ML081020348

EA-08-003, Meeting Summary for Palo Verde Nuclear Generating Station Public Meeting

ML081020348
Person / Time
Site:	Palo Verde
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)

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV611 RYAN PLAZA DRIVE, SUITE 400ARLINGTON, 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 licensee's request.

During this meeting, Palo Verde management discussed the apparent causes for the failure to

promptly correct the identified performance w eakness, 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 Verde's 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 Avail able Records (PARS) component of NRC's document

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Randall 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 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 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 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: Yes G No Initials: PJE Publicly Available G Non-Publicly Available G Sensitive Non-Sensitive DOCUMENT NAME:Distribution for Reactor Escalated.wpd D RS/OB TL:ACES C:DRS/OB P Elkmann K SFuller R Lantz /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 Emergency Action Level 1-7 Regulatory Conference Randy Edington Randy Edington Executive Vice President and Chief Nuclear Officer Executive Vice President and

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

Improvements*Assessments / ImPACT*Root Cause Investigations*Organizational Changes

• Significant Training Efforts

• Procedures / EAL Improvements

• NEI 99-01 Revision 5 EAL Methodology Conversion *Assessments / ImPACT*Root Cause Investigations*Organizational Changes

• Significant Training Efforts

• Procedures / EAL Improvements

• NEI 99-01 Revision 5 EAL Methodology Conversion Scott Bauer Scott Bauer Director Regulatory Affairs Director Regulatory Affairs Apparent WHITEFinding Apparent WHITE Finding*Performance Deficiency: Failure to Correct an RSPS Weakness in a Timely Manner*Emergency Preparedness Significance Determination Process Criteria:-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*Performance Deficiency: Failure to Correct an RSPS Weakness in a Timely Manner*Emergency Preparedness Significance Determination Process Criteria:-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 APS Perspective*Assumed Knowledge Deficiency Existed With Definition of Prolonged Release*Job Performance Measure (JPM) Was Flawed-Incorrect Answer-Insufficient Information

-Unrealistic Scenario*Corrective Action Program Not Effectively Used*Knowledge Deficiency Would Not Result in Misclassification of an Actual Event*Assumed Knowledge Deficiency Existed With Definition of Prolonged Release*Job Performance Measure (JPM) Was Flawed-Incorrect Answer-Insufficient Information

-Unrealistic Scenario*Corrective Action Program Not Effectively Used*Knowledge Deficiency Would Not Result in Misclassification of an Actual Event Table 1: Fission Product Barrier Reference (Modes 1-4) FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET temperature > 700ºF [1-1] Highest valid CET temperature > 1200ºF [1-1] RCS leak > 44 gpm [1-6] RCS leak rate > available makeup capacity as indicated by a loss of RCS subcooling (i.e., RCS at saturation conditions) [1-6] CTMT pressure 50 psig and increasing [1-10] Rapid unexplained CTMT pressure decrease following initial increase [1-10] RCS activity > 300 µCi/gm Dose Equivalent I-131 [1-3] CTMT pressure

> 8.5 psig with both CTMT Spray Systems notoperating [1-10] CTMT pressure or sump level response not consistent with LOCA conditions [1-10] Time since shutdown=0.2 hrs: CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or RU-149 > 2.4E+05 mrem/hr, OR Time since shutdown >.2 hrs: Refer to Appendix P [1-4] RU-148 / RU-149 curves [1-4] CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, orRU-149 > 7.8E+06 mrem/hr [1-11] Failure of both CTMT isolation valves in any one line to close and pathway to the environment exists [1-13] Time since shutdown=0.2 hrs: & total RCS leakage < 1 gpm:

RCS radiation monitor RU-150 or RU-151 > 2.2E+04 mrem/hr OR Time since shutdown >.2 hrs & total RCS leakage < 1 gpm: Refer to Appendix P [1-4] RU-150 / RU-151curve [1-4] SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] Release of contam. Secondary side to atmosphere (i.e., S/G safety or ADV) with S/G P/S leakage > Tech Spec allowable S/G P/S leakage [1-14] Valid RVLMS level currently or previously < 21% plenum [1-2] LOAF such that minimum acceptable feedwater flow cannot be maintained

