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| document type = Letter, Licensee Response to Notice of Violation
| document type = Letter, Licensee Response to Notice of Violation
| page count = 7
| page count = 7
| project =
| stage = Other
}}
}}
See also: [[see also::IR 05000529/2009006]]


=Text=
=Text=
{{#Wiki_filter:10 CFR 2.201 EA-09-057 AA subsidiary
{{#Wiki_filter:10 CFR 2.201 EA-09-057 AA                     subsidiaryof Pinnacle West CapitalCorporation Dwight C. Mims                                                               Mail Station 7605 Palo Verde Nuclear      Vice President                                     Tel. 623-393-5403         P.O. Box 52034 Generating Station      Regulatory Affairs and Plant Improvement            Fax 623-393-6077         Phoenix, Arizona 85072-2034 102-05993-DCM/DFH April 20, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
of Pinnacle West Capital Corporation
 
Palo Verde Nuclear Generating
==Reference:==
Station Dwight C. Mims Vice President Regulatory
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
Affairs and Plant Improvement
 
Tel. 623-393-5403
==Subject:==
Fax 623-393-6077
Palo Verde Nuclear Generating Station (PVNGS)
Mail Station 7605 P.O. Box 52034 Phoenix, Arizona 85072-2034
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.
102-05993-DCM/DFH
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.
April 20, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory  
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
Commission
* Diablo Canyon       . Palo Verde
Washington, DC 20555-0001
* San Onofre   . South Texas
Reference:
* Wolf Creek
Palo Verde Nuclear Generating  
 
Station Units 1, 2 and 3 NRC Problem Identification  
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.
and Resolution, and Confirmatory  
Sincerely, DCM/REB/DFH
Action Letter (CAL-4-07-004)  
 
Follow-Up  
==Enclosures:==
Inspection  
: 1. Restatement of Violation EA-09-057
Reports 05000528/2009006, 05000529/2009006, 05000530/2009006, and Notice of Violation, dated March 20, 2009 Subject: Palo Verde Nuclear Generating  
: 2. Reply to Notice of Violation EA-09-057 cc:   E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall           NRC NRR Project Manager R. I. Treadway       NRC Senior Resident Inspector for PVNGS
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  
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:
letter to APS, the NRC identified  
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.
that APS failed to adequately
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.
translate  
This violation is associated with a Green Significance Determination Process finding.
design basis maximum condensate  
I
storage tank temperature  
 
requirements  
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.
into procedures  
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.
to ensure the plant is operated within its design basis.Pursuant to the requirements  
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.
of 10 CFR 2.201 and the March 20, 2009, Notice of Violation (NOV) EA-09-057  
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.
that was attached to the above referenced  
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.
letter, APS hereby submits its reply to the NOV. Enclosure  
1
1 to this letter contains a restatement  
 
of the violation.  
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.
Enclosure  
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.
2 contains APS' reply to the NOV.No commitments  
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.
are being made to the NRC by this letter A member of the STARS (Strategic  
The Corrective Steps That Will Be Taken To Avoid Further Violations
Teaming and Resource Sharing) Alliance Callaway -Comanche Peak * Diablo Canyon .Palo Verde * San Onofre .South Texas * Wolf Creek  
'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.
ATTN: Document Control Desk U.S. Nuclear Regulatory  
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.
Commission
These corrective actions included the following actions to address the accountability and ownership within the engineering department:
Reply to Notice of Violation  
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.
EA-09-057 Page 2 If you have any questions, please contact Ray Buzard, Regulatory  
2
Affairs, Compliance
 
Section Leader, at (623) 393-5317.Sincerely, DCM/REB/DFH
Enclosure 2 Reply to Notice of Violation EA-09-057
Enclosures:  
    " Communications were provided to site personnel to establish a clear understanding of the role of the Engineering Department as the design authority.
1. Restatement  
* 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.
of Violation  
    " 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.
EA-09-057 2. Reply to Notice of Violation  
    " 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.
EA-09-057 cc: E. E. Collins Jr.J. R. Hall R. I. Treadway NRC Region IV Regional Administrator
* 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.
NRC NRR Project Manager NRC Senior Resident Inspector
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)
for PVNGS  
Module.
Enclosure  
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.
1 Restatement  
3
of Notice of Violation  
 
EA-09-057 During an NRC inspection  
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.
conducted  
4}}
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
}}

Latest revision as of 07:30, 14 November 2019

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  Arizona Public Service icon.png
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)
v • d • e


Text

10 CFR 2.201 EA-09-057 AA subsidiaryof Pinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 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
  • 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. NRC Region IV Regional Administrator J. R. Hall NRC NRR Project Manager R. I. Treadway 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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