ML20126E170
| ML20126E170 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1984 |
| From: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20126E093 | List: |
| References | |
| FOIA-85-37 NUDOCS 8506150312 | |
| Download: ML20126E170 (13) | |
Text
- s * * *' '*e.,
UNITED STATES
?s NUCLEAR REGULATORY COMMISSION f
'.E i j OFFICE OF tt.",PECTION AND ENFORCEMENT t
REGION V 2450 MARIA LANE, $UlTE 210 WALNUT CREEK, CALtFORNIA 94596 December 19, 1984 T0:
Tom Rehm. OED0 FROM:
B. Faulkenberry, RV I
" %.y f ' N ([y M id
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. 4 tin 4Y='A SUBJ:
REQUEST FROM ARIZONA STATE UTILITY COMMISSION Attached is the report I discussed with you on 12/19/84.
It is my understanding that you will handle the action requested in this document and that no additional action is required from Region V unless you so infonn me.
B. H. Faulkenberry Deputy Regional Administrator Attachment a/s n m.,,
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Arizona Public Service Company PO Box 21666 e PHOENIX. ARIZONA 85036
",$^Ms"e","3 December 14, 1984 RAff$ AND REQuLATIOpe ARIZONA m'~ ~ '
CC.;6,. 4c...y 0 DEC 141984 Arizona Corporation Commission 3
1200 W. Washington St.
,,, [ g { l i} }
Phoenix, AZ 85007 U$$EIE,cs Attn:
Mr. Wayne Ruhter Director, Utilities Divn.
Re:
ACC Decision No. 54247 - Plan for Administration of Performance Incentive Adjustment Gentlemen:
In accordance with the provisions in the Commission's Decision No. 54247 in Docket No. U-1345-83-155, Arizona Public Service Company hereby files 5 copies of the
" Plan for Administration of Performance Incentive Adjust-ment" which details the administration of the operating incentive provisions relative to.the Company's share of Four Corners and Palo Verde Unit #1.
If you or a member of your staff have any questions regarding this filing, please feel free to contact me.
Sincerely, j
l JRS/rt Enclosure s
ARIZONA PUBLIC SERVICE COMPANY Plan For Administration of Performance Incentive Adjustment per A.C.C. Decision No. 54247 Dated November 28, 1984 I.
GENERAL DESCRIPTION Certain of the Company's electric rate schedules are subject to the following Performance Incentive Adjustment clause.
"Plus or minus a Performance Incentive Adjustment Factor in fractions of dollars per kwh based upon the demonstrated operating performance standards of the Company's share of the Four Corners Generating Station and the Palo Verde Nuclear Generating Station Unit #1, compared to performance standards established by the Arizona Corporation Commission. The method of applica-tion is described in the filed Plan for Administration of Performance Incentive Adjustment."
The Arizona Corporation Commission (Commission) has established performance standards for Arizona Public Service Company's (Company) share of the Four Corners Generation Station (Four Corners) and the Palo Verde Nuclear Generating Station Unit #1 (Palo Verde #1). These standards are expressed in terms of an " Equivalent Availability Factor" (EAF) for the
(
operating performance related to Four Corners, and a " Capacity Factor" (CF) for the operating performance of Palo Verde #1, with a "deadband", a
(
penalty band and a reward band. The limits of the penalty band, deadband, l
and reward band are:
l Equivalent Availability / Capacity Factors Penalty Band Deadband Reward Band l
Four Corners 40% to 65%
65% to 75%
75% to 100%
Palo Verde #1 35% to 60%
60% to 75%
75% to 100%
l The actual operating performance of these generating facilities during a Measurement Period shall be compared to those standards.
l established by the Commission in order to determine the total Performance l
Incentive Adjustment amount to be credited or cdTTected from the Company's customers in the form of a Performance Incentive Adjustment Factor (PIAF) applied to their consumption during an Adjustment Period.
l l
Page 1
Provisions have also been made for adjustment of the actual measured operating performance standards used for determining the Performance Incentive Adjustment amount due to " extraordinary events."
The actual Performance Incentive Adjustment dollar amount (negative or positive) is to be billed on a per kwh basis during a 12-month period (Adjustment Period) following the operating performance Measurement Period, usually beginning with the first billing cycle of the fifth month following the Measurement Period.
Adjustments of $1,000,000 or less will be handled by credits / charges to the. Company's Purchased Power and Fuel Adjustment Clause (PPFAC) balance.
II.
ESTABLISHMENT OF OPERATING PERFORMANCE STANDARDS Operating performance standards upon which the Company's penalty /
reward status is to be determined shall be established separately for Four Corners and Palo Verde #1.
Such standards. _wil_1_,be. established _.only. furing apALrate cas,e which, fair value rate base and fair return thereon _is f p The standards, once established, will remain unchanged for at least 24 months.
Such standards shall be based upon industry experience of generally similar generating units weighted and appropriately adjusted for specific Company generating units subject to the Performance Incentive Adjustment including, but not limited to considerations of age, environmental equipment and coal quality.
III. EXTRAORDINARY EVENTS The Equivalent Availability Factor for Four Corners and the Capacity Factor for Palo Verde #1 attained over the Measurement Period that are used for purposes of computing the Performance Incentive Adjustment dollar amount, may be adjusted to account for " extraordinary events".
Any claims by the Company for special relief due to an
" extraordinary event", shall trigger an automatic hearing with notice to l
every party in the Company's,last general rate proceeding and shall not affect the imposition of any penalty / reward amounts pending the outcome of said hearing.
l The Company shall be permitted to claim the existence of an l
" extraordinary event" in order to reduce or cancel an otherwise required penalty incentive amount; but, however, such claim (s) shall not produce a reward situation when none would otherwise exist.
(
IV.
PERFORMANCE INCENTIVE I
Each of the Company's electric rate schedules which include an implicit or explicit charge per kwh will be subject to the following l
adjustment clause:
~
l Page 2
"Plus or minus a Performance Incentive Adjustment Factor in fractions of dollars per kwh based upon the demonstrated operating performance standards of the Company's share of the Four Corners Generating Station and the Palo Verde Nuclear Generating Station Unit #1, compared to performance standards established by the Arizona Corporation Commission. The method of application is described in the filed Plan for Administration of Performance Incentive Adjustment."
V.
ESTABLISHMENT OF THE PENALTY / REWARD DOLLAR AD.TUSTMENT AMOUlfr The Commission has established that the basis for determining the dollar Performance Incentive Award for the operating performance of Four Corners and Palo Verde #1 shall be.as shown on the following table (see Exhibit 1).
The resulting reward / penalty incentive dollar amount based on Four Corner's performance shall be algebraically added to that of Palo Verde #1 in determining the total performance incentive dollar amount to be awarded during the Adjustment Period.
1 e
t Page 3
EXM1 BIT 1 FOUR CORNERS GENERATING STATION (The Performance Incentive Adjustment dollar amount shall be based on the EAT during the Measurement Period as set forth below:)
Zone of Plant Operating Performance Performance Basis for the (Equiv. Availability Incentive Amount of Factor)
Renas Reward / Penalty
- 85% to 100%
Reward 100% of not avoided fuel costs over 85%; plus 50% of not a
fuel costs between 51 85%
75% to 85%
Reward 50% of not avoided fuel costs 65% to 75%
Deadband 0
(Neutral) 55% to 65%
Penalty 50% of not add'1. fuel costs 40% to 55%
Penalty 100% of not add'1. fuel costs below $5%; plus 50% of not add'1 fuel costs between 35%-65%
below 40%
Reconsideration of last general rate case per Decision No. 54247.
l Palo Verde Nuclear Generatina Station Unit #1 (The Performance Incentive Adjustment dollar amount associated with this facility shall be based on the CT during the Measurement Period as set forth below:)
Zone of Plant Performance Basis for the Operating Performance Incentive Amount of (Capacity Factor)
Ranae Reward / Penalty
- 85% to 100%
Reward 100% of not avoided fuel costs over 85%; plus 50% of nut l
svoided fuel costs between 751-85%
75% tu 85%
Reward 50% of not avoided fuel costs 60% to 75%
Deadband 0
l (Neutral) 50% to 60%
Penalty 50% of not add'1. fuel costs 35% to 50%
Penalty 100% of not add'1. fuel costs below 50%; plus 50% of add'1.
fuel costs between 50%-60%
f below 35%
Reconsideration of last general rate case per Decision No. 54247.
l
- A proxy shall be used for determining the gross avoided / additional fuel costs based on the Company's total Purchased Power and Fuel (PPF) expense per Mvh at generation level, exclusive of sepation Wh.4nd -fuel ampense for Tour Corners and Palo Verde #1 during the Measurement Period.
Generation Mvh and expense shall be those used in the company's Purchased j
Power and Tuol Adjustment Clause.
l l
l r
l Page 4
VI.
METHOD OF APPLICATION 1.
Effective Date The Plan will become effective on January 1, 1985, and commencing in 1986, the Company shall annually file with the Commission I
its computations of the Performance Incentive Adjustment Factor not later than March 1 based upon the EAF of Four Corners and the CF of Palo Verde
- 1.
The Performance Incentive Adjustment Factor (unless adjusted as a result of an " extraordinary event"), negative or positive, will become effective with first billing cycle of May immediately following the filing.
In the event an adjustment to the Company's Performance Incentive Adjustment amount is allowed by the Commission as a result of a claim due to an " extraordinary event", such adjustment shall be implemented as provided for in subsection (7) of this section of the Plan.
2.
Computation of Four Corners and Palo Verde #1 Operatina Performance Factors The Commission has established that for purposes of this l
incentive plan, the operating performance for Four Corners shall be based on the EAF of the plant during the Measurement Period, while that for Palo Verde #1 shall be based on its CF during the Measurement Period.
i The EAF for Four Corners shall be computed as follows:
EAF = AH - (EF0H + ESOH) x 100 i
PH d
where:
AH
= available hours EF0H = equivalent forced partial outage hours ESOH = equivalent scheduled partial outage hours PH
= period hours l
and l
(
EF0H = Forced partial outate hours x size of reduction in MW
[
MDC ap ESOH = Scheduled partial outane hours x size of reduction in NW MDC RP l
l' Weighted maximum dependable capacity in MW MDC
= during the Measurement Period. Weighting op to be computed as:
(MDC ) (hours in period 1) +...(MDC ) (hours in period n)
MDC =
1 n
op hours in Measurement Period l
l l
Page 5 m
e n
--,, - - - - - - - - - - +,
The CF for Palo Verde #1 shall be computed as follows:
CF =
MWH MW x PH where:
MWH = the amount of MWH's generated during the Measurement Period NW = time weighted rated capacity of Palo Verde #1 PH = number of hours in the Measurement Period For the purposes of this incentive plan, the Palo Verde generating Unit #1 shall begin its first Measurement Period on the first day of the third month following attainment of commercial operation. The CF used for determining the operating performance of the facility shall be weighted for the portion of such calendar year remaining in the Measurement Period from and including the first day of the third month following commercial operation.
As an example, assume:
max. dependable capacity = 370 sw ist day of MWH Generated Hrs Remaining Comm. Oper.
3rd Mo.
After Comm. Oper.
in Msrat. Period 3/31/85 6/1/85 1,140,192 5136 The Palo Verde #1 CF for the 1985 Measurement Period would then be calculated as follows:
CF =
1,140,192 MWH
= 60%
5,136 Hr x 370 MW 3.
Determination of the Company's Overall Performance Incentive Adjustment Dollar Amount The determination of the additional / avoided fuel costs during the Measurement Period associated with the Company's share of generating facilities subject to this incentive plan (presently Four Corners and Palo Verde #1) must first be calculated for each facility separately. The additional / avoided fuel costs for each facility are then algebraically summed in order to arrive at the total overall Performance Incentive l
Adjustment dollar amount (either a penalty or reward) to be billed during the Adjustment Period.
i The following description outlines the steps necessary in determining the overall Performance Incentive Adjustment dollar amount:
A.
Calculate the net replacement fuel cost for each facility similar to that shown for Four Corners below:
NRFC
= PPF
-F fc ab fc Page 6
where:
NRFC
= Four Corners estimated net replacement fuel cost in fc
$ per Mwh PPF
= Total APS Purchased Power and Fuel (PPF) expense per Mwh nb at generation level, exclusive of generation Hwh and fuel expense for Four Corners and Palo Verde during Measurement Period. Generation Hwh and expense shall be those used in APS' Purchased Power and Fuel Adjustment clause F
= Fuel expense per Hwh generated at APS' share of Four fc Corners during Measurement Period, using Hwh and expense in APS' PPFAC.
t B.
Compare the facility's operating performance factor during the Measurement Period with the table in Exhibit 1 of this Plan in order to determine if the facility is in a reward / penalty situation.
If in the deadband range, then no Performance Incentive amount is forthcoming for that facility.
C.
Compute avoided / additional generation (MWH's) for purposes of determining avoided / additional fuel costs similar to the methodology shown i
below for Four Corners:
If EAF is greater than 85% :
Avoided MWH = (MWH
- MWH
) +.5 (MWH
- MWH
)
avail
.85
.85
.75 If EAF is greater than 75% but less than 85% :
Avoided MWH =.5 (MWH
- MWH
)
avail
.75 i
If EAF'is greater than 55% but less than 65% :
i Add'1 MWH =.5 (MWH
- MWH
)
avail
.65 l
[results in a negative value]
l l
If EAF is less than 55% :
Add'1 MWH = (MWH
- MWH
) +.5 (MWH
- MWH
)
avail
.55
.55
.65
[results in a negative value) where:
l MWH
= MDC x PH x CF (for Palo Verde #1) avail op MWH
= MDC x PH x EAT (for Four Corners) avail op Page 7
n MWH
= MDC x PH x.85 (est. available generation in MWH at an EAF level of 85%)
.85 mp MWH
= MDC x PH x.55 (est. available generation in MWH at an EAF level of 55%)
.55 mp i
= Weighted maximum dependable capacity in NW during the op the Measurement Period PH
= Hours in Measurement Period EAF
= Equivalent Availability Factor during the Measurement op Period CF
= Capacity Factor during the Measurement Period Calculate the not avoided / additional fuel costs of each generation D.
facility similar to that shown below for use in determining the overall Performance Incentive Adjustment amount:
'R te. Sales' MWH Not Avoided fuel cost = (Avoided MWH x NRFC )x x
Tot. Sales fc MWH,y,gy MWH et.
ales
~
act (Add'l HWH x NRFC ) x x
Net Add'l fuel cost
=
Tot. Sales fc MWH,y,gy where:
Avoided NWH, Add'l MWH and MWH,y,gy are those respective values as computed in (C) above.
the actual MWH's generated at Four Corners (or MWH, g
=
Palo Verde #1) during the Measurement Period.
NRFC
" not replacement fuel cost as computed in (A) above.
fc Ret. Sales = the Company's retail sales (MWH's) during the Measurement Period.
Sales = the Company's total sales (MWH's) during the Measurement Tot.
Period.
The Company's total overall Performance Incentive dollar amount E.
is then determined by algebraically summing the net additional / avoided l
I fuel costs (as calculated in (D) above) for the generating facilities subject to this plan. A positive result indicates a reward situation and l
a negative indicates a penalty situation.
l Page 8 l
--,-,-...,,n,-,._,.
---__,,---n e-
..-p-
,,v,
-~-r v,- -
-,,,7
~
i 4.
Computation of the Performance Incentive Adjustment Factor
~
(PIAF)
The PIAF to be billed during the Adjustment Period in the form of a credit'or a charge, depending upon whether the overall Performance Incentive" Adjustment amount represerpts a penalty or reward, is computed as follows:
c
$CI + $B i
PIAF (in $/kwh) =
Kwhap where:
i SCI
= The Company's total overall Performance Incentive dollar ascunt (as computed in (4) above).
KWH '
= Projected retail sales in Kwh's during the Adjustment ap Period.
= Balance between the immediately previous Performance Incentive Adjustment dollars and the estimated incentive 1
dollars billed during the immediately preceding Adjustment Period.
S.
Definitions Measurement Period The calendar year during which operating performance factors are to be determined for computation of the Performance Incentive Adjustment amount for each of the generating facilities subject to this plan.
1 Adjustment Period The 12 billing cycle months, normally commencing with May following the Measurement Period, during which the PIAF is to be billed.
CF The Capacity Factor achieved during the Measurement Period that is used in determining the Performance Incentive dollar amount attributable to Palo Verde #1.
EAF The Equivalent Availability Factor achieved during the Measurement Period that is used in determining the Performance Incentive dollar amount attributable to Four Corners.
PIAF The Performance Incentive Adjustment Factor in $/kwh (to be stated in the nearest sixth decimal of a dollar /
kwh).
Page 9
6.
Interim Adjustment of the Performance Incentive Adjustment Factor (PIAF)
The normal expected application of the PIAF for the twelve months beginning with the first billing cycle of May would not require an interim adjustment. However, in the event that prior to the November billing cycles it appears to the Company that the amount to be billed during the twelve month period will be at variance by greater than plus or minus five percent from the required amount, the Company shall revise the PIAF for the November through April billing cycle months. The Company shall advise the Commission of the revised PIAF by October 1.
7.
Disposition of Final Variance of Billed Amount From the Actual Performance Incentive Adjustment Should the amount billed during the Adjustment Period (twelve month period ending April) be different from the actual Performance Incentive Adjustment dollar amount (plus or minus any previous difference not disposed of), such difference shall be added to or subtracted from the next Adjustment Period's Performance Incentive Adjustment amount. Also, any Performance Incentive penalty amounts levied against the Company which are later excused by Commission Order, shall be recovered by the Company as a credit to the next Adjustment Period's Performance Incentive Adjustment amount.
