ML080320590

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IR 05000528/2007012, 05000529/2007012, and 05000530/2007012; Preliminary White Finding
ML080320590
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 02/01/2008
From: Caniano R
Division of Reactor Safety IV
To: Edington R
Arizona Public Service Co
Shared Package
ml080310447 List:
References
EA-08-003, IR-07-012
Download: ML080320590 (6)


See also: IR 05000528/2007012

Text

UNITED STATES

NUC LEAR REG U LATO R Y C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 40 0

AR LI N GTO N , TEXAS 76011-4005

February 1, 2008

EA-08-003

Randall K. Edington

Senior Vice President, Nuclear

Mail Station 7602

Arizona Public Service Company

P.O. Box 52034

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION: INSPECTION

REPORT 05000528/2007012, 05000529/2007012, AND 05000530/2007012;

PRELIMINARY WHITE FINDING

Dear Mr. Edington:

This letter discusses a finding that appears to have low-to-moderate safety significance. As

described in Section 5.7 of NRC Inspection Report 05000528/2007012, 05000529/2007012,

and 05000530/2007012, weaknesses in senior operators' ability to implement Emergency

Action Level 1-7 (potential loss of the reactor coolant system barrier) were identified by Palo

Verde Nuclear Generating Station during emergency response organization training for

operators, and the weaknesses were not corrected in a timely manner appropriate to the

significance of the knowledge deficiencies. Specifically, when evaluated during training

evolutions beginning in May 2007, a high percentage of senior operators incorrectly declared a

general emergency for simulated plant conditions that would require only a site area emergency

declaration, and corrective actions were not completed until October 2007.

The NRC determined that weaknesses associated with the senior operators' implementation of

Emergency Action Level 1-7 were identified on or about May 2, 2007, during Licensed Operator

Continuing Training, Cycle 3. Subsequently, the same weaknesses were observed during an

initial license examination in July 2007, and again during the subject NRC inspection in October

2007. The NRC determined that the weaknesses were not entered into the Palo Verde Nuclear

Generating Station's corrective action program until August 2007, and corrective actions to

address the weaknesses for on-watch senior operators were not implemented until October

2007. The NRC determined that corrective actions were implemented to correct the

weaknesses of those senior operators and senior operator candidates whose implementation of

Emergency Action Level 1-7 were specifically evaluated; however, actions to ensure the correct

implementation of Emergency Action Level 1-7 by all on-shift senior operators were not

performed in a timely manner when the weakness was identified (reference NRC Manual

Chapter 0609, Appendix B, Section 5.0).

Randall K. Edington -2-

This finding was assessed based on the best available information, including influential

assumptions, using the applicable significance determination process and was preliminarily

determined to be a White finding. The final resolution of this finding will convey the increment in

the importance to safety by assigning the corresponding color, i.e., (WHITE) a finding with some

increased importance to safety, which may require additional NRC inspection. The finding has

a low-to-moderate safety significance because the identified senior operator performance

weakness in implementing an emergency action level was associated with risk significant

planning standard 10 CFR 50.47(b)(4). Part 50.47(b)(4) is a risk significant planning standard

as described in Manual Chapter 0612, Appendix B, Section 2.0. The performance deficiency

constituted a planning standard functional failure because Palo Verde Nuclear Generating

Station failed to correct a performance deficiency associated with a risk significant planning

standard within a time appropriate to its significance.

The finding is also an apparent violation of NRC requirements 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, IV.F.2.g., and is being considered for escalated enforcement action in

accordance with the NRC Enforcement Policy. The current Enforcement Policy is available on

the NRCs Web site at www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

The apparent violation and underlying performance deficiency was discussed during a

conference call between Messrs. S. Bauer, Department Leader, Regulatory Affairs; E. O'Neil,

Department Leader, Emergency Preparedness; and R. Lantz, Chief, Operations Branch, NRC

Region IV, on January 9, 2008.

Before we make a final decision on this matter, we are providing you an opportunity, (1) to

present to the NRC at a Regulatory Conference your perspectives on the facts and assumptions

used by the NRC to arrive at the finding and its significance, or (2) submit your position on the

finding to the NRC in writing. If you request a Regulatory Conference, it should be held within

30 days of the receipt of this letter and we encourage you to submit supporting documentation

at least one week prior to the conference in an effort to make the conference more efficient and

effective. If a Regulatory Conference is held, it will be open for public observation. If you

decide to submit only a written response, such submittal should be sent to the NRC within

30 days of receiving this letter.

Please contact Mr. Ryan E. Lantz, Chief, Operations Branch, Division of Reactor Safety, at

(817) 860-8159, within 10 business days of the date of this letter to notify the NRC of your

intentions. If we have not heard from you within 10 days, we will continue with our significance

determination and enforcement decision, and you will be advised by separate correspondence

of the results of our deliberations on this matter.

Since the NRC has not made a final determination in this matter, no Notice of Violation is being

issued for this inspection finding at this time. In addition, please be advised that the number

and characterization of apparent violations described in the subject inspection report may

change as a result of further NRC review.

Randall K. Edington -3-

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS

is accessible from the NRC Web site (the Public Electronic Reading Room).

Sincerely,

/RA/

Roy J. Caniano, Director

Division of Reactor Safety

Dockets: 50-528; 50-529; 50-530

Licenses: NPF-41; NPF-51; NPF-74

cc:

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

Scott Bauer, Director

Regulatory Affairs

Palo Verde Nuclear Generating Station

Mail Station 7636

P.O. Box 52034

Phoenix, AZ 85072-2034

Randall K. Edington -4-

Mr. Dwight C. Mims

Vice President, Regulatory Affairs and

Performance Improvement

Palo Verde Nuclear Generating Station

Mail Station 7636

P.O. Box 52034

Phoenix, AZ 85072-2034

Jeffrey T. Weikert

Assistant General Counsel

El Paso Electric Company

Mail Location 167

123 W. Mills

El Paso, TX 79901

Eric J. Tharp

Director of Generation

Los Angeles Department of Water & Power

Southern California Public Power Authority

P.O. Box 51111, Room 1255

Los Angeles, CA 90051-5700

John Taylor

Public Service Company of New Mexico

2401 Aztec NE, MS Z110

Albuquerque, NM 87107-4224

Geoffrey M. Cook

Southern California Edison Company

5000 Pacific Coast Hwy, Bldg. D21

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

Randall K. Edington -5-

Matthew Benac

Assistant Vice President

Nuclear & Generation Services

El Paso Electric Company

340 East Palm Lane, Suite 310

Phoenix, AZ 85004

Chief, Radiological Emergency Preparedness Section

National Preparedness Directorate

Technological Hazards Division

Department of Homeland Security

1111 Broadway, Suite 1200

Oakland, CA 94607-4052

Randall K. Edington -6-

Electronic distribution by RIV:

Regional Administrator (EEC)

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 (CJP)

RITS Coordinator (MSH3)

M. Vasquez

V. Dricks

W. Maier

D. Starkey, OE

N. Hilton, OE

Mary Ann Ashley, NRR

R. Kahler, NSIR

K. Williams, NSIR

SUNSI Review Completed: ___Y___ADAMS: Yes No Initials: _REL_____

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

S:DRS\reports\PV white letter.doc

C:OB C:PBD NSIR ACES D:DRS

RELantz/lmb TPruett KWilliams MVasquez RJCaniano

/RA/ /RA/ /RA/ E /RA/ /RA/

1/15/08 1/17/08 1/28/08 1/25/08 1/29/08 / 2/1/08

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax