ML091210111

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

ML091210111
Person / Time
Site:	Palo Verde
Issue date:	04/20/2009
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05993-DCM/DFH, CAL-4-07-004, EA-09-057
Download: ML091210111 (7)

See also: IR 05000529/2009006

Text

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