In the event the next Performance Incentive Adjustment Factor is zero, the difference shall be added to or subtracted from the Purchased Power and Fuel Adjustment Balance.
8.
Continuity of Plan for Administration The plan once begun for a particular Measurement Period (calendar year), will be effective for that entire calendar year, and any resultant l
Performance Incentive Adjustment amount (penalty or reward) will be billed l
to customers, even though the plan might be modified or discontinued after the Measurement Period.
9.
Revenue Relatad Taxes or Impositions The Performance Incentive Adjustment Factor billings shall be subject to all applicable revenue taxes and impositions.
i Page 10
t
- Q.
d<b Arizona Public Service Company P O BOX 21666
- PHOENIX. ARIZONA 85036 vC 1 DEN
=< pao amuuma December 20, 1984
/ ARIZC"A COF.PORATICN j
COMMISSION lg DEC 2 01984 '
l Arizona Corporation Commission 1200 West Washington Street i
Phoenix, Arizona 85007 4
3 Attn:
Mr. Wayne Ruhter i
Director, Utilities Divn.
l c..; =.
j
=
Re:
Revision to the Plan for Administration of Performance Incentive Adjustment Gentlemen:
Attached please find five copies of revised Page 6 of the Plan for Administration of Performance Incentive Adj ustment filed with the Commission on December 14, 1984.
The revisions are not substantive and are indicated by an arrow.
If you or any member of your staff have any questions, please do not hesitate to call me.
l Sincerely, O
BPH/JRS/pb attachment W2
I The CF for Palo Verde #1 shall be computed as follows:
CF =
MWH MDC x PH mp where:
MWH
= the amount of MWH's generated during the Measurement Period MDC,p = weighted max. dependable capacity of Palo Verde #1 PH
= number of hours in the Measurement Period For the purposes of this incentive plan, the Palo Verde generating Unit #1 shall begin its first Measurement Period on the first day of the third month following attainment of commercial operation. The CF used for determining the operating performance of the facility shall be weighted for the portion of such calendar year remaining in the Measurement Period from and including the first day of the third month following commercial operation.
As an example, assume:
l max. dependable capacity = 370 mw ist day of MWH Generated on &
Hrs Remaining Comm. Oper.
3rd Mo.
After 06/01/85 in Msrmt. Period 3/31/85 6/1/85 1,140,192 5136 The Palo Verde #1 CF for the 1985 Measurement Period would then be f
calculated as follows:
l CF =
1,140,192 MWH
= 60*.
5,136 Hr x 370 MW 3.
Determination of the Company's Overall Performance Incentive Adiustment Dollar Amount The determination of the additional / avoided fuel costs during the Measurement Period associated with the Company's share of generating facilities subject to this incentive plan (presently Four Corners and Palo Verde #1) must first be calculated for each facility separately. The l
additional / avoided fuel costs for each f acility are then algebraically summed in order to arrive at the total overall Performance Incentive Adjustment dollar amount (either a penalty or reward) to be billed during the Adjustment Period.
l The following description outlines the steps necessary in determining the overall Performance Incentive Adjustment dollar amount:
l A.
Calculate the net replacement fuel cost for each faeility similar to that shown for Four Corners below:
j l
l NRFC
= PPF
-F
)
fc nb fc Page 6
?
~;. '
r i
h Arizona Public Service Company P o. Got t1848 s PHoENDr, ARitokA ggny ANPF-31573/EEVBJr December 26, 1984 Mr. Darrell Eisenhut Director of Division of Licensing U. S. Nuclear Regulatory Cor:: mission Washington, D. C. 20555
. ;o
'SDBJECTs NRC READINESS REVIEW
?ILS No.:
84-002-419.05 Dear Mr. Eisenhut With respect to the o>perational readiness of Palo Verde Unit 1, Attachment A is submitted to provide information regarding various actions we have taken, or will take to enhance operator preparedness.
In response to questions raised respecting the Unit 1 fuel load incentive program, a copy of the program is submitted as Attachment 3.
The primary safeguards which insure that this program does not impair quality rest on the fact that neither Senior Project Manage-ment nor any Quality Assurance and quality Control personnel are involved in the program.
Honitoring activities conducted by the Quality Assurance Department have not identified any itema related to this program that would affect quality.
In fact, as Attachment C shows, their observation is that the incentive program has had a positive affect in that the emphasis-is on doing the. job RIGHT the first time.
Additionally, senior management has been very sensitive to this czatter and has, continually emphasized to all project personnel that we must do the job right in a quality manner.
Safety and quality have always been the primary objectives at Palo Verde.
We have also had discussions rogarding the level of operating experience at the middle and upper managmeent levels for Palo Verde. As a consequence, in addition to the positions of advisor to managernent filled by Paul McGuire who has extensive experience end background in reactor startup and operations and the consultant i
Mike Etrlo, previously furnished by S03 to assist the PVNCS Plant Manager and his staff, we have obtained the commitment from SCE to provide two additional qualified people with experience in the startup of San onofre Units 2 and 3.
One of these additional people would serve de an advisor / consultant to the APS upper cianagement at icvels including the PVNCS Plant Manager.
The other would serve the same function at levels of management of operations irmnediately below the PVHG3 Plant Hanager.
n r)
M) f N
3p$ W jf,
O Page Two Mr. Darrell Eisenhut December 26, 1984 With respect to the requalification program for 'SRO's and RO's, we will review, as stated in Attachment A, training and evaluation techniques in use at other facililties to enhance cor.munications a=ong supervisors and operatora. Additionally, arrangements have been made with SCE to obtain, prior to initial criticality, a review and critique of the Palo Verde requalification program by senior cember(s) of the San Onofre Training Department.
- h. b.
\\ _ _ _
Sincerely,
/
cu_.t.
