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{{Adams
#REDIRECT [[IR 05000528/2009006]]
| number = ML091210111
| issue date = 04/20/2009
| title = NRC Problem Identification and Resolution, and Confirmatory Action Letter (CAL-4-07-004) Follow-Up Inspection Reports 05000528/2009006, 05000529/2009006, 05000530/2009006 & Notice of Violation, Dated March 20, 2009
| author name = Mims D
| author affiliation = Arizona Public Service Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000528, 05000529, 05000530
| license number =
| contact person =
| case reference number = 102-05993-DCM/DFH, CAL-4-07-004, EA-09-057
| document type = Letter, Licensee Response to Notice of Violation
| page count = 7
}}
See also: [[see also::IR 05000529/2009006]]
 
=Text=
{{#Wiki_filter:10 CFR 2.201 EA-09-057 AA subsidiary
of Pinnacle West Capital Corporation
Palo Verde Nuclear Generating
Station Dwight C. Mims Vice President Regulatory
Affairs and Plant Improvement
Tel. 623-393-5403
Fax 623-393-6077
Mail Station 7605 P.O. Box 52034 Phoenix, Arizona 85072-2034
102-05993-DCM/DFH
April 20, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory
Commission
Washington, DC 20555-0001
Reference:
Palo Verde Nuclear Generating
Station Units 1, 2 and 3 NRC Problem Identification
and Resolution, and Confirmatory
Action Letter (CAL-4-07-004)
Follow-Up
Inspection
Reports 05000528/2009006, 05000529/2009006, 05000530/2009006, and Notice of Violation, dated March 20, 2009 Subject: Palo Verde Nuclear Generating
Station (PVNGS)Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Reply to Notice of Violation
EA-09-057 In the above referenced
letter to APS, the NRC identified
that APS failed to adequately
translate
design basis maximum condensate
storage tank temperature
requirements
into procedures
to ensure the plant is operated within its design basis.Pursuant to the requirements
of 10 CFR 2.201 and the March 20, 2009, Notice of Violation (NOV) EA-09-057
that was attached to the above referenced
letter, APS hereby submits its reply to the NOV. Enclosure
1 to this letter contains a restatement
of the violation.
Enclosure
2 contains APS' reply to the NOV.No commitments
are being made to the NRC by this letter A member of the STARS (Strategic
Teaming and Resource Sharing) Alliance Callaway -Comanche Peak * Diablo Canyon .Palo Verde * San Onofre .South Texas * Wolf Creek
ATTN: Document Control Desk U.S. Nuclear Regulatory
Commission
Reply to Notice of Violation
EA-09-057 Page 2 If you have any questions, please contact Ray Buzard, Regulatory
Affairs, Compliance
Section Leader, at (623) 393-5317.Sincerely, DCM/REB/DFH
Enclosures:
1. Restatement
of Violation
EA-09-057 2. Reply to Notice of Violation
EA-09-057 cc: E. E. Collins Jr.J. R. Hall R. I. Treadway NRC Region IV Regional Administrator
NRC NRR Project Manager NRC Senior Resident Inspector
for PVNGS
Enclosure
1 Restatement
of Notice of Violation
EA-09-057 During an NRC inspection
conducted
on February 2 through February 27, 2009, a violation
of NRC requirements
was identified.
In accordance
with the NRC Enforcement
Policy, the violation
is listed below: 10 CFR Part 50, Appendix B, Criterion
Ill, "Design Control," requires, in part, that the design basis for structures, systems and components
be translated
into specifications, drawings, procedures, and instructions.
Contrary to the above, from 1985 to February 27, 2009, the licensee failed to adequately
translate
design basis information
into specifications, drawings, procedures, and instructions.
Specifically, the licensee failed to adequately
translate
design basis maximum condensate
storage tank temperature
requirements
into procedures
to ensure the plant is operated within its design basis.This violation
is associated
with a Green Significance
Determination
Process finding.I
Enclosure
2 Reply to Notice of Violation
EA-09-057 The Reason For The Violation The root causes for failing to adequately
translate
the maximum condensate
storage tank (CST) temperature
design limit into procedures
were found to be similar to those previously
identified
by the Palo Verde Improved Performance
and Cultural Transformation (ImPACT) root cause evaluations
of "Weaknesses
in Design Control and Configuration
Management
Process" and "Engineering
Technical
Rigor." Specifically, the Palo Verde Engineering
Department
had not taken full ownership
and accountability
as the design authority
at the Palo Verde Nuclear Generating
Station (PVNGS) and Engineering
leadership
had not maintained
accountability
for enforcement
of engineering
fundamentals
and human performance
standards.
The Corrective
Steps That Have Been Taken And The Results Achieved As an immediate
corrective
action, on February 18, 2009, Standing Order 219 was issued to increase the frequency
for monitoring
the CST local temperature
when main condenser
condensate
is rejected to the CST, as this could elevate CST temperature.
