ML062430661

Midcycle Performance Review and Inspection Plan - Palo Verde Nuclear Generating Station

ML062430661
Person / Time
Site:	Palo Verde
Issue date:	08/31/2006
From:	Mallett B Region 4 Administrator
To:	James M. Levine Arizona Public Service Co
References
Download: ML062430661 (9)

Text

UNITED STATES NUCLEAR REGULATORY C O M M I S S I O N REGION I V 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, TEXAS 76011-4005 August 31, 2006 James M. Levine, Executive Vice President, Generation Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PAL0 VERDE NUCLEAR GENERATING STATION On August 9, 2006, the NRC staff completed its performance review of Palo Verde Nuclear Generating Station for the first half of the calendar year 2006 assessment cycle. Our technical staff reviewed performance indicators (PIS)for the most recent quarter and inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility in order for you to inform us of any planned inspections that may conflict with your plant activities.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as Official Use Only - Security Related Information will include the physical protection review and resultant inspection plan.

Plant performance for the most recent quarter for all three units was within the Degraded Cornerstone column of the NRCs Action Matrix. This assessment is based on one Yellow finding, that has been open since the fourth quarter of 2004, in the Mitigating Systems Cornerstone involving a significant section of containment sump safety injection piping that was void of water at all three Palo Verde Nuclear Generating Station units.

Our March 2, 2006, annual assessment letter noted the results of the supplemental inspection that we conducted in 2005 in response to the Yellow finding. The NRC concluded that the Arizona Public Service Company had performed an adequate root cause evaluation of the design control violation associated with the Yellow finding; however, some of the corrective actions were narrowly focused, the implementation of some corrective actions had not been demonstrated to be fully effective at the time of this fall 2005 inspection, and monitoring criteria and reviews were not fully established to ensure that corrective actions were effective to prevent recurrence of risk significant performance issues. Consequently, we did not have assurance that your planned corrective actions were sufficient to address the causes for the Yellow finding.

In response to our request, the Arizona Public Service Company notified the NRC on April 15, 2006, of its readiness for the NRC to confirm through a followup 95002 supplemental inspection that the Arizona Public Service Company had completed the steps necessary to assure that the corrective actions are of sufficient scope to correct the performance deficiencies associated with the Yellow finding. An NRC inspection team conducted the onsite portion of the inspection the

Arizona Public Service Company week of July 24, 2006, and the results of the inspection will be documented in NRC Inspection Report 05000528; 05000529; 05000530/2006010. While it appears that the issues specifically associated with the voided emergency core cooling system piping have been effectively addressed, we have concluded that the corrective actions taken in response to the root causes and related programmatic concerns involving questioning attitude, technical rigor, and operability determinations have not been fully effective. Also, we have determined that the performance monitoring measures (e.g., metrics) necessary to fully assess the effectiveness of the corrective actions within these areas do not take into account all the relevant data.

In our annual assessment letter, dated March 2, 2005, our midcycle assessment letter, dated August 30, 2005, and our annual assessment letter, dated March 2, 2006, we advised you of substantive crosscutting issues in the areas of human performance and problem identification and resolution. The human performance area themes involved procedural compliance, procedural adequacy, and communications between engineering and operations personnel.

The problem identification and resolution area themes involved identification, evaluation, and effectiveness of corrective actions of nonconforming conditions. We continued to identify findings in both crosscutting areas, which are summarized below. You should also note that we have added to the characterization of these substantive crosscutting issues to address the most recent revision of NRC Manual Chapter 0305, Operating Reactor Assessment Program, dated June 22,2006.

During this assessment period, the NRC identified a total of 24 examples of Green findings with crosscutting aspects in the human performance area. These findings involved the Initiating Events, Mitigating Systems, and Occupational Radiation Safety cornerstones. Crosscutting themes were identified in the following area components: (1) Decision-making (instances of not utilizing a systematic decision making process and instances of ineffective communication of decisions to personnel), and (2) Work Practices (instances of ineffective human error prevention techniques and instances of not following procedures). Examples include: multiple instances of failing to comply with Technical Specification requirements during the process of unit startup; failures to perform technically adequate operability evaluations for degraded and nonconforming conditions of safety-related systems and components; instances of failing to follow procedures which resulted in consequential plant impacts; and instances of failing to use other appropriate error prevention techniques which resulted in inappropriate system configurations, as well as other unintended, consequential impacts on plant systems and components. The crosscutting themes identified during this assessment are similar to those that have been identified in previous NRC assessments, particularly with respect to the themes of failure to follow procedures and ineffective interactions between engineering and operations personnel when assessing degraded and nonconforming conditions.

