IR 05000528/2005001
| ML050610294 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/02/2005 |
| From: | Troy Pruett Division Reactor Projects III |
| To: | Overbeck G Arizona Public Service Co |
| References | |
| IR-05-001 | |
| Download: ML050610294 (8) | |
Text
rch 2, 2005
SUBJECT:
ANNUAL ASSESSMENT LETTER - PALO VERDE NUCLEAR GENERATING STATION (REPORT 05000528/2005001; 05000529/2005001; 05000530/2005001)
Dear Mr. Overbeck:
On February 3, 2005, the NRC completed its end-of-cycle plant performance assessment of the Palo Verde Nuclear Generating Station. The end-of-cycle review for Palo Verde involved the participation of reactor technical divisions in evaluating performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2004.
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 so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.
This performance review and enclosed inspection plan do not include physical protection information. A separate end-of-cycle performance review letter designated and marked as
"Exempt from Public Disclosure in Accordance with 10 CFR 2.390" will include the physical protection review and resultant inspection plan.
Overall, Palo Verde operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green). However, two apparent violations, including the final significance determination of an associated potentially greater than Green finding, involving the voiding of the emergency core cooling system containment sump suction piping is still under review as part of the significance determination and traditional enforcement processes. These apparent violations were discussed at a conference on February 17, 2005.
During the assessment process, the staff identified a substantive crosscutting issue in the area of human performance. The adverse trend in human performance issues indicates that you have not effectively addressed the underlying causes associated with this substantive crosscutting area. The substantive crosscutting issue involved 16 Green findings. These
Arizona Public Service Company -2-findings shared several common performance characteristics; however, they were dominated by personnel errors (e.g., instances of failing to follow procedure) and resource issues (e.g.,
inadequate procedures and work instructions). These problems were identified across several cornerstones and involved multiple groups within your organization. Specifically, nine Green findings involving personnel errors were primarily associated with a failure to follow procedures.
Three of these findings involved personnel failing to implement emergency procedures during the loss of offsite power event in June 2004, while other findings pertained to personnel errors involving the movement of irradiated fuel. In addition, four findings were identified regarding the adequacy of procedures and work instructions. In one example, the work instructions for pressurizer spray valve maintenance were not adequate and the valve failed open shortly after maintenance on the valve and valve positioner.
Additionally, a substantive crosscutting issue in problem identification and resolution has been identified based on a number of corrective action findings. The adverse trend in problem identification and resolution issues indicates that you have not effectively addressed the underlying causes associated with this substantive crosscutting area. The substantial crosscutting issue involved 18 Green findings. These findings were indicative of implementation problems within the specific areas of identifying problems and entering them in the corrective action program, evaluating conditions in the corrective action program, and implementing effective corrective actions. These problems were identified across several cornerstones and involved multiple groups within your organization. Specifically, four findings were identified with a common performance characteristic associated with the failure to adequately identify problems in your corrective action program. In two of these cases, NRC inspectors had to prompt Palo Verde staff members to enter problems into your program. In addition, seven findings shared a common performance characteristic associated with a failure to adequately evaluate conditions. Four of these examples involved the failure to promptly evaluate the operability of degraded or nonconforming equipment. This included the failure to promptly evaluate voided suction piping in the emergency core cooling systems. Also of concern were seven Green findings with a common performance characteristic associated with inadequate corrective actions. Several of these findings resulted in plant events or the failure of safety equipment to operate correctly during an event. For example, the failure to take adequate corrective actions for a failure of an emergency diesel generator excitation circuit contributed to the failure of the Unit 2, Train A emergency diesel generator to respond as designed to the loss of offsite power event in June 2004.
Through implementation of the baseline inspection program, we will assess your actions to address both of these crosscutting issues. The closure of these issues will be based on whether your corrective actions reduce the number of findings.
As noted in our previous annual assessment letter, a meeting was conducted at the NRC Region IV Office on January 14, 2004, to discuss aspects of safety conscious work environment at Palo Verde. This issue was discussed again in our midcycle assessment letter, dated August 30, 2004. During the January 14 meeting, you discussed plans to conduct additional employee training related to safety conscious work environment and conduct a site survey in 2005 to gauge the work environment and employee willingness to raise safety issues. We understand that the training has been completed and the site survey is scheduled to be completed by March 2005. We will continue to focus our baseline inspection activities on your actions to address your assessments in this area.
Arizona Public Service Company -3-The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. In addition to the baseline inspections, NRC will also be conducting inspections related to Inspection Procedure 50001, "Steam Generator Replacement Inspection," Temporary Instructions 2515/150, "Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles," and 2515/160, Pressurizer Penetration Nozzles and Steam Space Piping Connections in U.S. Pressurized Water Reactors (NRC Bulletin 2004-01)."
The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved 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 meeting.
