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
March 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:
Daniel Roe, Executive Director Arizona Division of Emergency Management 5636 East McDowell Road Building 101 Phoenix, AZ 85008-3495 Karen Armes, Regional Director Federal Emergency Management Agency Region IX 1111 Broadway, Suite 1200 Oakland, CA 94607-4052
Arizona Public Service Company-4-The Honorable Ron Drake Mayor of Avondale 525 North Central 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 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 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 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 M. Dwayne Carnes, Director Regulatory Affairs/Nuclear Assurance 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
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
Palo Verde Inspection / Activity Plan 03/04/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 03/01/2005 08:36:21 Report 22
OB-EP EX
- EMERGENCY PREPAREDNESS EXERCISE Baseline Inspections 02/28/2005 03/04/2005 Exercise Evaluation IP 7111401 1, 2, 3 Baseline Inspections 02/28/2005 03/04/2005 Emergency Action Level and Emergency Plan Changes IP 7111404 1, 2, 3 Baseline Inspections 02/28/2005 03/04/2005 Performance Indicator Verification IP 71151 1, 2, 3
EB17B
- PERMANENT PLANT MODS Baseline Inspections 03/07/2005 03/11/2005 Permanent Plant Modifications IP 7111117B 1, 2, 3
PEB-12B
- MAINTENANCE EFFECTIVENESS Baseline Inspections 03/07/2005 03/11/2005 Maintenance Effectiveness IP 7111112B 1, 2, 3
SG REPL
- U1 STEAM GEN REPLACEMENT Other Routine 02/28/2005 12/31/2005 Steam Generator Replacement Inspection IP 50001
1 EB
- 10CFR50.59 Baseline Inspections 03/07/2005 03/11/2005 Evaluation of Changes, Tests, or Experiments IP 7111102 1, 2, 3
EB08P
- ISI U2 - VESSEL VOL (TI 150/152) AS REQ Safety Issues 04/04/2005 04/15/2005 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC Bulletin 2002-02 IP 2515/150
Safety Issues 04/04/2005 04/15/2005 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01]
Baseline Inspections 04/04/2005 04/15/2005 Inservice Inspection Activities - PWR IP 7111108P
Baseline Inspections 04/11/2005 04/22/2005 Inservice Inspection Activities - PWR IP 7111108P
3 OB-INIT
- INITIAL EXAM Not Applicable 07/11/2005 07/15/2005 PALO VERDE UNIT1 (05/05) INITIAL EXAM X02282
Not Applicable 07/11/2005 07/15/2005 PALO VERDE UNIT 2 (11/05) - INITIAL EXAM X02283
Not Applicable 07/11/2005 07/15/2005 PALO VERDE UNIT 3 (11/05) - INITIAL EXAM X02284
Not Applicable 08/01/2005 08/05/2005 PALO VERDE UNIT1 (05/05) INITIAL EXAM X02282
Not Applicable 08/01/2005 08/05/2005 PALO VERDE UNIT 2 (11/05) - INITIAL EXAM X02283
Not Applicable 08/01/2005 08/05/2005 PALO VERDE UNIT 3 (11/05) - INITIAL EXAM X02284
2 EB08P
- ISI U1 - VESS VOL (TI 150/152) AS REQ Safety Issues 10/10/2005 10/14/2005 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01]
Baseline Inspections 10/10/2005 10/14/2005 Inservice Inspection Activities - PWR IP 7111108P
Baseline Inspections 10/24/2005 10/28/2005 Inservice Inspection Activities - PWR IP 7111108P
1 ACRSA
- ACCESS CONTROL TO RAD SIGNIFICANT AREAS Baseline Inspections 10/17/2005 10/21/2005 Access Control to Radiologically Significant Areas IP 7112101 1, 2, 3
EB21
- ENG-SSD&PC Baseline Inspections 01/09/2006 02/24/2006 Safety System Design and Performance Capability IP 7111121 1, 2, 3
OB-EP2
- EMERG PREPAREDNESS PROGRAM INSPECTION Baseline Inspections 01/23/2006 01/27/2006 Alert and Notification System Testing IP 7111402 1, 2, 3 Baseline Inspections 01/23/2006 01/27/2006 Emergency Response Organization Augmentation Testing IP 7111403 1, 2, 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Palo Verde Inspection / Activity Plan 03/04/2005 - 09/30/2006 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 03/01/2005 08:36:21 Report 22
OB-EP2
- EMERG PREPAREDNESS PROGRAM INSPECTION Baseline Inspections 01/23/2006 01/27/2006 Emergency Action Level and Emergency Plan Changes IP 7111404 1, 2, 3 Baseline Inspections 01/23/2006 01/27/2006 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 7111405 1, 2, 3 Baseline Inspections 01/23/2006 01/27/2006 Performance Indicator Verification IP 71151 1, 2, 3
ALARA1
- ALARA PLANNING AND CONTROLS Baseline Inspections 02/13/2006 02/17/2006 ALARA Planning and Controls IP 7112102 1, 2, 3
PEB-05T
- TRIENNIAL FIRE PROTECTION Baseline Inspections 04/10/2006 04/14/2006 Fire Protection IP 7111105T 1, 2, 3 Baseline Inspections 04/24/2006 04/28/2006 Fire Protection IP 7111105T 1, 2, 3
EB08
- U3-ISI Baseline Inspections 04/03/2006 05/05/2006 Inservice Inspection Activities - PWR IP 7111108P
1 ACRSA
- ACCESS CONTROL TO RAD SIGNIFICANT AREAS Baseline Inspections 04/10/2006 04/14/2006 Access Control to Radiologically Significant Areas IP 7112101 1, 2, 3
PEB
- PV PIR INSPECTION Baseline Inspections 05/08/2006 05/12/2006 Identification and Resolution of Problems IP 71152B 1, 2, 3 Baseline Inspections 05/22/2006 05/26/2006 Identification and Resolution of Problems IP 71152B 1, 2, 3
PEB
- HX PERFORMANCE Baseline Inspections 06/05/2006 06/09/2006 Heat Sink Performance IP 7111107B 1, 2, 3
OB-RQ
- PV REQUALIFICATION INSP Baseline Inspections 08/07/2006 08/11/2006 Licensed Operator Requalification Program IP 7111111B 1, 2, 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.