District 9410 S. 355th Avenue Arlington, AZ 85322 Carter Gable Arlington Canal Company P.O. Box 150 Arlington, AZ 85322 Doris Heisler Tonopah Valley Association 3002 N. 423rd Avenue Tonopah, AZ 85354 Lyle King Buckeye Farmer P.O. Box 713 Buckeye, AZ 85326
Arizona Public Service Company-6-Chris Larson Arlington CATS Club P.O. Box 194 Arlington, AZ 85322 Grace Molina Arlington Hispanic Community P.O. Box 131 Arlington, AZ 85322 Les Meredith Arlington Lions Club P.O. Box 69 Arlington, AZ 85322 Pam Miller HC03 Box 85 Palo Verde, AZ 85343 Neil Peters P.O. Box 57 Arlington, AZ 85322 Paul Roetto Friends of Saddle Mountain 3708 N. 339th Avenue Tonopah, AZ 85354 Roxanne Morris Ruth Fisher Unified School District 38201 W. Indian School Road Tonopah, AZ 85354 Judy Shaw 20 N. 350th Avenue Tonopah, AZ 85354 Robert Hathaway TVCC 37705 W. Buckeye Road Tonopah, AZ 85354 Andy Jacobs Office of U.S. Senator Jon Kyl 2200 E. Camelback Road, Suite 120 Phoenix, AZ 85016 Carlos Sierra Office of U.S. Senator John McCain 5353 North 16th Street, Suite 105 Phoenix, AZ 85016 Ruben H. Reyes, District Director Office of U.S. Congressman Raul Grijalva 810 E. 22nd Street, Suite 102 Tucson, AZ 85713 Sheriff Joe Arpaio 100 West Washington, Suite 1900 Phoenix, AZ 85003 Fulton Brock, Supervisor, District 1 Board of Supervisors 301 W. Jefferson Phoenix, AZ 85003 Don Stapley, Supervisor, District 2 Board of Supervisors 301 W. Jefferson Phoenix, AZ 85003 Andrew Kunasek, Supervisor, District 3 Board of Supervisors 301 W. Jefferson Phoenix, AZ 85003 Max W. Wilson, Supervisor, District 4 Board of Supervisors 301 W. Jefferson Phoenix, AZ 85003 Mary Rose Wilcox, Supervisor, District 5 Board of Supervisors 301 W. Jefferson Phoenix, AZ 85003 Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770
Arizona Public Service Company-7-Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Craig K. Seaman, General Manager Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Hector R. Puente Vice President, Power Generation El Paso Electric Company 310 E. Palm Lane, Suite 310 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 Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Karen O'Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339
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
Palo Verde Inspection / Activity Plan 03/01/2006 - 09/30/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 03/01/2006 08:32:03 Report 22
EB1-08P
- U3-ISI Baseline Inspections 04/10/2006 04/14/2006
7111108P IP Inservice Inspection Activities - PWR Baseline Inspections 04/24/2006 04/28/2006
7111108P IP Inservice Inspection Activities - PWR
RP-ORS
- OCCUPATIONAL RADIATION SAFETY Baseline Inspections 04/10/2006 04/14/2006 1, 2, 3 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 04/10/2006 04/14/2006 1, 2, 3 7112102 IP ALARA Planning and Controls Baseline Inspections 04/10/2006 04/14/2006 1, 2, 3 71151 IP Performance Indicator Verification
EB2-07B
- HX PERFORMANCE Baseline Inspections 06/05/2006 06/09/2006 1, 2, 3 7111107B IP Heat Sink Performance
EB1-21
- CDB Baseline Inspections 07/31/2006 08/04/2006 1, 2, 3 7111121 IP Component Design Bases Inspection Baseline Inspections 08/14/2006 08/25/2006 1, 2, 3 7111121 IP Component Design Bases Inspection
OB-RQ
