ML17313A536
| ML17313A536 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/12/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17313A537 | List: |
| References | |
| 50-528-98-99, 50-529-98-99, 50-530-98-99, NUDOCS 9808180192 | |
| Download: ML17313A536 (18) | |
See also: IR 05000528/1998099
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9808180192
DOC.DATE: 98/08/12
NOTARIZED: NO
DOCKET
CIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi
05000528
STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi
05000529
STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi
05000530
AUTH.NAME
AUTHOR AFFILIATION
MERSCHOFF, E.W.
Region
4 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
LEVINE,J.M.
Arizona Public Service
Co.
(formerly Arizona Nuclear Power
SUBJECT:
Responds
to comments provided by APS on 980422,re
SALP Repts
50-528/98-99,5'0-529/98-99
S 50-530/98-99
on 980408.SALP
Board concluded that no change to Operations rating was
appropriate. Revised
page
5 of SALP rept encl.
DISTRIBUTION CODE:
IE40D
COPIES
RECEXVED:LTR
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SIZE:
TITLE: Systematic
Assessment
of Licensee
Performance
(S LP) Report
NOTES:STANDARDIZED PLANT
Standardized plant.
Standardized plant.
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NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE
WASTETH
TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DZSTRIBUTZON LISI
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTRC
DESK
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ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZADRIVE'. SU!TE 400
ARLINGToN,TExAs 760I1-6064
August 12,
1998
James M. Levine, Senior Vice
President, Nuclear
Arizona Public Service Company
P.O. Box 53999
Phoenix, Arizona 85072-3999
SUBJECT:
RESPONSE TO COMMENTS RELATED TO NRC'S SYSTEMATIC
ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
REPORT 50-528/98-99; 50-529/98-99; 50-530/98-99
Dear Mr. Levine:
On April22, 1998, Arizona Public Service Company (APS) provided docketed comments in
response
to SALP Report 50-528/98-99; 50-529/98-99; 50-530/98-99, dated April 8, 1998, for
the Palo Verde Nuclear Generating Station (PVNGS),'and requested that the NRC reconsider
the Category 2 rating assigned to the Operations functional area.
This letter was supplemented
by a second letter, dated May 8, 1998, that provided comments in response
to the NRC's
presentation at the April28, 1998, SALP public meeting.
In these letters, APS stated that
performance in the Operations area during the past SALP period was consistently and properly
focused on safety and compliance with NRC regulations and that they had continued to
demonstrate
a superior level of performance.
APS based this assertion on the following major
principles:
Plant performance [as indicated by key operating parameters] had improved significantly
[and was] a direct result of improved Operations performance;
+
Operations had demonstrated
control of site activities to maintain a superior level of
safety performance; and,
Although there were identified weaknesses,
when viewed in a broader context,
interdepartmental communications involving Operations had been and continued to be
effective in controlling plant operations.
+
The safety significance of the issues highlighted in the SALP report was minimal and,
when taken in context with the numerous activities which APS performed well, did.not
justify a reduction in the functional area SALP assessment
from Category
1 to
Category 2.
Any consideration of the events surrounding the March 1993 missed operator
surveillance test, including whether APS had an opportunity to identify the 1993 matter
in May 1996, was inappropriate to consider within this SALP evaluation because
they
were historical (in that the actual event occurred 5 years prior) and was predecisional in
nature (with respect to the completion of investigatory and enforcement actions).
'II808i80i'7I2 'II808i2
ADGCK 05000528
8
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I
I
Arizona Public Service Company
-2-
After reviewing all aspects of performance, the SALP Board concluded that no change to the
Operations rating was appropriate.
Overall safety performance was determined to be very
good, but not superior, although several areas of strength were noted that did reflect superior
performance.
These areas included the strong operational performance achieved by each unit
during the assessment
period, the improvements in the conduct of refueling operations, and the
demonstrated
ability of management
to effectively deal with priority issues.
To properly address all of the APS'ssertions,
it was necessary to evaluate and reach
conclusions on those items which were process concerns (whether or not to consider items
which occurred outside of the assessment
period; how to evaluate information for which final
enforcement decisions have not been reached; and how to factor the "span of vulnerability"
associated
with multi-unit operations) prior to reconsidering the technical issues which were
brought forward.
In this regard, the Region consulted with the Office of Nuclear Reactor
Regulation (NRR) to determine whether consideration of the 1993 surveillance issue, the
subsequent
1996 opportunity for discovering it, and the associated
enforcement being
considered by the NRC was appropriate.
