ML081020348

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EA-08-003, Meeting Summary for Palo Verde Nuclear Generating Station Public Meeting
ML081020348
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/10/2008
From: Ryan Lantz
Operations Branch IV
To: Edington R
Arizona Public Service Co
References
EA-08-003
Download: ML081020348 (53)
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Text

UNITED STATES NU CLEAR REGU LATOR Y C O M M I SSI O N R E GI ON I V 611 R YAN PLAZA D R I V E, SU I TE 400 AR LIN GTON , TEXAS 76011-4005 April 10, 2008 EA-08-003 Randall K. Edington, Executive Vice President, Nuclear and Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

MEETING

SUMMARY

FOR PALO VERDE NUCLEAR GENERATING STATION PUBLIC MEETING

Dear Mr. Edington:

On March 25, 2008, the NRC held a Regulatory Conference with Arizona Public Service Company at the Region IV offices in Arlington, Texas, to discuss the apparent violation identified in NRC inspection report 2007-012, at its Palo Verde Nuclear Generating Station, and in an NRC letter dated February 1, 2008. The apparent violation was a failure to implement corrective actions for a weakness in the performance of senior reactor operators that the licensee had identified in May 2007. This conference was held at the licensees request.

During this meeting, Palo Verde management discussed the apparent causes for the failure to promptly correct the identified performance weakness, and corrective actions to ensure the correction of future performance weaknesses, and discussed its evaluation of the significance of the apparent violation. The meeting attendance list and Palo Verdes presentation are enclosed.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be made 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 at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Randall K. Edington Should you have any questions concerning this matter, we will be pleased to discuss them with you.

Sincerely,

/RA/

Ryan E. Lantz, Chief Operations Branch Division of Reactor Safety Dockets: 50-528, 50-529, 50-530 Licenses: NPF-41, NPF-51, NPF-74

Enclosures:

1. Meeting Attendance List
2. Palo Verde Nuclear Generating Station Presentation cc w/o Enclosure 2:

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 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

Randall K. Edington Karen O' Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Chairperson, Regional Assistance Committee Region IX Federal Emergency Management Agency Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052

Randall K. Edington Electronic distribution by RIV:

Regional Administrator (EEC)

DRP Director (DDC)

DRS Director (RJC1)

DRS Deputy Director (TWP)

Senior Resident Inspector (GXW2)

Senior Resident Inspector (RIT)

Branch Chief, DRP/D (MCH2)

Senior Project Engineer, DRP/D (GEW)

Team Leader, DRP/TSS (CJP)

RITS Coordinator (MSH3)

DRS STA (DAP)

M. Vasquez (GMV)

C. Maier (MCM1)

K. Fuller (KSF)

R. Lantz (REL)

V. Dricks, PAO (VLD)

R. Kahler, NSIR/DRP/EP (REK)

J. Adams, OEDO RIV Coordinator (JTA)

ROPreports PV Site Secretary (PRC)

SISP Review Completed: _3/31/08_ ADAMS: U Yes G No Initials: PJE U Publicly Available G Non-Publicly Available G Sensitive U Non-Sensitive DOCUMENT NAME:Distribution for Reactor Escalated.wpd DRS/OB TL:ACES C:DRS/OB PElkmann KSFuller RLantz

/RA/ /RA/ /RA/

4/10/08 4/10/08 4/10/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE 1 MEETING ATTENDANCE LIST Nuclear Regulatory Commission E. Collins, Regional Administrator T. Pruett, Deputy Director, Division of Reactor Safety V. Watkins, Deputy Director (Acting), Division of Reactor Safety (NASA)