[1-8] H 2 concentration > 3.5% by volume [1-10] 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 potential loss of Fuel Clad Barrier [1-5] Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of RCS Barrier [1-9] Any condition that, in the opinion of the SM/EC, indicates loss or 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 Clad or RCS Loss of both Fuel Clad and RCS OR Potential loss of both Fuel Clad and RCS OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier Loss of any two barriers AND Potential loss of a third barrier Table 1: Fission Product Barrier Reference (Modes 1-4) FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET temperature > 700ºF [1-1] Highest valid CET temperature > 1200ºF [1-1] RCS leak > 44 gpm [1-6] RCS leak rate > available makeup capacity as indicated by a loss of RCS subcooling (i.e., RCS at saturation conditions) [1-6] CTMT pressure 50 psig and increasing [1-10] Rapid unexplained CTMT pressure decrease following initial increase [1-10] RCS activity > 300 µCi/gm Dose Equivalent I-131 [1-3] CTMT pressure

> 8.5 psig with both CTMT Spray Systems notoperating [1-10] CTMT pressure or sump level response not consistent with LOCA conditions [1-10] Time since shutdown=0.2 hrs: CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or RU-149 > 2.4E+05 mrem/hr, OR Time since shutdown >.2 hrs: Refer to Appendix P [1-4] RU-148 / RU-149 curves [1-4] CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, orRU-149 > 7.8E+06 mrem/hr [1-11] Failure of both CTMT isolation valves in any one line to close and pathway to the environment exists [1-13] Time since shutdown=0.2 hrs: & total RCS leakage < 1 gpm: RCS radiation monitor RU-150 or RU-151 > 2.2E+04 mrem/hr OR Time since shutdown >.2 hrs & total RCS leakage < 1 gpm: Refer to Appendix P [1-4] RU-150 / RU-151curve [1-4] SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] Release of contam. Secondary side to atmosphere (i.e., S/G safety or ADV) with S/G P/S leakage > Tech Spec allowable S/G P/S leakage [1-14] Valid RVLMS level currently or previously < 21% plenum [1-2] LOAF such that minimum acceptable feedwater flow cannot be maintained

[1-8] H 2 concentration > 3.5% by volume [1-10] 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 potential loss of Fuel Clad Barrier [1-5] Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of RCS Barrier [1-9] Any condition that, in the opinion of the SM/EC, indicates loss or 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 Clad or RCS Loss of both Fuel Clad and RCS OR Potential loss of both Fuel Clad and RCS OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier Loss of any two barriers AND Potential loss of a third barrier SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] SGTR > 44 gpm

[1-7]SGTR > 132 gpm with a prolonged release

of contaminated

secondary coolant occurring from the ruptured SG to the environment (see

Limitations in Section 1)

[1-7]

Prolonged Release 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 FeedwaterLine 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 Cooldownto Mode 5 Attribute of EAL 1-7*EPIP 99, Appendix A, Section 1, Precautions and Limitations Defines "Prolonged Release of Contaminated Secondary Coolant"as

Encompassing:-A Main Steam Line Break-A FeedwaterLine 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 Cooldownto Mode 5 Attribute of EAL 1-7 Timeline Timeline*JPM Administered 30 Times from 2005 to 2007*21 Emergency Coordinators (EC) Classified GE (Declaring EAL 1-7 Loss Versus Potential Loss)*8 ECsWere 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*JPM Administered 30 Times from 2005 to 2007

• 21 Emergency Coordinators (EC) Classified GE (Declaring EAL 1-7 Loss Versus Potential Loss)*8 ECsWere 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 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)*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 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*APS Failed to Afford the Appropriate Significance to an Emergency Preparedness Classification Issue-Error Propagated Into NRC Initial Exam-Recurred During 95003 Inspection*APS Agrees This Was a Performance Deficiency*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*APS Failed to Afford the Appropriate Significance to an Emergency Preparedness Classification Issue-Error Propagated Into NRC Initial Exam-Recurred During 95003 Inspection*APS Agrees This Was a Performance Deficiency Significance 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*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 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*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 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*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 APS Perspective*SGTR JPM Cues-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*SGTR JPM Cues-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 APS Perspective*SGTR JPM Cues

-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)*SGTR JPM Cues

-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 Event Timeline JPM Scenario SGTR>200 gpm, Rx Trip & LOOP

Open ADVs.

Isolate faulted SG 30 min GE EAL 1-7 L, 1-14L, 1-2 PLRVLMS < 21%

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

TSC & EOF ActivatedJPM asks for classification

for all conditions at this

point in time Event Timeline JPM Scenario Event Timeline JPM Scenario SGTR>200 gpm, Rx Trip & LOOP

Open ADVs.