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 me at 817-860-8173 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Troy W. Pruett, Chief Project Branch D Division of Reactor Projects Dockets: 50-528 50-529 50-530 Licenses: NPF-41 NPF-51 NPF-74 Enclosure:
Palo Verde Nuclear Generating Station Inspection/Activity Plan cc w/enclosure: Karen Armes, Regional Director Daniel Roe, Executive Director Federal Emergency Management Agency Arizona Division of Emergency Region IX Management 1111 Broadway, Suite 1200 5636 East McDowell Road Oakland, CA 94607-4052 Building 101 Phoenix, AZ 85008-3495
Arizona Public Service Company -4-The Honorable Ron Drake The Honorable Adolfo Gamez Mayor of Avondale Mayor of Tolleson 525 North Central 9555 West Van Buren Street Avondale, AZ 85323 Tolleson, AZ 85353 The Honorable Dustin Hull The Honorable Bryan Hackbarth Mayor of Buckeye Mayor of Youngtown 100 North Apache Road 12030 Clubhouse Square Buckeye, AZ 85326 Youngtown, AZ 85363 The Honorable Fred Waterman Steve Olea Mayor of El Mirage Arizona Corporation Commission P.O. Box 26 1200 W. Washington Street El Mirage, AZ 85335 Phoenix, AZ 85007 The Honorable Elaine Scruggs Douglas K. Porter, Senior Counsel Mayor of Glendale Southern California Edison Company 5850 West Glendale Avenue Law Department, Generation Resources Glendale, AZ 85301 P.O. Box 800 Rosemead, CA 91770 The Honorable Jim Cavanaugh Mayor of Goodyear Chairman 119 North Litchfield Road Maricopa County Board of Supervisors Goodyear, AZ 85338 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 The Honorable J. Woodfin Thomas Mayor of Litchfield Aubrey V. Godwin, Director 244 West Wigwam Blvd. Arizona Radiation Regulatory Agency Litchfield Park, AZ 85340 4814 South 40 Street Phoenix, AZ 85040 The Honorable John Keegan Mayor of Peoria M. Dwayne Carnes, Director 8401 West Monroe Street Regulatory Affairs/Nuclear Assurance Peoria, AZ 85345 Palo Verde Nuclear Generating Station Mail Station 7636 The Honorable Phil Gordon P.O. Box 52034 Mayor of Phoenix Phoenix, AZ 85072-2034 200 West Washington Phoenix, AZ 85007 Hector R. Puente Vice President, Power Generation The Honorable Joan Shafer El Paso Electric Company Mayor of Surprise 310 E. Palm Lane, Suite 310 12425 West Bell Road Phoenix, AZ 85004 Surprise, AZ 85374
Arizona Public Service Company -5-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 Cheryl Adams Southern California Edison Company 5000 Pacific Coast Hwy. Bldg. DIN 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 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339
Arizona Public Service Company -6-Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (GXW2)
Branch Chief, DRP/D (TWP)
Senior Project Engineer, DRP/D (GEW)
Team Leader, DRP/TSS (RLN1)
RITS Coordinator (KEG)
RidsNrrDipmIipb V. Dricks, PAO (VLD)
W. Maier, RSLO (WAM)
C. Gordon (CJG)
DRS Branch Chiefs (LJS, MPS1, ATG, JAC)
S. Richards, Chief, NRR/DIPM/IIPB (SAR)
M. Case, Deputy Dir. for Inspection and Programs (MJC)
B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)
B. Wetzel, Acting Chief, ROPMS, OEDO (DWW)
H. Berkow, Director, LPD4, NRR/DLPM (HNB)
R. Gramm, Chief, PDIV-2, NRR/DLPM (RAG)
M. Fields, NRR Project Manager (MBF1)
SISP Review Completed: TWP___ ADAMS: / Yes G No Initials: TWP__
/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive S:\DRP\DRPDIR\EOC 04\Assessment Letters\PV.wpd RIV:DRP/D D:DRS D:DRP For signature TWPruett;mjs DDChamberlain ATHowell TWPruett
/RA/ /RA/ /RA/ /RA/