R. Lantz, Chief, Operations Branch, Division of Reactor Safety M. Hay, Chief, Branch D, Division of Reactor Projects K. Fuller, Regional Counsel; Director, Allegation Coordination and Enforcement Staff M. Vasquez, Senior Enforcement Specialist R. Kahler, Team Leader, NSIR/DRP/EP P. Elkmann, Senior Emergency Preparedness Inspector, Operations Branch, R. Treadway, Senior Resident Inspector Arizona Public Service Company R. Edington, Executive Vice President, Chief Nuclear Officer D. Mims, Vice President, Regulatory Affairs and Performance Improvement S. Bauer, Director, Regulatory Affairs J. Waid, Director, Training T. Radtke, General Manager, Emergency Services and Support P. Carpenter, Department Leader, Operations M. Ray, Department Leader Designate, Emergency Preparedness J. Wood, Department Leader, Operations Training R. Henry, Site Representative, Salt River Project Other Attendees R. Kidwell, Senior Nuclear Technologist, Regulatory Affairs, Comanche Peak Steam Electric Station J. Kinnel S. Oleo T. Young

ENCLOSURE 2 PALO VERDE NUCLEAR GENERATING STATION PRESENTATION

Emergency Action Level 1-7 Regulatory Conference

Randy Edington Executive Vice President and Chief Nuclear Officer

SAFELY and efficiently generate electricity for the long term Emergency Preparedness Improvements

  • Assessments / ImPACT
  • Root Cause Investigations
  • Organizational Changes
  • Significant Training Efforts
  • Procedures / EAL Improvements

Scott Bauer Director Regulatory Affairs

Apparent WHITE Finding

  • Performance Deficiency: Failure to Correct an RSPS Weakness in a Timely Manner

- Timeliness Well in Excess of Suggested Guidance

- Timeliness Inappropriate in View of the Significance of the Weakness

  • Inappropriate Because of the Inability to Properly Classify an Emergency Condition
  • Finding Preliminarily Determined to be of Low to Moderate Safety Significance

APS Perspective

  • Assumed Knowledge Deficiency Existed With Definition of Prolonged Release

- Incorrect Answer

- Insufficient Information

- Unrealistic Scenario

  • Corrective Action Program Not Effectively Used
  • Knowledge Deficiency Would Not Result in Misclassification of an Actual Event

FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET Highest valid CET temperature RCS leak > 44 gpm [1-6] RCS leak rate > available CTMT pressure 50 psig and Rapid unexplained CTMT temperature > 700ºF > 1200ºF [1-1] makeup capacity as indicated increasing [1-10] pressure decrease following

[1-1] by a loss of RCS subcooling initial increase [1-10]

(i.e., RCS at saturation conditions) [1-6]

RCS activity > 300 µCi/gm Dose CTMT pressure > 8.5 psig with CTMT pressure or sump level Equivalent I-131 [1-3] both CTMT Spray Systems not response not consistent with operating [1-10] LOCA conditions [1-10]

Time since shutdown=0.2 hrs: CTMT radiation monitor Failure of both CTMT isolation CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, or valves in any one line to close RU-148 > 2.1E+05 mrem/hr, or RU-149 > 7.8E+06 mrem/hr and pathway to the RU-149 > 2.4E+05 mrem/hr, [1-11] environment exists OR [1-13]

Time since shutdown >.2 hrs:

Refer to Appendix P [1-4]

RU-148 / RU-149 curves [1-4]

Time since shutdown=0.2 hrs: SGTR > 44 gpm [1-7] SGTR > 132 gpm with a Release of contam. Secondary

& total RCS leakage < 1 gpm: prolonged release of side to atmosphere (i.e., S/G RCS radiation monitor RU-150 contaminated secondary safety or ADV) with S/G P/S or RU-151 > 2.2E+04 mrem/hr coolant occurring from the leakage > Tech Spec allowable OR ruptured S/G to the S/G P/S leakage [1-14]

Time since shutdown >.2 hrs environment (see limitations in

& total RCS leakage < 1 gpm: Section 1) [1-7]

Refer to Appendix P [1-4]

RU-150 / RU-151curve [1-4]

Valid RVLMS level LOAF such that minimum H2 concentration > 3.5% by currently or previously acceptable feedwater flow volume [1-10]

< 21% plenum [1-2] cannot be maintained [1-8]

CET > 1200ºF and not restored w/i 15 min. or CET > 700ºF with RVLMS < 21% plenum and not restored within 15 min. [1-12]