%w c
-4 E
AP h. Van Bru ynt e President Hucle Production ANPP Project Director EEVB/jdf cce H. Thectpson (NRR)
J. Martin (Begion V)
T. Novak (NRR)
G. Xnighton (NRR)
H. Licitra (liRR)
~
e G
G e
S G
O
JRB 12/26/84 ATTACHMENT A ACTIONS TO ENHANCE OPEHATOR PREPAREDNESS The Plant Manager, tho Operatione Manager, Unic I Operatione Superin-tendent, Unit I Day Shift Supervisor, the Plant Services Manager, the Training Manager, and the Licensed Training Supervisor have nec and discussed the issues raised by 1) the NRC readiness review and
- 2) the results of the annual requalification exam.
The following actions have been agreed to.
1.
Prior to any shift crew assuming the responsibilities in Hode 6 the Unit I Operations Superintendent and/or the Day Shift Supervisor shall meet with the Shift Supervisor to assure awarenees of (i) applicable Technical Specifications (including Limiting Conditions of Operations), and (ii) specific procedures appropriate to plant conditions in that mode.
Each Shift supervisor will then brief his crew.
Consideration will be given to the er. tension of this process or for taking other measures prior to operation in other l
modes.
2.
The need for operator preparedness for Low Power Physics Testing has been long recognized.
Training on repre-i sentative test procedures has been performod on the simulato1-l and in tne claearcom as part of the first annual requali-l fication program.
Additional training will be performed during the next six-week requalification cycle starting on January 7, 1985. This training will be complete for all l
shifts prior to initial criticality.
3.
Training on Power Ascension Testing (including natural circulation) will be performed both in the classroom and
)
in the simulator during six-week requalification cycles which begin on February 18, 1985 and April 1, 1985.
This training util be complete for all shifts prior to exceeding 207, reactor power.
4.
Thero will be continued emphaele and evaluation of all crews on the simulator for precision of communication and strict adherence to procedures during training prior to and after initial criticality. The Training Deper:mont will reviww operations communications training and evaluation techniques in use at ochar facilities.
Based on thLs review, improved techniques appropriate to Palo Verdo Operations will be developed.
1
='
Revised DBK5/15/84 ATTACEMENT_B P7RGS UNIT 1 FUEL I,0AD INCBNTIVE PROGRAM Prompt fuel load of PVNGS Unit 1 is of paramount importance to the customers and stockholders of the ANPP Participants.
As such it Is the intent of the PVNGS Unit 1 Fuel Load Incentive Program (hereinafter referred to as the Program) to maximizo the probability of achieving the earliest. possible fuel load data consistent with the Participants' dedication to quality and safety and consistent with all applicable regulations.
It is recognized that the project team which APS has assembled to engineer, construct, startup and operate PVHGS Unit 1 is dedicated and loyal to the concept of devoting their full attention and ener-gies to the earliest ~ possible EucI load date for Unit 1.
It is further recognized, however, that a financial incontivo to each contributing team member la an effective means to assist the team management in assuring a maximum effort from every contributing team member over the duration of startup prior to fuel load.
ELICIBILITY:
Only management employees of - Arizona Public Service Company or other ANPF Participants assigned to work on PVNGS Unit i fuel load activities are eligiblo to participate in the program.
Eligible employees who are also participants in the AV3 corporate management incentive program.shall be given the choice of participation 'in either the A?S corporate management incentive program or the Program but not both.
The Vice President, Nuclear, his assistant and all employeca of'the APS Quality Assurance Department shell be ineligible ~
to participate in the program.
It shall be t,h e responsiblity of the APS Vice President, Nuclear to voconmond to the ANPP Administrative Committee the names of individuals eligible to participate in the program.
Personnel recommendod for oligibility to participate in the program subsequent to the initial. eligibility date of Hay 1,
1984, shall receive a prorated share of the incentive.
The prorating period shall begin June 1, 1984, and end August 31, 1984.
INCENTIVE The Program incentive shall be calculated using a base incentive.
for each Program participant.
The base incentive or a prorated portion thereof shall be awarded to cach program participant if fuel load activitics for PVNGS Unit 1 occur during the 24-hour period, November 1,
1984.
Fuel load activities shall be defined as the insertion of the first fuel cicmont assembly into the reactor vessel.
For each 24-hour period subsequent to November 1,
1934, for which fuol load activities are delayed, the base incentive or prorated porcion thoroof shalt be reduced by the amount of 2/3 of 17. resultina in no incentive being awarded for commencement of fuel load activi-ties on l'VNGS Unit 1, subscquent to March 30, 1985.
e i
- > age 2 DDK5/15/84 For each 24-hour period prior to November 1,
1954, for which fuel load activities commenco on PVNGS Unit 1,
the base incontive or prorated portion thereof shall be-increased by the amount of 2/3 of IL 2/3 of the proaran partici-The base incentive shall be defined as pants' annual base pay (including deformants) on May 1,
1984, or the date of their cligibility whichever is less.
PAY 1Gt17:
Payment of the incentive shall occur in the pay period following the 40th day after cocnencement of fuel load cetivities on PVNGS Unit 1.
Payment of the incentive shall be in the form of a special one time adjustment to salary.
PROCRAM ADMINISTRATION: The ANPP Administrative Committee shall administer the program to assure that safety and quality objectives are achieved, approve oligible personnel and determine corumencement of fuc1 load activities of PVNGS Unit 1.
The APS Vice President, Nuclear shall ' assist by providing recommendations of eligible personnel and advising the ANPP Administrative Cormittee of the estimated program payout.
Program costs shall be shared by the AHPP Participants in tfieir Participation share.
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4 ATTACfDmHT C meca n 4 mow 2' tem
- b Arltann Nuclear PowerProject COMPANY CORRESPONoENCE QUALITY ASSURANCE DEPARDIRNT e 6Tc Dc:eMer 26, 1934 to:
E. E, Van Brunt Jr.
sr. s 4060 so. s
.6312 raou:
W E. Ida si.. s 4074 ni. s 6011 susatori HANAGEMENT INCENTIVE EFFECI' ON SAFEGUARDS File 84-014-000 To your question whether.the Corporate QA/QC Department took any special precautions to ensure the ANPP Management Incentive Program did not have any adverso affect on Plant Safeguards.