Second, the SALP Board was provided with specific
guidance concerning how to consider and place into proper context the large span of
vulnerability associated
with Palo Verde's three-unit operations.
In response to APS'oncerns about the historical and predecisional implications of considering
certain information, the requirements and guidance provided in NRC Management Directive
8.6, "Systematic Assessment
of Licensee Performance (SALP)," were reviewed with NRR. The
guidance for making SALP assessments
is explicit in that it states that all relevant information,
even that which occurs outside of the assessment
period, should be considered by the SALP
Board.'he agency cannot ignore information of which it has knowledge just because
enforcement sanctions may not have been fullyconsidered; instead, it is appropriate to place
the performance implications of such information into proper perspective.
Thus, it was
appropriate to consider how the 1993 surveillance event reflects on current performance at Palo
Verde.
In response
to your concerns about the span of vulnerability to which Palo Verde is subjected
since it is "the nation's largest nuclear generating station," it is acknowledged that, depending
on the nature of and circumstances associated with certain events and issues, there may be
differences in how they should be assessed.
However, it is not appropriate to believe that all
issues should be considered simply on a pro rata basis.
In fact, agency guidance is explicit in
that it requires a knowledgeable balancing of issues in a functional area.
It precludes the
application of statistical balancing of data.'here
are performance deficiencies, such as
radiological exposure and individual contamination events, which may be appropriate for
'RC Management Directive 8.6 states that the SALP Board should "place in perspective any significant
events or findings that took place outside the assessment
period that bear on the evaluations in the report."
NRC Management Directive 8.6 states that the SALP Board should focus on "knowledgeably balancing
the issues in a functional area and their safety significance. Statistical or numerical balancing of data is
inappropriate."
I
't
Arizona Public Service Company
-3-
quantitative comparison.
In contrast, however, events such as those which reflect failures or
breakdowns in licensee process barriers are not appropriate for normalization.
After clarifying these policy questions, the SALP Board reconvened to review the specific issues
noted in APS'pril 22 and May 8 letters, the information provided at the April28, 1998, SALP
public meeting, the enforcement and investigation information relative to the March 1993
.
missed surveillance issue (including APS'pril 22, 1998, letter to P. V. Joukoff, NRC Office of
Investigations), and all other relevant assessment
data.
This review addressed
all of the issues
brought forward by APS, including the relevancy and significance of the communications
weaknesses
identified in the SALP report. Of particular note, however,'as
the fact that the
performance implications associated
with the 1993 missed operator surveillance and the
subsequent
(1996) opportunity for APS to identify this issue were much better known when the
Board reconvened; this allowed for a more complete and, therefore, better assessment
of the
performance implications of this matter.
0
The Board also reviewed the entire SALP report to ensure that the characterization of findings
in each of the functional area discussions was factual and appropriate.
Altogether, the Board
had ample information to review its previous assessment
decision and determine whether an
appropriate assessment
had been made.
The Board concluded that performance shortcomings which were at least partly caused by
breakdowns in interdepartmental communications did occur. APS acknowledged that these
events occurred in their April22 and May 8 letters; however, they were characterized as not
meeting APS'erformance expectations and as having "minimal safety significance." On this
point, the Board disagrees with APS. The actual safety consequences
of the individual events
did not evolve to a point where plant safety was jeopardized; however, the communication
breakdowns were significant because they indicated weaknesses
which, under different
circumstances
could have led to significant operational events.
The Board determined that
these performance discrepancies were significant enough that they should not be numerically
balanced to reflect three unit operations.
Additionally, these events occurred throughout the
SALP period, reflecting a performance concern that was not dealt with in a timely and
comprehensive
manner.
Also of note are the recent inspection findings involving the
misaligned high pressure safety injection (HPSI) discharge check valves. While this
enforcement action is ongoing, the basic circumstances
have been determined and have
revealed several opportunities during this SALP cycle for APS to have detected the problem
and prevented its recurrence.
In the aggregate, these events are not reflective of superior
performance and constitute a decline in overall performance.
As was discussed at the SALP public meeting but not in the SALP report, the NRC was
concerned by the performance insights obtained from the 1993 missed operator surveillance,
especially those which reflected on current performance.
The ongoing failure of the operators
to bring the issue to management
attention raised questions about the integrity of individuals in
p
II
ositions of authority and responsibility within the Operations organization.