Any condition that, in the opinion of the SM/EC, indicates loss or Any condition that, in the opinion of the SM/EC, indicates loss Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of Fuel Clad Barrier [1-5] or potential loss of RCS Barrier [1-9] potential loss of CTMT Barrier [1-15]

APPLY THE CRITERIA ABOVE TO THE CONDITIONS BELOW UNUSUAL EVENT (NUE) ALERT SITE AREA EMERGENCY (SAE) GENERAL EMERGENCY (GE)

Any loss OR any potential loss of Containment Any loss OR any potential loss of either Fuel Loss of both Fuel Clad and RCS Loss of any two barriers Clad or RCS OR AND Potential loss of both Fuel Clad and RCS Potential loss of a third barrier OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier

FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS SGTR > 44 gpm [1-7]

RCS leak > 44 gpm [1-6]

SGTR SGTR > 132> gpm132 with gpma with SGTR > 44 gpm Highest valid CET temperature > 700ºF

[1-1]

Highest valid CET temperature

> 1200ºF [1-1]

RCS leak rate > available makeup capacity as indicated CTMT pressure 50 psig and prolonged increasing release

[1-10] of a prolonged release Rapid unexplained CTMT pressure decrease following by a loss of RCS subcoolingcontaminated secondary initial increase [1-10]

(i.e., RCS at saturation of contaminated coolant occurring from the

[1-7] RCS activity > 300 µCi/gm Dose conditions) [1-6]

secondary ruptured S/G to thecoolant CTMT pressure > 8.5 psig with CTMT pressure or sump level Equivalent I-131 [1-3] environment occurring both CTMT Spray(see limitations from Systems the in not consistent with not response

[1-7]

1) [1-10]

operating Section LOCA conditions [1-10]

Time since shutdown=0.2 hrs: ruptured SG to the CTMT radiation monitor Failure of both CTMT isolation CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or environment RU-149 > 7.8E+06 mrem/hr(see RU-148 > 6.8E+06 mrem/hr, or valves in any one line to close and pathway to the RU-149 > 2.4E+05 mrem/hr, OR Limitations

[1-11]

in environment

[1-13]

exists Time since shutdown >.2 hrs:

Refer to Appendix P [1-4]

Section 1) [1-7]

RU-148 / RU-149 curves [1-4]

Time since shutdown=0.2 hrs: SGTR > 44 gpm [1-7] SGTR > 132 gpm with a Release of contam. Secondary

& total RCS leakage < 1 gpm: prolonged release of side to atmosphere (i.e., S/G RCS radiation monitor RU-150 contaminated secondary safety or ADV) with S/G P/S or RU-151 > 2.2E+04 mrem/hr coolant occurring from the leakage > Tech Spec allowable OR ruptured S/G to the S/G P/S leakage [1-14]

Time since shutdown >.2 hrs environment (see limitations in

& total RCS leakage < 1 gpm: Section 1) [1-7]

Refer to Appendix P [1-4]

RU-150 / RU-151curve [1-4]

Valid RVLMS level LOAF such that minimum H2 concentration > 3.5% by currently or previously acceptable feedwater flow volume [1-10]

< 21% plenum [1-2] cannot be maintained [1-8]

CET > 1200ºF and not restored w/i 15 min. or CET > 700ºF with RVLMS < 21% plenum and not restored within 15 min. [1-12]

Any condition that, in the opinion of the SM/EC, indicates loss or Any condition that, in the opinion of the SM/EC, indicates loss Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of Fuel Clad Barrier [1-5] or potential loss of RCS Barrier [1-9] potential loss of CTMT Barrier [1-15]

APPLY THE CRITERIA ABOVE TO THE CONDITIONS BELOW UNUSUAL EVENT (NUE) ALERT SITE AREA EMERGENCY (SAE) GENERAL EMERGENCY (GE)

Any loss OR any potential loss of Containment Any loss OR any potential loss of either Fuel Loss of both Fuel Clad and RCS Loss of any two barriers Clad or RCS OR AND Potential loss of both Fuel Clad and RCS Potential loss of a third barrier OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier

Prolonged Release

  • EPIP 99, Appendix A, Section 1, Precautions and Limitations Defines Prolonged Release of Contaminated Secondary Coolant as Encompassing:

- A Main Steam Line Break

- A Feedwater Line Break

- A Stuck-open SG Safety

- A Stuck-open Atmospheric Dump Valve

- A Plant Cooldown (i.e., to Mode 5) While Steaming the Affected SG to Atmosphere

  • Cooling SG to 540 Degrees F is Not a Prolonged Release
  • Potential Inability to Properly Classify is Specific to the Cooldown to Mode 5 Attribute of EAL 1-7

Timeline

  • JPM Administered 30 Times from 2005 to 2007
  • 21 Emergency Coordinators (EC) Classified GE (Declaring EAL 1-7 Loss Versus Potential Loss)
  • 8 ECs Were Remediated to Intended GE JPM Answer
  • May 2, 2007 1 EC Challenged JPM Answer and JPM Error Was Recognized But No Corrective Action Initiated
  • May 3, 2007 JPM Selected for NRC Initial Exam
  • JPM Validated as GE by Exam Preparers

Timeline

  • July 27, 2007 JPM Administered in July NRC Exam and Answer Challenged by License Candidate
  • July 30, 2007 PVAR Written
  • September 19, 2007 JPM Corrected
  • October 9, 2007 Corrected JPM Administered to EC (Not Yet Retrained) and Classified as GE
  • October 25, 2007 Remediation Training Completed for ECs (Within 90 Days of PVAR)

APS Perspective

  • Actions to Remediate the Identified Deficiency Took 175 Days From Identification
  • APS Failed to Enter the JPM Error Into the Corrective Action Program Upon Initial Identification on May 2, 2007

- Error Propagated Into NRC Initial Exam

- Recurred During 95003 Inspection

  • APS Agrees This Was a Performance Deficiency

Significance

  • Knowledge Deficiency Would Not Result in the Inability to Properly Classify an Emergency Condition

- EAL 1-7 and EAL Scheme Not Deficient

- JPM Error Reinforced a Misapplication of the EAL in the JPM Setting

- Misapplication of EAL 1-7 in the JPM Setting Would Not Result in the Inability to Classify an Actual Emergency Condition

  • Performance Deficiency is of Very Low Safety Significance

APS Perspective

  • Event Classification Training Has Multiple Levels:

- Classroom Training and Written Exams on EAL Tables

- Emergency Plan JPMs are a Tool for Testing Individual Knowledge of the EAL Tables

- Simulator-evaluated Scenarios Test the Ability of Operations Teams to Classify Events

- Full-scale Drills / Exercises Test the Ability of ERO Teams to Classify Events

APS Perspective

  • Failure of This JPM Would Not Lead to Misclassification in an Actual Event

- JPM Provides a Limited Set of Information

  • A Very Small Subset of Available Plant Indications
  • A Snapshot in Time of an Event
  • Examinee is Given up to 15 Minutes to Evaluate the Information Provided and Make a Classification
  • Selected Cues Trigger EAL Decisions

- JPM Did Not Provide the Sequence of the Event

  • Operator Actions That Had Been Taken
  • How the Plant Got to the Current Conditions
  • Each Procedure Followed and Where the CRS is in Those Procedures
  • Classifications Would Occur in Stages, Not All at One Time

APS Perspective

- An SGTR>200 gpm Has Occurred

- Reactor Has Been Tripped

- On the Reactor Trip, a Loss of Power to the Grid Occurred

- A Loss of Both HPSI Pumps Occurred

- The CRS Entered the Functional Recovery Procedure

- Power Restored to PBA-S03 Using the A EDG and the A HPSI Pump Has Been Started

- RVLMS Indicated <21% in the Outlet Plenum 10 Minutes Ago But Is Now >21%

- Secondary Plant Stabilized Using ADVs and A AFW

APS Perspective

- An SGTR>200 gpm Occurred (EAL 1-7 PL or L)