A special monitoring effort was conducted for those items identified on
'~
the Integrated Tracking System as necessary for Licensing. This monitoring activity assured us that plant personnel were making proper and complete efforts and decisions in resolving and closing these open items.
We also took the opportunity to attend various Plant Weekly Management Meetings to observe. Management actions and attitudes in preparing the Plant for Licensing.
ifanagement attitude in fact has been to'etrive to do everything right the first, tirne. Rework requires more time and would have been detrimental to their Incentive Program.
ANPP QA/QC in It's normal mode of operation also has had a very aggressive involvement in the Plant, in Procedure Rev. tows Test Result Reviews, Monitoring and Auditing of Construction, Startup Testing and Operation Activities.
Based on the above and.the Management attitude which prevails throughout ANPP to have one of the best plants in the United States. the
.rporate QA/QC Depart: ent does not feel the-lhnagement Incentive had any adverse offect on Plant Safeguards, czt.a L
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W. 5. Ido Director Corporate QA/QC WEI/ alp cc:
L. A. Souzn
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NAME:
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EXTENSION:
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(NOTE:
This includes this page)
THIS MESSAGE IS BEING SENT FROM A ZEROX 485, AUTOMATIC MACHINE.
IF THERE ARE ANY QUESTIONS PLEASE CALL (602) 932-5300 X6362 THE AUTOMATIC TELECOPIER NUMBER IS (602) 932-5300 X6367.
...e...........................................................
For Office Use Only:
Person Receiving Telecepyr Person sending telecopy:
Name H..tw a
Date/ Time Date /Tiine 4.-
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'e, UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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December 27, 1984 MEMORANDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor. Regulation FROM:
James Lieberman Director and Chief Counsel Regional Operations and Enforcement Division, OELD SU; JECT:
REQUEST FOR ACTION REGARDING FALO VERDE NUCLEAR-GENERATING STATION UNIT 1 The attached letter to you from Myron Scott on behalf of the Coalition for Responsible Energy Education (CREE) requests that you withhold low-power licensino of Falo Verde Unit i until the NRC undertakes a review of certain incentive' plansfor their impact on safety and alleged underfunding of emergency preparedness plans.
CREE's request should be handled as a Section 2.206 request, because it is acdressed to an appropriate NRC official, the request asks for specific actions and provides a basis for the request.
Finai action need not be taken on the request before a license is issued if the matters raised in CREE's request can be deferred for resolution after low-power licensing withou: compromising public health and safety.
Assuming this latter course of action may be appropriate, I have enciesed a draft acknowledg-ment letter to Mr. Scott infoming him that CREE's request.is under consideration.
Your staff will need to provide information for incorporation in the draft to explain the basis for not taking action prior to issuance of the low-power license.
From my conversation with Ed Case on CREE's request, I understand that Region V may be performing increased inspections related to the matters raised in the recues.
If so, this fact would be appropriate for inclusion in the acknowl-edgmer.t iet'ter.
A craft Federal Recister notice is also enclosed for your use.
i r
It is my understanding that the licensee has been asked to comment on the bonus system described in CREE's request.
If you desire further information from..the licensee about the bonus system or other matters raised in CREE's request, 'you can solicit that information pursuant to 10 CFR 50.54(f).
l Please ensure that all correspondence related to this i 2.206 request is referred to me for concurrence and that I receive copies of all incoming and outgoing correspondence related to CREE's request.
Please have your staff con-r tact call my staff contact for further assistance on this matter.
As you may note, the enclosure to CREE's request is not complete.
When we receive a com-plete copy orths enclosures, we will forward them to you.
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James Lieberman
/0 d Director and Chief Counsel h
Regional Operations and Enforcement Division
Enclosures:
CREE request Draft letter and Motice g
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p cc: (w/ encl. )
R. DeYoung, IE J. Martin, Reg. V D. Eisenhut, NRR E. Christenbury, DELD J. Axelrad, IE L. Shollenberger, Reg. V DISTRIBUTION ELD Rar NRC Central Subject Reading Burns chron t
Lieberman chron 2.206 chron Subject (P-84-28)
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Cunnincham/Murray c.
CONTACT:
Stephen G. Burns, OELD x27268
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(7590-01)
NUCLEAR REGULATORY COMMISSION (Docket No. 50-
)
ARIZONA PUBLIC SERVICE CO.
(Palo Verde Nuclear Generating Station, Unit 1)
REOUEST FOR ACTION UNDER 10 CFR 5 2.205 -
Nctice is hereby given that by letter dated December 18, 1984, Myren L.
Scott on behalf of the Coalition for Responsible Eeergy Education, Tempe, Az.,
has requested that the NRC withhold issuance of a low-power license for Unit 1 of the Arizona Public~ Service Company's Palo Verde Nuclear Generating Station until appropriate reviews for safety impact are undertaken of certain incen-tive plans initiated by the company and the Arizona Corporation Comission and questions about the adequacy of funding for state and local emergency plans are resolved.
Mr. Scott's letter is beina treated as a request for action under 10 CFR 5 2.205 and, accordingly, appropriate action will be taken on the request within a reasonable time.
A,ccpy of the request is available for public inspection in the Com.nission's Public Document Rcom at 1717 H Street, N.W., Washington, D.C. 20555, and at the local public document room for the Palo Verde facility located at Dated at Bethesda, Maryland, this day of January,1985.
FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation
L, Docket No. 50--
Mr. Myron L. Scott, Executive Director Coalition for Responsible Energy Education 315 W. Riviera Drive Tempe, Arizona 85282
Dear Mr. Scott:
This letter is sent to acknowledge receipt of your letter to me dated December 18, 1984, concerning Unit 1 of the Palo Verde Nuclear Generating Station.
In your letter, you request that the NRC withhold issuance of a low-power license for Palo Verde Unit i until a review has been undertaken D
of the safety impact of incentive regulations imposed by the Arizona Corporation Commission and the bonus plan initiated by Arizona Public Service Company.