Isolate faulted SG 30 minRVLMS < 21%

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

TSC & EOF ActivatedJPM asks for classification

for all conditions at this

point in timeSAE EAL 1-7 PL, 1-14L and 1-2 PL SAE EAL 1-7 PL

and EAL 1-14L Event TimelineSimulator Results for JPM Scenario Initial Conditions Event TimelineSimulator Results for JPM Scenario Initial Conditions SAE EAL 1-7 PL &

EAL 1-14L SGTR>200 gpm, Rx Trip & LOOP

Open ADVs.

Isolate faulted

SG 30 minEvent TerminationSAE EAL 1-14L, 1-6 L, 1-7 PLRCS Subcooling

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

TSC & EOF Activated RCS Cooled Down Table 1: Fission Product Barrier Reference (Modes 1-4) FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET temperature > 700ºF [1-1] Highest valid CET temperature > 1200ºF [1-1] RCS leak > 44 gpm [1-6] RCS leak rate > available makeup capacity as indicated by a loss of RCS subcooling (i.e., RCS at saturation conditions) [1-6] CTMT pressure 50 psig and increasing [1-10] Rapid unexplained CTMT pressure decrease following initial increase [1-10] RCS activity > 300 µCi/gm Dose Equivalent I-131 [1-3] CTMT pressure

> 8.5 psig with both CTMT Spray Systems notoperating [1-10] CTMT pressure or sump level response not consistent with LOCA conditions [1-10] Time since shutdown=0.2 hrs: CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or RU-149 > 2.4E+05 mrem/hr, OR Time since shutdown >.2 hrs: Refer to Appendix P [1-4] RU-148 / RU-149 curves [1-4] CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, orRU-149 > 7.8E+06 mrem/hr [1-11] Failure of both CTMT isolation valves in any one line to close and pathway to the environment exists [1-13] Time since shutdown=0.2 hrs: & total RCS leakage < 1 gpm:

RCS radiation monitor RU-150 or RU-151 > 2.2E+04 mrem/hr OR Time since shutdown >.2 hrs & total RCS leakage < 1 gpm: Refer to Appendix P [1-4] RU-150 / RU-151curve [1-4] SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] Release of contam. Secondary side to atmosphere (i.e., S/G safety or ADV) with S/G P/S leakage > Tech Spec allowable S/G P/S leakage [1-14] Valid RVLMS level currently or previously < 21% plenum [1-2] LOAF such that minimum acceptable feedwater flow cannot be maintained

[1-8] H 2 concentration > 3.5% by volume [1-10] 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 potential loss of Fuel Clad Barrier [1-5] Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of RCS Barrier [1-9] Any condition that, in the opinion of the SM/EC, indicates loss or 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 Clad or RCS Loss of both Fuel Clad and RCS OR Potential loss of both Fuel Clad and RCS OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier Loss of any two barriers AND Potential loss of a third barrier Table 1: Fission Product Barrier Reference (Modes 1-4) FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET temperature > 700ºF [1-1] Highest valid CET temperature > 1200ºF [1-1] RCS leak > 44 gpm [1-6] RCS leak rate > available makeup capacity as indicated by a loss of RCS subcooling (i.e., RCS at saturation conditions) [1-6] CTMT pressure 50 psig and increasing [1-10] Rapid unexplained CTMT pressure decrease following initial increase [1-10] RCS activity > 300 µCi/gm Dose Equivalent I-131 [1-3] CTMT pressure

> 8.5 psig with both CTMT Spray Systems notoperating [1-10] CTMT pressure or sump level response not consistent with LOCA conditions [1-10] Time since shutdown=0.2 hrs: CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or RU-149 > 2.4E+05 mrem/hr, OR Time since shutdown >.2 hrs: Refer to Appendix P [1-4] RU-148 / RU-149 curves [1-4] CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, orRU-149 > 7.8E+06 mrem/hr [1-11] Failure of both CTMT isolation valves in any one line to close and pathway to the environment exists [1-13] Time since shutdown=0.2 hrs: & total RCS leakage < 1 gpm:

RCS radiation monitor RU-150 or RU-151 > 2.2E+04 mrem/hr OR Time since shutdown >.2 hrs & total RCS leakage < 1 gpm: Refer to Appendix P [1-4] RU-150 / RU-151curve [1-4] SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] Release of contam. Secondary side to atmosphere (i.e., S/G safety or ADV) with S/G P/S leakage > Tech Spec allowable S/G P/S leakage [1-14] Valid RVLMS level currently or previously < 21% plenum [1-2] LOAF such that minimum acceptable feedwater flow cannot be maintained