- Reactor Has Been Tripped

- On the Reactor Trip, a Loss of Power to the Grid Occurred

- A Loss of Both HPSI Pumps Occurred

- The CRS Entered the Functional Recovery Procedure

- Power Restored to PBA-S03 Using A EDG and the A HPSI Pump Has Been Started

- RVLMS Indicated <21% in the Outlet Plenum 10 Minutes Ago But Is Now >21% (EAL 1-2 PL)

- Secondary Plant Stabilized Using ADVs and A AFW (EAL 1-14 L and EAL 1-7 PL)

Event Timeline JPM Scenario JPM asks for classification for all conditions at this point in time TSC & EOF Activated Isolate GE EAL 1-7 L, faulted SG 1-14L, 1-2 PL R>200 gpm, RVLMS < 21%

rip & LOOP ADVs.

30 min Indefinite 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (worst case)

Event Timeline JPM Scenario JPM asks for classification for all conditions at this point in time TSC & EOF Activated EAL 1-7 PL EAL 1-14L SAE EAL 1-7 PL, Isolate faulted SG 1-14L and 1-2 PL R>200 gpm, RVLMS < 21%

rip & LOOP ADVs.

30 min Indefinite 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (worst case)

Event Timeline Simulator Results for JPM Scenario Initial Conditions TSC & EOF Activated EAL 1-7 PL &

1-14L SAE EAL 1-14L, 1-6 L, 1-7 PL RCS Cooled Down R>200 gpm, RCS Subcooling Isolate faulted Event Termination rip & LOOP lost SG ADVs.

30 min Multiple Hours 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (worst case)

FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET Highest valid CET temperature RCS leak > 44 gpm [1-6] RCS leak rate > available CTMT pressure 50 psig and Rapid unexplained CTMT temperature > 700ºF > 1200ºF [1-1] makeup capacity as indicated increasing [1-10] pressure decrease following

[1-1] by a loss of RCS subcooling initial increase [1-10]

(i.e., RCS at saturation conditions) [1-6]

RCS activity > 300 µCi/gm Dose CTMT pressure > 8.5 psig with CTMT pressure or sump level Equivalent I-131 [1-3] both CTMT Spray Systems not response not consistent with operating [1-10] LOCA conditions [1-10]

Time since shutdown=0.2 hrs: CTMT radiation monitor Failure of both CTMT isolation CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, or valves in any one line to close RU-148 > 2.1E+05 mrem/hr, or RU-149 > 7.8E+06 mrem/hr and pathway to the RU-149 > 2.4E+05 mrem/hr, [1-11] environment exists OR [1-13]

Time since shutdown >.2 hrs:

Refer to Appendix P [1-4]

RU-148 / RU-149 curves [1-4]

Time since shutdown=0.2 hrs: SGTR > 44 gpm [1-7] SGTR > 132 gpm with a Release of contam. Secondary

& total RCS leakage < 1 gpm: prolonged release of side to atmosphere (i.e., S/G RCS radiation monitor RU-150 contaminated secondary safety or ADV) with S/G P/S or RU-151 > 2.2E+04 mrem/hr coolant occurring from the leakage > Tech Spec allowable OR ruptured S/G to the S/G P/S leakage [1-14]

Time since shutdown >.2 hrs environment (see limitations in

& total RCS leakage < 1 gpm: Section 1) [1-7]

Refer to Appendix P [1-4]

RU-150 / RU-151curve [1-4]

Valid RVLMS level LOAF such that minimum H2 concentration > 3.5% by currently or previously acceptable feedwater flow volume [1-10]

< 21% plenum [1-2] cannot be maintained [1-8]

CET > 1200ºF and not restored w/i 15 min. or CET > 700ºF with RVLMS < 21% plenum and not restored within 15 min. [1-12]

Any condition that, in the opinion of the SM/EC, indicates loss or Any condition that, in the opinion of the SM/EC, indicates loss Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of Fuel Clad Barrier [1-5] or potential loss of RCS Barrier [1-9] potential loss of CTMT Barrier [1-15]