You also contend that funding of emergency preparedness is inadequate and should preclude licensing until that issue is resolved.
Your letter is being treated as a request for action under 10 CFR 2.206.
Accordingly, I will inform you of my decision on your request within a reasonable time.
Although you requested action on these matters prior to issuance of a low power license, I do not believe that adequate assurance of public health and safety requires such immediate relief.
(NRR:
describe basis for this conclusion)
Accordingly, I believe that action on your recuest can be deferred without compromising public health and safety until the staff has had an opportunity to more fully examine the issues raised in your request.
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I enclose a Copy of a notice that will be published in the Federal Recister concerning your request.
Sincerely, Harold R. Denton Director Office of Nuclear Reactor Regulation CC:
Arizona Public Service Co.
Enclosure:
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J Decket Ib. 50-528
.(10 CFR 2.206) fir. Myron L. Scott, Executive Director Coclition for Responsible Energy tducation 215 W. P.f yiera Drive Tempe, Arizona 35282 becrMr.' Scott:
This istter is sent to acknowledge receipt of your letter to rne dated Dece5er 18, 1984, concerning Unit 1 of the Palo Verde. Nuclear Generating Station.
In your letter, you request that the NRC withh.114 issuance of a low-power Itcense for Palo Verde Unit i until a review has been undertaken 4
of the safety impact of incentive reculations impnsed by the Ari cna Ccrporaticn Comission and the bonus plan initiated by Arizona Public Sevice Cc: uany. Vnu also contend thct funding of emeroency preparedness is inadequate and should preclude lidensing until that issue is resclved.
Ycur letter is being treeted i
as a request for action under 10 CFR 2.206.
Accordingly, I will infom you of my decision of your request within a reasonable tirne.
Although you recuested action on these m:tters pricr to issuince of a lcw 000er license, I du not telieve that such irr.,ediate relief is recuired tinte there is adequate assurance oi' public health and safety for the following reascas:
(1) The incentive prograas should net have affected the completion of Pale Yarde Unit. I since plant construction was exzentially conplete prior to in.' tinting the incentive progras.
A' iso, prior to issuance of the 'ci-prier licenn, the s.tcff had dr. terr:ined thrcugh a nunter ci inspections thtt construction and testing of the plant had beer. cc.:Lleted in subst:ntial acrecment with the decketed cc :mimnts and regiatry requirmants, with tha exception of several items which were included.n c:.r.dittens of the itesnse for ccm,mletien prior to fuel lotd and other i
(
specifi _d times.
s (2) The fuel ioad and Irs: power testing progra: fer Pelo Verds Unit 1 is sche.duled to take ab0ut 4 nonths to complete.
During that period.
en. enhrnced inspection effort is ple". red fnr the pir.nt.
The staff is also currently reviewing the inplicationr. of the Paln Verde incentive plans on operation above 57 power for consideration in the i'isuance of
- full po,1er license.
'(3) The staff's roviw for Palo Verde had determined thet the states of ths c erti:ncy plans las accepteble for issuence of :. futi ! cad 7.nd Inu r.0.-tcr lictn:c.
Specifically, the licensees nnsite pi,.n wn.e. fnund p
ecceptable and the results of the amergency drill in September 19M established that the applicant'.5 plan is 1;eing pepperl With regard to the offsite, State and local ~ plans, tiie'y 1:.cplemented.
Federal Emeroency Henagemant Agency (TEMf.) is currently revlwing these plans.
Pricr'to issuance of t full power license (i.e., cperation above 5; of rated counr), a flading is recuire.d by FEPA nn the ' adequacy of the State and lecti plans. As a result of the Septe%er 19M drill, which included the offstte plans, Fc74 was able to dctermine that there is reasonabic Ecst:rance that appropriate protection measures can be implemented by effsite jurisdictions, llowever, FEMA will be requested to include your
. concert:5 in cCcpleting its evaluation of the offsite plans.
~
Acccrdingly, I believe that action nn your request can he defe.rred without ec prodsing public health and safety until the staff has had.an opportunity to core fuliy examine the issues raised in your request.
I enciese a copy of a notice that vifil be published in the Federal Recister concerning your request.
Sincereis, Harold R. Denton, Director Office of Nucicar Reactor ?:gulation Enclesvre:
A.s stated cc: Sct. nert page 4
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'[,[.,~ef, Docket No. 50-(10 CFR 2.206)
Mr. Myron L. Scott, Executive Director Coalition for Responsible Energy Education 315 W. Riviera Drive Tempe, Arizona 85282
Dear Mr. Scott:
This letter is sent to acknowledge receipt of your letter to me dated December 18, 1984, concerning Unit 1 of the Palo Verde Nuclear Generating Station.
In your letter, you request that the NRC withhold issuance of a low-power license for Palo Verde Unit 1 until a review has been undertaken of the safety impact of incentive regulations imposed by the Arizona Corporation Commission and the bonus plan initie.ted by Arizona Public Service Company. You also contend that funding of emergency preparedness is inadequate and should preclude licensing until that issue is resolved.
Your letter is being treated as a request for action under 10 CFR 2.206.
Accordingly, I will inform you of my decision on your request within a reasonable time.
Although you requested action on these matters prior to issuance of a low power license, I do not believe ' hat adequate assurance of public health and c
safety requires such immediate relief.
(NRR: describe basis for this conclusion)
Accordingly, I believe that action on your request can be deferred without compromising p'ublic health and safety until the staff has had an opportunity to more fully examine the issues raised in your request.
j
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2-I enclose a copy of-a notice that will be puSlished in the Federal Register concerning you'r request.
Sincerely, Harold R. Denton Director Office of Nuclear Reactor Regulat' ion ec:
Arizona Public Service Co.
Enclosure:
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(7590-01)
NUCLEAR REGULATORY COMMISSION (Docket No. 50,).
ARIZONA PUBLIC SERVICE CO.