Thirteen examples of Green findings and one Severity Level IV violation were identified in the corrective action component of the problem identification and resolution crosscutting area.

These findings involved the Initiating Events, Mitigating Systems, and Emergency Preparedness cornerstones. Crosscutting themes identified in this component involved inadequate evaluations of problems and untimely implementation of corrective actions.

Examples include: failures to address the extent of condition of problems; failures to fully evaluate problems resulting in repetitive or long-standing problems affecting safety systems and components; and failures to correct known degraded conditions in a timely manner. The

Arizona Public Service Company crosscutting themes identified during this assessment are similar to those that have been identified in previous NRC assessments, particularly with respect to inadequate evaluation of conditions adverse to quality, as well as inadequate and ineffective correction of problems.

During the assessment period, the NRC performed periodic inspections of your corrective actions to address both crosscutting areas. The results of our inspections show that you have taken some corrective actions to address these issues; however, these actions have not been completely effective, are still being developed, or are only partially implemented. In many cases, metrics and measures did not effectively monitor performance or performance trends.

This is the same performance status noted in our March 2, 2006, assessment letter.

Accordingly, we plan to continue to focus baseline inspections, as well as perform an additional problem identification and resolution inspection (as discussed in detail below), in order to assess your progress in implementing and verifying the effectiveness of your Integrated Improvement Plan as it relates to these two substantive crosscutting issues. The above crosscutting aspects will remain open until we determine that corrective actions implemented in accordance with your Integrated Improvement Plan have resulted in improved performance.

A meeting has been scheduled for September 7, 2006, in Arlington, Texas, to discuss your progress in implementing the actions within human performance and problem identification and resolution areas of your Integrated Improvement Plan, as well as corrective actions and performance measures for the root causes and related programmatic issues associated with the Yellow finding that relate to questioning attitude, technical rigor, and operability determinations. Other focus areas of the meeting will be a discussion of the status of corrective actions taken in response to your 2005 safety culture survey and initiatives to improve performance within operations.

The enclosed inspection plan details the inspections, including Temporary Instructions, except those related to physical protection, scheduled through March 31, 2008. In addition to the baseline inspections, NRC will be implementing Inspection Procedure 50001, Steam Generator Replacement Inspection, relative to the planned replacement of the Unit 3 steam generators.

As described in NRC Manual Chapter 0305, Operating Reactor Assessment Program, an additional problem identification and resolution inspection should be considered when facilities enter the Degraded Cornerstone column of the NRC Action Matrix. Because of a lack of sufficient progress in addressing both the substantive crosscutting issues and the conclusion of the March 2006 Problem Identification and Resolution Inspection that performance declined in this area, we plan to conduct an additional problem identification and resolution inspection in early 2007 to further evaluate the effectiveness of your corrective actions in resolving the substantive crosscutting issues.

The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the end-of-cycle review.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public

Arizona Public Service Company Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.ciov/readinq-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Troy W. Pruett at (817) 860-8173 with any questions you may have regarding this letter or the inspection plan.

SincereIy ,

Bruce S. Mallett Regional Administrator Dockets: 50-528 50-529 50-530 Licenses: NPF-41 NPF-51 NPF-74

Enclosure:

Palo Verde Inspection/Activity Plan cc w/

Enclosure:

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

Arizona Public Service Company Craig K. Seaman, General Manager 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 John W. Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51 111, Room 1255-C Los Angeles, CA 90051-0100 John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Thomas D. Champ Southern California Edison Company 5000 Pacific Coast Hwy, Bldg. D I B 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

Arizona Public Service Company 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 2% Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE,Suite 100 Atlanta, GA 30339

Arizona Public Service Company Electronic distribution by RIV:

Regional Administrator (BSMI)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJCI)

Senior Resident Inspector (GXW2)

Branch Chief, DRP/D (TWP)

Senior Project Engineer, DRP/D (GEW)

Team Leader, DRP/TSS (RLNI)

RlTS Coordinator (KEG)