APPLY THE CRITERIA ABOVE TO THE CONDITIONS BELOW UNUSUAL EVENT (NUE) ALERT SITE AREA EMERGENCY (SAE) GENERAL EMERGENCY (GE)

Any loss OR any potential loss of Containment Any loss OR any potential loss of either Fuel Loss of both Fuel Clad and RCS Loss of any two barriers Clad or RCS OR AND Potential loss of both Fuel Clad and RCS Potential loss of a third barrier OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier

FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET Highest valid CET temperature RCS leak > 44 gpm [1-6] RCS leak rate > available CTMT pressure 50 psig and Rapid unexplained CTMT temperature > 700ºF > 1200ºF [1-1] makeup capacity as indicated increasing [1-10] pressure decrease following

[1-1] by a loss of RCS subcooling initial increase [1-10]

(i.e., RCS at saturation conditions) [1-6]

RCS activity > 300 µCi/gm Dose CTMT pressure > 8.5 psig with CTMT pressure or sump level Equivalent I-131 [1-3] both CTMT Spray Systems not response not consistent with operating [1-10] LOCA conditions [1-10]

Time since shutdown=0.2 hrs: CTMT radiation monitor Failure of both CTMT isolation CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, or valves in any one line to close RU-148 > 2.1E+05 mrem/hr, or RU-149 > 7.8E+06 mrem/hr and pathway to the RU-149 > 2.4E+05 mrem/hr, [1-11] environment exists OR [1-13]

Time since shutdown >.2 hrs:

Refer to Appendix P [1-4]

RU-148 / RU-149 curves [1-4]

Time since shutdown=0.2 hrs: SGTR > 44 gpm [1-7] SGTR > 132 gpm with a Release of contam. Secondary

& total RCS leakage < 1 gpm: prolonged release of side to atmosphere (i.e., S/G RCS radiation monitor RU-150 contaminated secondary safety or ADV) with S/G P/S or RU-151 > 2.2E+04 mrem/hr coolant occurring from the leakage > Tech Spec allowable OR ruptured S/G to the S/G P/S leakage [1-14]

Time since shutdown >.2 hrs environment (see limitations in

& total RCS leakage < 1 gpm: Section 1) [1-7]

Refer to Appendix P [1-4]

RU-150 / RU-151curve [1-4]

Valid RVLMS level LOAF such that minimum H2 concentration > 3.5% by currently or previously acceptable feedwater flow volume [1-10]

< 21% plenum [1-2] cannot be maintained [1-8]

CET > 1200ºF and not restored w/i 15 min. or CET > 700ºF with RVLMS < 21% plenum and not restored within 15 min. [1-12]

Any condition that, in the opinion of the SM/EC, indicates loss or Any condition that, in the opinion of the SM/EC, indicates loss Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of Fuel Clad Barrier [1-5] or potential loss of RCS Barrier [1-9] potential loss of CTMT Barrier [1-15]

APPLY THE CRITERIA ABOVE TO THE CONDITIONS BELOW UNUSUAL EVENT (NUE) ALERT SITE AREA EMERGENCY (SAE) GENERAL EMERGENCY (GE)

Any loss OR any potential loss of Containment Any loss OR any potential loss of either Fuel Loss of both Fuel Clad and RCS Loss of any two barriers Clad or RCS OR AND Potential loss of both Fuel Clad and RCS Potential loss of a third barrier OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier

FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET Highest valid CET temperature RCS leak > 44 gpm [1-6] RCS leak rate > available CTMT pressure 50 psig and Rapid unexplained CTMT temperature > 700ºF > 1200ºF [1-1] makeup capacity as indicated increasing [1-10] pressure decrease following

[1-1] by a loss of RCS subcooling initial increase [1-10]

(i.e., RCS at saturation conditions) [1-6]

RCS activity > 300 µCi/gm Dose CTMT pressure > 8.5 psig with CTMT pressure or sump level Equivalent I-131 [1-3] both CTMT Spray Systems not response not consistent with operating [1-10] LOCA conditions [1-10]