[1-8] H 2 concentration > 3.5% by volume [1-10] 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 potential loss of Fuel Clad Barrier [1-5] Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of RCS Barrier [1-9] Any condition that, in the opinion of the SM/EC, indicates loss or 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 Clad or RCS Loss of both Fuel Clad and RCS OR Potential loss of both Fuel Clad and RCS OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier Loss of any two barriers AND Potential loss of a third barrier Table 1: Fission Product Barrier Reference (Modes 1-4) FUEL CLAD BARRIER RCS BARRIER CONTAINMENT BARRIER POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS Highest valid CET temperature > 700ºF [1-1] Highest valid CET temperature > 1200ºF [1-1] RCS leak > 44 gpm [1-6] RCS leak rate > available makeup capacity as indicated by a loss of RCS subcooling (i.e., RCS at saturation conditions) [1-6] CTMT pressure 50 psig and increasing [1-10] Rapid unexplained CTMT pressure decrease following initial increase [1-10] RCS activity > 300 µCi/gm Dose Equivalent I-131 [1-3] CTMT pressure

> 8.5 psig with both CTMT Spray Systems notoperating [1-10] CTMT pressure or sump level response not consistent with LOCA conditions [1-10] Time since shutdown=0.2 hrs: CTMT radiation monitor RU-148 > 2.1E+05 mrem/hr, or RU-149 > 2.4E+05 mrem/hr, OR Time since shutdown >.2 hrs: Refer to Appendix P [1-4] RU-148 / RU-149 curves [1-4] CTMT radiation monitor RU-148 > 6.8E+06 mrem/hr, orRU-149 > 7.8E+06 mrem/hr [1-11] Failure of both CTMT isolation valves in any one line to close and pathway to the environment exists [1-13] Time since shutdown=0.2 hrs: & total RCS leakage < 1 gpm:

RCS radiation monitor RU-150 or RU-151 > 2.2E+04 mrem/hr OR Time since shutdown >.2 hrs & total RCS leakage < 1 gpm: Refer to Appendix P [1-4] RU-150 / RU-151curve [1-4] SGTR > 44 gpm [1-7] SGTR > 132 gpm with a prolonged release of contaminated secondary coolant occurring from the ruptured S/G to the environment (see limitations in Section 1) [1-7] Release of contam. Secondary side to atmosphere (i.e., S/G safety or ADV) with S/G P/S leakage > Tech Spec allowable S/G P/S leakage [1-14] Valid RVLMS level currently or previously < 21% plenum [1-2] LOAF such that minimum acceptable feedwater flow cannot be maintained

[1-8] H 2 concentration > 3.5% by volume [1-10] 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 potential loss of Fuel Clad Barrier [1-5] Any condition that, in the opinion of the SM/EC, indicates loss or potential loss of RCS Barrier [1-9] Any condition that, in the opinion of the SM/EC, indicates loss or 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 Clad or RCS Loss of both Fuel Clad and RCS OR Potential loss of both Fuel Clad and RCS OR Potential loss of either Fuel Clad or RCS AND loss of any additional barrier Loss of any two barriers AND Potential loss of a third barrier Conditions for Misclassification Unlikely 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*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 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 Associ ated With a Potential Loss of Fuel Clad*Assumed Knowledge Deficiency Created by the JPM is Inconsequential to Classification of SGTRsNot 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 Ta ke Into Account Actual Changes in Plant Conditions-Multiple Personnel Would Be Involved Depending on Timing/Sequence-Integration/Multiple Information Sources Available*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 Associ ated With a Potential Loss of Fuel Clad*Assumed Knowledge Deficiency Created by the JPM is Inconsequential to Classification of SGTRsNot 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 Ta ke Into Account Actual Changes in Plant Conditions-Multiple Personnel Would Be Involved Depending on Timing/Sequence-Integration/Multiple Information Sources Available Additional Information 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, Additio nal EC-qualified People Would Be Checking Classification*These Independent Checks Not Available During JPM*STAsReceived Specific "Prolonged Release" Training Independent of JPM Error Corrective Actions*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, Additio nal EC-qualified People Would Be Checking Classification*These Independent Checks Not Available During JPM*STAsReceived Specific "Prolonged Release" Training Independent of JPM Error Corrective Actions Conclusion Conclusion*APS Agrees This Was a Performance Deficiency-CAP Not Initially Used Which Propagated Error and Delayed Corrective Actions*Job Performance Measures Have Limited, Specific Application*Deficiency Did Not Result in the Inability to Properly Classify an Emergency Condition in an Actual Event*Broad-based Corrective Actions Taken and Planned to Improve Emergency Preparedness*APS Agrees This Was a Performance Deficiency-CAP Not Initially Used Which Propagated Error and Delayed Corrective Actions*Job Performance Measures Have Limited, Specific Application*Deficiency Did Not Result in the Inability to Properly Classify an Emergency Condition in an