The lack of followup
on this issue by the employee concerns program in late 1996 also raised questions about t
ut the
aggressiveness
and breadth of the APS corrective action program.
While the event itself did
not occur within this SALP period, the performance attributes which the Board considered in its
assessment
did occur within this assessment
period, and these attributes were not indicative of
.
Arizona Public Service Company
-4-
superior performance.
The transmittal letter has been revised to reflect these concerns and is
provided as part of Enclosure
1.
I believe that this letter now articulates the NRC's view of the relationship between the issues of
operator performance, corrective actions, licensee self-assessment,
and the SALP assessment.
With respect to APS'ssertion that the Palo Verde Plant Performance Reviews (PPR) did not
communicate any performance decline and, in fact, indicated continuing superior operational
performance, it must be noted that the operator integrity issue and the sulfuric acid spill event
evolved during the last 6 months of the SALP period and were not addressed
by a PPR.
Given
the emphasis that is placed on performance during the final 6 months of a SALP period, no
disagreements
between the PPR and SALP results were identified.
Finally, as mentioned previously, the Board also reviewed the other functional area
assessments
in the SALP report to assure issues were clearly and properly communicated.
One item was identified in the Plant Support functional area where clarification was appropriate.
Enclosure
1 to this letter also provides a revised page 5 of the SALP report (in addition to the
previously mentioned revised transmittal letter) to provide this clarification. The replacement
language is noted by a side-bar.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure willbe placed in the NRC Public Document Room.
Should you have any questions or comments,
I would be pleased to discuss them with you.
Sincerely,
Ellis W. Mersch
Regional Admi istrator
Docket Nos.: 50-528; 50-529; 50-530
License Nos.: NPF-41; NPF-51; NPF-74
Enclosure:
Replacement Pages to NRC SALP Report
50-528/98-99; 50-529/98-99; 50-530/98-99
cc w/enclosure:
Mr. Steve Olea
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, Arizona 85007
l,
t
I
t
Arizona Public Service Company
Douglas K. Porter, Senior Counsel
Southern California Edison Company
Law Department, Generation Resources
P.O. Box 800
Rosemead,
California 91770
Chairman
Maricopa County Board of Supervisors
301 W. Jefferson, 10th Floor
Phoenix, Arizona 85003
Aubrey V. Godwin, Director
Arizona Radiation Regulatory Agency
4814 South 40 Street
Phoenix, Arizona 85040
Angela K. Krainik, Manager
Nuclear Licensing
Arizona Public Service Company
P.O. Box 52034
Phoenix, Arizona 85072-2034
John C. Horne, Vice President
Power Supply
El Paso Electric Company
2025 N. Third Street, Suite 220
Phoenix, Arizona 85004
Terry Bassham,
Esq.
General Counsel
El Paso Electric Company
123 W. Mills
El Paso, Texas
79901
Mr. Robert Burt
Los Angeles Department of Water 8 Power
Southern California Public Power Authority
111 North Hope Street, Room 1255-B
Los Angeles, California 90051
Mr. David Summers
Public Service Company of New Mexico
Albuquerque, New Mexico 87102
Arizona Public Service Company
Mr. Brian Katz
= Southern California Edison Company
14300 Mesa Road, Drop D41-SONGS
San Clemente, California 92672
Mr. Robert Henry
Salt River Project
6504 East Thomas Road
Scottsdale, Arizona 85251
l
I
Arizona Public Service Company
-7-
AUG
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E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
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C. Gordon
Records Center, INPO
Deputy Regional Administrator
SRIs at all RIV sites
C. A. Hackney
B. Murray, DRS/PSB
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Regional Administrator
DRP Director
Branch Chief (DRP/D, WCFO)
Senior Project Inspector (DRP/D)
Branch Chief (DRP/TSS)
WCFO File
The Chairman (MS: 16-6-15)
Commissioner Rogers (MS: 16-6-15)
Commissioner Diaz
Commissioner McGaffigan
L. J. Callan, EDO (MS: 17-6-21)
Associate Dir. for Projects, NRR
Associate Dir. for Insp., and Tech. Assmt, NRR
SALP Program Manager, NRR/ILPB (2 copies)
J. W. Roe, NRR, Director, Division of Reactor Projects lli/IV
M. B. Fields, NRR, Project Manager
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Enclosure
ERRATA
REPLACEMENT PAGES
TO SALP REPORT
50-528/98-99; 50-529/98-99; 50-530/98-99