Time since shutdown=0.2 hrs: CTMT radiation monitor Failure of both CTMT isolation CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, or valves in any one line to close RU-148 > 2.1E+05 mrem/hr, or RU-149 > 7.8E+06 mrem/hr and pathway to the RU-149 > 2.4E+05 mrem/hr, [1-11] environment exists OR [1-13]

Time since shutdown >.2 hrs:

Refer to Appendix P [1-4]

RU-148 / RU-149 curves [1-4]

Time since shutdown=0.2 hrs: SGTR > 44 gpm [1-7] SGTR > 132 gpm with a Release of contam. Secondary

& total RCS leakage < 1 gpm: prolonged release of side to atmosphere (i.e., S/G RCS radiation monitor RU-150 contaminated secondary safety or ADV) with S/G P/S or RU-151 > 2.2E+04 mrem/hr coolant occurring from the leakage > Tech Spec allowable OR ruptured S/G to the S/G P/S leakage [1-14]

Time since shutdown >.2 hrs environment (see limitations in

& total RCS leakage < 1 gpm: Section 1) [1-7]

Refer to Appendix P [1-4]

RU-150 / RU-151curve [1-4]

Valid RVLMS level LOAF such that minimum H2 concentration > 3.5% by currently or previously acceptable feedwater flow volume [1-10]

< 21% plenum [1-2] cannot be maintained [1-8]

CET > 1200ºF and not restored w/i 15 min. or CET > 700ºF with RVLMS < 21% plenum and not restored within 15 min. [1-12]

Any condition that, in the opinion of the SM/EC, indicates loss or Any condition that, in the opinion of the SM/EC, indicates loss Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of Fuel Clad Barrier [1-5] or potential loss of RCS Barrier [1-9] potential loss of CTMT Barrier [1-15]

APPLY THE CRITERIA ABOVE TO THE CONDITIONS BELOW UNUSUAL EVENT (NUE) ALERT SITE AREA EMERGENCY (SAE) GENERAL EMERGENCY (GE)

Any loss OR any potential loss of Containment Any loss OR any potential loss of either Fuel Loss of both Fuel Clad and RCS Loss of any two barriers Clad or RCS OR AND Potential loss of both Fuel Clad and RCS Potential loss of a third barrier OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier

Conditions for Misclassification Unlikely

  • Given the Assumed Knowledge Deficiency, the Following Must All Occur for There to be a Misclassification

- SGTR >132 gpm

- Must be a Loss of Condenser Forcing ADVs to be Used (i.e., Containment Loss)

- Fuel Clad Barrier Potential Loss

- These Conditions Must All Exist Prior to Isolation of the Affected SG

Summary

  • JPM Does Not Reflect the Conditions of an Actual Event

- Timing/Sequence Not Provided

  • Faulted SG Would Be Isolated, Terminating Release

- Integrated Control Room Information Not Available

- SGTR Events Generally Not Associated With a Potential Loss of Fuel Clad

  • Assumed Knowledge Deficiency Created by the JPM is Inconsequential to Classification of SGTRs Not Leading to Potential Loss of Fuel Clad
  • JPM Does Not Exercise Classification As It Would Be Done During an Actual Event

- Classification Would Occur in Stages As the Event Progresses

- Classifications Would Take Into Account Actual Changes in Plant Conditions

- Multiple Personnel Would Be Involved Depending on Timing/Sequence

- Integration/Multiple Information Sources Available

Additional Information

  • During an Event, a Peer Check is Directed and a Final Review is Performed as Time Permits

- EPIP-01 and -03 Used for Classification

- Procedures Direct the EC to Have Another EC-qualified Person Independently Verify the Classification (Normally the STA)

- If Technical Support Center and Emergency Operations Facility are Manned, Additional EC-qualified People Would Be Checking Classification

  • These Independent Checks Not Available During JPM
  • STAs Received Specific Prolonged Release Training Independent of JPM Error Corrective Actions

Conclusion

  • APS Agrees This Was a Performance Deficiency

- CAP Not Initially Used Which Propagated Error and Delayed Corrective Actions

  • Deficiency Did Not Result in the Inability to Properly Classify an Emergency Condition in an Actual Event