(Palo Verde Nuclear Generating Station, Unit 1)
REQUEST FOR ACTION UNDER 10 CFR 5 2.206-Notice is hereby given that by letter dated December 18, 1984, Myron L.
Scott on behalf of the Coalition for Responsible Energy Education. Tempe, Az.,
has requested that the NRC withhold issuance of a low-power license for Unit 1 of the Arizona Public Servic'e Company's Palo Verde Nuclear Generating Station until appropriate reviews for safety impact are undertaken of certain incen-tive plan's initiated by the company and the Arizona Corporation Commission and questions about the adequacy of funding for state and local emergency plans are resolved. Mr. Scott's letter is being treated as a request for action under 10 CFR I 2.206 and, accordingly, appropriate action will be taken on the request within a reasonable time.
A copy of the request is available for public inspection in the Connission's Public Document Room at 1717 H Street, N.W., Washington, D.C. 20555, and at the
~
local public document room for the Palo Verde facility located at l
{
Dated at Bethesda, Maryland, this day of January,1985.
l FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation i
f
~5 Arizona Public Service Company ANPP-31708-EEVB/WFQ January 16, 1985 Mr. Darrell Eisenhut Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Docket No. STN 50-528 License No. NPF-34 File: 85-056-026; 85-002-419.5
Reference:
Letter from E. E. Van Brunt, Jr., APS, to D. Eisenhut, NRC, dated December 26, 1984 (ANPP-31573);
Subject:
NRC Readiness Review.
Dear Mr. Eisenhut:
The reference letter discussed several areas regarding the operation of PVNGS Unit 1 including the fuel load incentive program which was provided as Attachment B to the letter.
t Inadvertently, the version of the program submitted by the referenced letter was not the final version of the program. The final version actually implemented is attached and marked to indicate the minor differences from the previously submitted version.
Very truly yours, 9 9 dw%au E. E. Van B unt, Jr.
APS Vice President Nuclear Production ANPP Project Director EEVB/WFQ/mb Attachment cc:
J. B. Martin E. A. Licitra R. P. Zimmerman A. C. Gehr G. Ilernandez II. Thompson T. Novak G. Knighton g
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ANPP.31/Ua 4
STATE OF ARIZONA )
) ss.
COUNTY OF MARICOPA)
I, Edwin E.
Van B runt, Jr.,
represent that I am Vice President, Nuclear Production of Arizona Public Servico Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true, i
b./cd o.m {c 4 4.u..!sn u,
- )
s Edwin E. Van Brunt, Jr.
Sworn to before me this day of
, 1984.
Notary Public My Commission Expires:
I Pag 1 of 2 DBK5/15/84 ATTACINENT B PVNGS UNIT 1 FUEL LOAD INCENTIVE PROGRAM Prompt fuel load of PVNGS Unit 1 is of paramount importance to the customers and stockholders of the ANPP Participants. As such it is the intent of the PVNGS Unit 1 Fuel Load Incentive Program (hereinafter referred to as the Program) to maximize the probability of achieving the earliest possible fuel load date consistent with the Participants' dedication to quality and safety and consistent with all applicable regulations.
It is recognized that the project team which APS has assembled to engineer, construct, startup and operate PVNGS Unit 1 is dedicated and loyal to the concept of devoting their full attention and ener-gies to the earliest possible fuel load date for Unit 1.
It is further recognized, however, that a financial incentive to each contributing team member is an effective means to assist the team management in assuring a maximum effort from every contributing team member over the duration of startup prior to fuel load.
ELIGIBILITY:
Only nanagement employees of Arizona Public Service Company or other ANPP Participants assigned to work on PVNGS Unit I fuel load activities are eli 1ble to participate in the program.
Eli'ible 8
g employees who are also participants in the APS corporate management incentive program shall be given the choice of participation in either the APS corporate management incentive program or the Program but not both. The Vice President, Nuclear Production, his assistant l
and all employees of the APS Quality Assurance Department shall be ineligible to participate in the program.
It shall be the responsibility of the APS Vice President, Nuclear Production to recommend to the ANPP Administrative Committee the l
names of individuals eligible to participate in the program.
Personnel recommended for-eligibility to participate in the program subsequent to the initial eligibility date of May 1, 1984, shall receive a prorated share of the incentive. The prorating period shall begin June 1, 1984, and end August 31, 1984.
INCENTIVE:
The Program incentive shall be calculated using a base incentive for each Program participant. The~ba'se inc~entive or a prorated
~~
portion thereof shall be awarded to each program participant if fuel load activities for PVNGS Unit 1 occur during the 24-hour period, November 1, 1984.
Fuel load activities shall be defined as the insertion of the first fuel element assemtly into the reactor vessel.
For each 24-hour period subsequent to November 1, 1984, for which fuel load activities are delayed, the base incentive or prorated portion thereof shall be reduced by the amount of 2/3 of 1% resulting in no incentive being awarded for commencement of fuel load activi-ties on PVNGS Unit 1, subsequent to March 30, 1985.
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.Page 2 DBK5/15/86
/
For each 26-hour period to November 1, 1984, for which fuel load activities commence on PVNGS Unit 1, the base incentive or prorated portion thereof shall be increased by the amount of 2/3 of 1%.
The ba.se incentive shall be defined as the program partici-l pants' annual base pay (including deferments) on May 1, 1984, or the date of their eligibility whichever is less.
PAYMENT:
Payment of the incentive shall occur in the pay period following the 40th day after commencement of fuel load activities on PVNGS Unit 1.
Payment of the incentive shall be in the form of a special one time adjustment to sazary.
PROGRAM ADMINISTRATION: The ANPP Administrative Committee shall administer the program to ensure that safety and quality objectives are achieved, approve eligible personnel and determine commencement
- of fuel load act of PVNGS Unit 1.
The APS Vice President, Nuclear Production shall assist by providing recommendations of eligible personnel and advising the ANPP Administrative Committee of the estimated program payout.
Program costs shall be shared by the ANPP Participants in their Participation share.
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