- PV REQUALIFICATION INSP Baseline Inspections 09/18/2006 09/22/2006 1, 2, 3 7111111B IP Licensed Operator Requalification Program
EB1-08P
- ISI U2 Baseline Inspections 10/16/2006 10/20/2006
7111108P IP Inservice Inspection Activities - PWR Baseline Inspections 10/30/2006 11/03/2006
7111108P IP Inservice Inspection Activities - PWR
- U3 SG REPLACEMENT ACTIVITIES Other Routine 01/01/2007 12/31/2007
50001 IP Steam Generator Replacement Inspection
RP-ORS
- OCCUPATIONAL RADIATION SAFETY Baseline Inspections 01/08/2007 01/12/2007 1, 2, 3 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 01/08/2007 01/12/2007 1, 2, 3 7112102 IP ALARA Planning and Controls Baseline Inspections 01/08/2007 01/12/2007 1, 2, 3 71151 IP Performance Indicator Verification
EB2-12B
- MAINTENANCE RULE INSPECTION Baseline Inspections 01/22/2007 01/26/2007 1, 2 7111112B IP Maintenance Effectiveness
- PIR INSPECTION Baseline Inspections 01/22/2007 01/26/2007 1, 2, 3 71152B IP Identification and Resolution of Problems Baseline Inspections 02/05/2007 02/09/2007 1, 2, 3 71152B IP Identification and Resolution of Problems
RP TEAM
- RADIATION SAFETY TEAM Baseline Inspections 01/29/2007 02/02/2007 1, 2, 3 7112103 IP Radiation Monitoring Instrumentation and Protective Equipment Baseline Inspections 01/29/2007 02/02/2007 1, 2, 3 7112201 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems Baseline Inspections 01/29/2007 02/02/2007 1, 2, 3 7112202 IP Radioactive Material Processing and Transportation Baseline Inspections 01/29/2007 02/02/2007 1, 2, 3 7112203 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program
EP1
- PV EP EXERCISE Baseline Inspections 03/05/2007 03/09/2007 1, 2, 3 7111401 IP Exercise Evaluation This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Palo Verde Inspection / Activity Plan 03/01/2006 - 09/30/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 03/01/2006 08:32:03 Report 22
EP1
- PV EP EXERCISE Baseline Inspections 03/05/2007 03/09/2007 1, 2, 3 7111404 IP Emergency Action Level and Emergency Plan Changes Baseline Inspections 03/05/2007 03/09/2007 1, 2, 3 71151 IP Performance Indicator Verification
EB1-08P
- ISI U1 Baseline Inspections 04/02/2007 04/13/2007
7111108P IP Inservice Inspection Activities - PWR
RP-ORS
- OCCUPATIONAL RADIATION SAFETY Baseline Inspections 04/09/2007 04/09/2007 1, 2, 3 7112101 IP Access Control to Radiologically Significant Areas Baseline Inspections 04/09/2007 04/09/2007 1, 2, 3 7112102 IP ALARA Planning and Controls Baseline Inspections 04/09/2007 04/09/2007 1, 2, 3 71151 IP Performance Indicator Verification
EXAM
- INITIAL EXAM Not Applicable 07/09/2007 07/13/2007
X02351 PV UNIT 1 - INITIAL EXAM (08/07)
Not Applicable 07/09/2007 07/13/2007
X02352 PV UNIT 2 - INITIAL EXAM (08/07)
Not Applicable 07/09/2007 07/13/2007
X02353 PV UNIT 3 - INITIAL EXAM (08/07)
Not Applicable 07/30/2007 08/03/2007
X02351 PV UNIT 1 - INITIAL EXAM (08/07)
Not Applicable 07/30/2007 08/03/2007
X02352 PV UNIT 2 - INITIAL EXAM (08/07)
Not Applicable 07/30/2007 08/03/2007
X02353 PV UNIT 3 - INITIAL EXAM (08/07)
EB2-05T
- TRIENNIAL FIRE PROTECTION Baseline Inspections 07/23/2007 07/27/2007 1, 2, 3 7111105T IP Fire Protection [Triennial]
Baseline Inspections 08/13/2007 08/17/2007 1, 2, 3 7111105T IP Fire Protection [Triennial]
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.