2/23/05 2/25/05 2/25/05 3/2/05 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Page 1 of 2 Palo Verde 03/01/2005 08:36:21 Inspection / Activity Plan Report 22 03/04/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type OB-EP EX - EMERGENCY PREPAREDNESS EXERCISE 5 1, 2, 3 IP 7111401 Exercise Evaluation 02/28/2005 03/04/2005 Baseline Inspections 1, 2, 3 IP 7111404 Emergency Action Level and Emergency Plan Changes 02/28/2005 03/04/2005 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 02/28/2005 03/04/2005 Baseline Inspections EB17B - PERMANENT PLANT MODS 2 1, 2, 3 IP 7111117B Permanent Plant Modifications 03/07/2005 03/11/2005 Baseline Inspections PEB-12B - MAINTENANCE EFFECTIVENESS 2 1, 2, 3 IP 7111112B Maintenance Effectiveness 03/07/2005 03/11/2005 Baseline Inspections SG REPL - U1 STEAM GEN REPLACEMENT 4 1 IP 50001 Steam Generator Replacement Inspection 02/28/2005 12/31/2005 Other Routine EB - 10CFR50.59 1 1, 2, 3 IP 7111102 Evaluation of Changes, Tests, or Experiments 03/07/2005 03/11/2005 Baseline Inspections EB08P - ISI U2 - VESSEL VOL (TI 150/152) AS REQ 2 2 IP 2515/150 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC Bulletin 2002-02 04/04/2005 04/15/2005 Safety Issues 2 IP 2515/160 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01] 04/04/2005 04/15/2005 Safety Issues 2 IP 7111108P Inservice Inspection Activities - PWR 04/04/2005 04/15/2005 Baseline Inspections 2 IP 7111108P Inservice Inspection Activities - PWR 04/11/2005 04/22/2005 Baseline Inspections OB-INIT - INITIAL EXAM 3 1 X02282 PALO VERDE UNIT1 (05/05) INITIAL EXAM 07/11/2005 07/15/2005 Not Applicable 2 X02283 PALO VERDE UNIT 2 (11/05) - INITIAL EXAM 07/11/2005 07/15/2005 Not Applicable 3 X02284 PALO VERDE UNIT 3 (11/05) - INITIAL EXAM 07/11/2005 07/15/2005 Not Applicable 1 X02282 PALO VERDE UNIT1 (05/05) INITIAL EXAM 08/01/2005 08/05/2005 Not Applicable 2 X02283 PALO VERDE UNIT 2 (11/05) - INITIAL EXAM 08/01/2005 08/05/2005 Not Applicable 3 X02284 PALO VERDE UNIT 3 (11/05) - INITIAL EXAM 08/01/2005 08/05/2005 Not Applicable EB08P - ISI U1 - VESS VOL (TI 150/152) AS REQ 2 1 IP 2515/160 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01] 10/10/2005 10/14/2005 Safety Issues 1 IP 7111108P Inservice Inspection Activities - PWR 10/10/2005 10/14/2005 Baseline Inspections 1 IP 7111108P Inservice Inspection Activities - PWR 10/24/2005 10/28/2005 Baseline Inspections ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1, 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections EB21 - ENG-SSD&PC 6 1, 2, 3 IP 7111121 Safety System Design and Performance Capability 01/09/2006 02/24/2006 Baseline Inspections OB-EP2 - EMERG PREPAREDNESS PROGRAM INSPECTION 1 1, 2, 3 IP 7111402 Alert and Notification System Testing 01/23/2006 01/27/2006 Baseline Inspections 1, 2, 3 IP 7111403 Emergency Response Organization Augmentation Testing 01/23/2006 01/27/2006 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 03/01/2005 08:36:21 Inspection / Activity Plan Report 22 03/04/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type OB-EP2 - EMERG PREPAREDNESS PROGRAM INSPECTION 1 1, 2, 3 IP 7111404 Emergency Action Level and Emergency Plan Changes 01/23/2006 01/27/2006 Baseline Inspections 1, 2, 3 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 01/23/2006 01/27/2006 Baseline Inspections 1, 2, 3 IP 71151 Performance Indicator Verification 01/23/2006 01/27/2006 Baseline Inspections ALARA1 - ALARA PLANNING AND CONTROLS 1 1, 2, 3 IP 7112102 ALARA Planning and Controls 02/13/2006 02/17/2006 Baseline Inspections PEB-05T - TRIENNIAL FIRE PROTECTION 4 1, 2, 3 IP 7111105T Fire Protection 04/10/2006 04/14/2006 Baseline Inspections 1, 2, 3 IP 7111105T Fire Protection 04/24/2006 04/28/2006 Baseline Inspections EB08 - U3-ISI 1 2 IP 7111108P Inservice Inspection Activities - PWR 04/03/2006 05/05/2006 Baseline Inspections ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1, 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 04/10/2006 04/14/2006 Baseline Inspections PEB - PV PIR INSPECTION 3 1, 2, 3 IP 71152B Identification and Resolution of Problems 05/08/2006 05/12/2006 Baseline Inspections 1, 2, 3 IP 71152B Identification and Resolution of Problems 05/22/2006 05/26/2006 Baseline Inspections PEB - HX PERFORMANCE 1 1, 2, 3 IP 7111107B Heat Sink Performance 06/05/2006 06/09/2006 Baseline Inspections OB-RQ - PV REQUALIFICATION INSP 3 1, 2, 3 IP 7111111B Licensed Operator Requalification Program 08/07/2006 08/11/2006 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.