Actual Event*Broad-based Corrective Actions Taken and Planned to Improve Emergency Preparedness Terry Radtke Terry Radtke General Manager Emergency Services and Support General Manager

Emergency Services and Support Leadership Training Leadership Training Accountability Model Accountability Model Assessment 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*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 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*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 Benchmarking*Site visits in 2007 / 2008Pilgrim River Bend WaterfordCallaway FitzPatrick Turkey Point Nine Mile PointSONGSSt. Lucie *Industry and Peer Expert Assistance*Best Practice Improvement Plans *Performance Metrics*Site visits in 2007 / 2008Pilgrim River Bend WaterfordCallaway FitzPatrick Turkey Point Nine Mile PointSONGSSt. Lucie *Industry and Peer Expert Assistance*Best Practice Improvement Plans *Performance Metrics Ownership and Accountability Ownership and Accountability Senior Management Reinforced EP Importance and Priority EP ADDED FOR INCREASED EMPHASIS Ownership and Accountability 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)*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 Ownership and Accountability RP ERO OPS TRNG EP A L I G N M E N T Knowledge and Training Knowledge and Training*Increased Drills and Exercises *Implementing Systematic Approach to Training for ERO Positions*Focused EAL and PAR Training

• Emergency Services and Support General Manager Added to Site Training Oversight

Committee*EC EAL Knowledge Improvement Plan *Increased Drills and Exercises

• Implementing Systematic Approach to Training for ERO Positions*Focused EAL and PAR Training

• Emergency Services and Support General Manager Added to Site Training Oversight

Committee*EC EAL Knowledge Improvement Plan Resources 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*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 Facilities and Equipment*Communication-Audio / Video-ERO Pagers-NAN / PBX Phones*Software-RADDOSE-Web EOC (Implementing)*Sirens*Communication-Audio / Video

-ERO Pagers-NAN / PBX Phones*Software-RADDOSE-Web EOC (Implementing)*Sirens C orrective Actions C orrective 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 *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 C orrective Actions C orrective Actions*Operator Training EAL JPMsand Training Simulator Exercises Receive Emergency Planning Review and Concurrence*Training on the EP Significance Determination Process Elements *EAL Improvements*NEI 99-01 Revision 5 EAL Methodology Conversion*Operator Training EAL JPMsand Training Simulator Exercises Receive Emergency Planning Review and Concurrence*Training on the EP Significance Determination Process Elements *EAL Improvements*NEI 99-01 Revision 5 EAL Methodology Conversion Conclusion Conclusion*Broad-based Improvement Plan *Specific EAL Improvement Actions*Increased Ownership and Accountability

• Driving Knowledge and Standards

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

• Driving Knowledge and Standards

• Improved Alignment of ERO Stakeholders Dwight Mims Dwight Mims Vice President Regulatory Affairs and Plant Improvement Vice President

Regulatory Affairs and Plant Improvement Closing 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*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 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*Similar to Disposition of Finding in IR 2005002-Could Also Be Addressed as a Deficiency in Training of Emergency Response Personnel Under PS b(15)*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*Similar to Disposition of Finding in IR 2005002-Could Also Be Addressed as a Deficiency in Training of Emergency Response Personnel Under PS b(15)

Closing Closing*APS Initiated and Made Significant Improvements in Emergency Preparedness Throughout 2007*APS Will Continue to Implement the Planned Actions to Further Improve Performance*APS Will Continue to Monitor and Assess Emergency Preparedness Performance and

Actively Engage With the Industry*Goal: Be Recognized as an Industry Leader in Emergency Preparedness*APS Initiated and Made Significant Improvements in Emergency Preparedness

Throughout 2007*APS Will Continue to Implement the Planned Actions to Further Improve Performance*APS Will Continue to Monitor and Assess Emergency Preparedness Performance and

Actively Engage With the Industry*Goal: Be Recognized as an Industry Leader in Emergency Preparedness