Terry Radtke General Manager Emergency Services and Support

Leadership Training Accountability Model

Assessment

  • Nuclear Assurance Audit (Feb) /

Evaluated Exercise (March)

- Developed EP Improvement Plan

  • Management Review / ImPACT Review (June)

- Independent Assessment

- ImPACT Assessment Activities

- Revision of the EP Improvement Plan

Assessment

  • ImPACT Root Cause Investigation (August)

- Business Plan Building Block Status

- Site Integrated Business Plan (SIBP)

- Site Integrated Improvement Plan (SIIP)

  • EAL 1-7 Root Cause Investigation (October)

- EC Advisors Established

- Accelerated Knowledge / Training Improvement Actions

- EAL Reviews

Benchmarking

  • Site visits in 2007 / 2008 Pilgrim River Bend Waterford Callaway FitzPatrick Turkey Point Nine Mile Point SONGS St. Lucie
  • Industry and Peer Expert Assistance
  • Best Practice Improvement Plans
  • Performance Metrics

Ownership and Accountability EP ADDED FOR INCREASED EMPHASIS Senior Management Reinforced EP Importance and Priority

Ownership and Accountability

  • Policy Guide 1503 EP Expectations
  • Leader Briefings on ERO Expectations at Alignment Meetings
  • ERO Duty Team Weekly Meetings and Associated Metric
  • EC and EOD Alignment Meetings
  • Established Cross-discipline EP Steering Committee

- Extensive Revision to Emergency Plan Implementing Procedures (EPIPs)

Ownership and Accountability A

TRNG L

I G

N RP EP OPS M

E N

ERO T

Knowledge and Training

  • Increased Drills and Exercises
  • Implementing Systematic Approach to Training for ERO Positions
  • Emergency Services and Support General Manager Added to Site Training Oversight Committee
  • EC EAL Knowledge Improvement Plan

Resources

  • Key Stakeholders Embedded into EP

- RP / Operations

  • Organization Realignment

- EP Leader Direct Report to General Manager

- New EP Director-level Position

- EP Communications Equipment Staff

  • Temporary Assignments

Facilities and Equipment

  • Communication

- Audio / Video

- ERO Pagers

- NAN / PBX Phones

  • Software

- RADDOSE

- Web EOC (Implementing)

Corrective Actions

  • Computer-based Training and Face-to-Face Training Briefings for EAL 1-7 Knowledge Between Training Cycles
  • Errors in Exam Materials (e.g., Exam Questions, JPMs) Entered Into CAP
  • Simulator, Exam and JPM Failures Entered Into CAP
  • Trending of Operator Training Weaknesses
  • EAL 1-7 JPM Corrected and Initiating Cues Revised

Corrective Actions

  • Operator Training EAL JPMs and Training Simulator Exercises Receive Emergency Planning Review and Concurrence
  • EAL Improvements

Conclusion

  • Broad-based Improvement Plan
  • Specific EAL Improvement Actions
  • Increased Ownership and Accountability
  • Driving Knowledge and Standards
  • Improved Alignment of ERO Stakeholders

Dwight Mims Vice President Regulatory Affairs and Plant Improvement

Closing

  • APS Failed to Enter the Identified Deficiency in the Corrective Action Program
  • Corrective Actions Were, Therefore, Delayed and the Error Recurred
  • After Evaluation, APS Concluded There Was Not an Inability to Properly Classify an Actual Event
  • The Deficiency Should Be Very Low Safety Significance

Closing

  • SDP application

- Current: Loss of b(14) PS Function for Failing to Correct a b(4) RSPS Weakness

- Alternative: Same as Above With Timeliness Determined Not to Be Inappropriate in View of Final Evaluation of Significance of Time to Correct the Weakness

- Could Also Be Addressed as a Deficiency in Training of Emergency Response Personnel Under PS b(15)

Closing

  • APS Will Continue to Implement the Planned Actions to Further Improve Performance
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