V. Dricks, PA0 (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (JAC, ATG, LJS, MPSI)

B. Wetzel, Chief, TRPS, OED0 (BAW)

S. Richards, Deputy Director, DIRS, NRR (SAR)

C. Holden, Deputy Director, DORL, NRR (CFH)

C. Haney, Director, DORL, NRR (CXH)

D. Terao, Chief, LPLG, DORL, NRR (DXT)

M. Fields, NRR Project Manager (MBFI)

SUNS1 Review Completed: T W P - ADAMS: J Y e s 0 No Initials:-TWP J Publicly Available 0 Non-Publicly Available 0 Sensitive J Non-Sensitive OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

a m E m c m m m m

-mc .-

I 0

m e c C

.-0 C

0)

.-0 1

(0

.-0 c c c c

.-0 .-0 .-0 .-0 I - - -

a, c

m 0

a, a -m Q 0 a,

a 0

a, m

Q m 0

a, a

0 0 a a a a 0

m c u m a ,

0 a

ro - c c

-c m

a,

- c m

-mK -mC -mc -mC a, a, m (0

E LT -.-

a, a,

-a, -

a,

.- -E a

c a, a,a,a,a,

.E .E .E .E E S S T a,

m a m a, %m m a,

m m m m m m m m m m l?i m cn m m 0) m m m m m W 0 W b b b b

[D 0 W 0 W 0 0 W W 0

0 0

N 0

2 . .

0 N

a . .

0 N

0 N

0 N

0 2

0 0

N 0

0 N

0 0

N 0

0 N

m 0

Zi 0

ln 2

m 0

m 2

0 m

m 0

N N

m 0

T-7 m

N E?

Fs!

sisisisi 0 0 0 0 s isisisi 0 0 0 0 W W 0 W 0 W 0 W 0 W 0 W 0 b b b b 0

0 2

ln 0

2 r

0 N

0 2

0 N

m -. s 0

N 0 0

0 N N "

0 0

ZiZiZiZi 0

0 0 0

s s 6 7

Tt N 0 0 r  ? 2 2 2 2 c3 0 m

0 m

0 0

7 z zz;;z r m r m m "

N 9 -ae 0 I 0

N 0 V

LT -m 2El .-

c a,

0 2a, K .-

I W

2 m W .-

D (3

0 LT K

za,

-0 m

Y

m m m m m m m m 10 C C C m C C C C C C

.e .e .o c c c

.-0 .o .o .o .o .o c - c c -

.-0

..d 0 0 0 0 0 0 0 0 0 m m a , m m a l a , m a , m a , a J m a l a, a n a a  ? i = = = = = a a a a a a m

m m m m

-Cm w-C a-C, - -m m m m m m

.I! .I! .I! .o .o .o m m m m f f l

-C -C -C -C -C m a l a l a ,

-C a-E-E-E-E-E

.E .E- - .E -g

.- a a a a a a a a a a a a - -

.E - -

.E .E .E -2 .-F 3m 3m 3m 3 . . d - c c c c 3 3 x 3 3 m m m m m 3

m m m m 2 0 0 0 z z z z z z 0 0 0 m m m m m m b b b b 0 b b b b b b b b b m m m m m 03 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

N a s 3 G!G!e 0

N 0

N 0

N m

0 g g g 0 0 0 0 0

=;=;=$ZZ 0 0 0 0 0 0 0 0 0

N m

m m m G* ! G*! Ge! 7 - 7

?!

0 0 0 0 0 0 0 0 0 0 0 0 0 N 0

b 0

b 0

b 0 b 0 b 0

b 0

b 0

b 0

b 0

b 0

b b 0 0 0 b m m m m m m 0

0 0 0 0 0 0

2" m s s G

0

!e2 0

0 N

s 0

N 0 0 0 0

N s s 0

N 0

N s

0 N

0 N

0 0 0 N N N s s a a a o o o m m m 0 0 0 0 0

?!?!Q!?!?! .

0 N

Ln m m m a 0 0

• 0 S Z i = i = S i =

0 0 0 0 0 0 2

0 N r r d In r r r L

m m

m

.c m 0

Q C

s a,

0 h b z se G!

03 e

I I I 5

% 3%% J 9 9 k

J t

-C

.-0 m

0 z z E c

I , I , 0 N m 7 ~m z t

z c c c t-z z z k UC m

Y E

3 3 3 3 2 2 2 L

u

> n L w I I