On February 27, 2009, procedure
40DP-90PA2, "Area 2 Operator Logs, Modes 1 -4," required a plant Auxiliary
Operator to monitor the CST temperature
three times per shift (in four hour intervals).
This revision (which became effective
in the afternoon
of February 26, 2009) included a note providing
the design limits of 40°F and 120°F and the operating
limits of 60°F and 11 0°F for the CST temperature.
Additionally, the revision provides actions for the Auxiliary
Operator to notify the Control Room Supervisor (CRS) or Shift Manager (SM) if the CST temperature
reaches 105 0 F in order to maintain a heightened
awareness
of system operations
that may impact CST temperature, e.g., high rate blowdowns.
If the CST temperature
reaches 11 0°F, the procedure
directs the CRS or SM to stop actions that reject main condenser
condensate
into the CST.Concurrent
with the changes made to procedure
40DP-90PA2, procedure
40OP-9ZZ14, "Feedwater
and Condensate," was revised to include limitations
for the CST temperature
and precautions
regarding
the potential
impact on the CST temperature
when rejecting
main condenser
condensate
to the CST.1
Enclosure
2 Reply to Notice of Violation
EA-09-057 In addition to the operating
procedure
changes referenced
above, Engineering
reviewed design documents
to determine
if more restrictive
values than the 120'F (maximum)
and the 40°F (minimum)
were used to support other engineering
analyses.
The result of the review identified
two design documents where temperature
values were more restrictive;
however, Engineering
had previously
reported deficiencies
with both documents
in the Corrective
Action Program, and Operability
Determinations
were in place that concluded
the CST remained operable.
One Operability
Determination
was revised at Engineering's
request to provide further detail about CST cover gas temperature.
The Updated Final Safety Analysis Report (UFSAR) Chapters 6 and 15 safety analyses were also reviewed for extent of condition.
No analyses were identified
that used CST temperatures
more restrictive
than 40°F and 120 0 F.These actions have resulted in increased
awareness
by appropriate
Operations
and Engineering
personnel
of the CST design temperature
values and plant conditions
that could affect the CST temperature.
The Corrective
Steps That Will Be Taken To Avoid Further Violations
'Corrective
actions for the lack of ownership
and accountability
as the design authority
and engineering
leadership
not maintaining
accountability
for enforcement
of engineering
fundamentals
and human performance
standards were developed
as a part of the ImPACT root cause evaluations.
Implementation
of these recent corrective
actions and other related ImPACT corrective
actions, in conjunction
with continued
emphasis on the principles
and behaviors
inherent in those corrective
actions, will assist in the mitigation
of legacy behaviors
that led to the lack of ownership
of the corrective
actions for resolution
of design and licensing
basis issues for the CST temperature.
These corrective
actions included the following
actions to address the accountability
and ownership
within the engineering
department:
An Engineering
Principals
and Expectations
handbook was developed
and training was provided to engineering
personnel
for clear understanding
of engineering
roles and responsibilities
including
the engineering
responsibility
as the design authority.
2
Enclosure
2 Reply to Notice of Violation
EA-09-057" Communications
were provided to site personnel
to establish
a clear understanding
of the role of the Engineering
Department
as the design authority.
* A Conduct of Engineering
procedure
was developed
and issued to the engineering
staff to provide guidance for engineering
decisions
during performance
of various tasks and activities.
This procedure
outlines the expectations
and the behaviors
necessary
for the engineering
staff to demonstrate
proper ownership
of the design basis and employ high standards
of technical
rigor and conservative
decision making in functioning
as the technical
conscience
of the site." A Palo Verde leadership
model was developed
and implemented
to establish
standards
of performance
and use them as the basis for improving
individual
behaviors
and station performance." An engineering
product quality review board, consisting
of senior engineering
management, was implemented
to evaluate selected engineering
products to ensure behaviors
that support high standards
of work are achieved and appropriate
feedback is provided.* Engineering
human performance
tools were issued to provide guidance that supports improved quality through work checklists
and pre-job briefings.
This is supported
by an engineering
observation
program to monitor, evaluate and coach high standards
of performance.
In addition to the above actions, a Component
Design Basis Review (CDBR)project is currently
in progress to identify and correct potential
latent design basis degraded conditions
on components
that have risk significance
similar to the guidance identified
in the NRC Component
Design Basis Inspection (CDBI)Module.Palo Verde will continue to monitor the CST temperature
at an increased frequency
until the CST temperature
design basis review is completed
and clearly documented.
This review will also include an assessment
of heat sources that affect the CST temperature
and an assessment
of the method of monitoring
condensate
storage tank bulk temperature.
3
Enclosure
2 Reply to Notice of Violation
EA-09-057 The Date When Full Compliance
Will Be Achieved Full compliance
was achieved on February 27, 2009, when procedures
40DP-90PA2, "Area 2 Operator Logs, Modes 1 -4," and 40OP-9ZZ1
4, "Feedwater
and Condensate," provided instructions
for increased
monitoring
and recording
of the local CST temperature
and actions to be taken if temperature
limits are approached.
4
}}

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