ML073120025

Correction to Audit of Licensee Regulatory Commitment Management Program

ML073120025
Person / Time
Site:	Palo Verde
Issue date:	11/13/2007
From:	Markley M NRC/NRR/ADRO/DORL/LPLIV
To:	Edington R Arizona Public Service Co
Markley, M T, NRR/DORL/LP4, 301-415-5723
References
TAC MD6157, TAC MD6158, TAC MD6159
Download: ML073120025 (7)

Text

November 13, 2007 Mr. Randall K. Edington Executive Vice President Nuclear/

Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

CORRECTION TO AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. MD6157, MD6158 AND MD6159)

Dear Mr. Edington:

On October 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) issued the report for its audit of the Arizona Public Service Company (APS) regulatory commitment management program for the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3. The NRC normally conducts an audit of a licensee=s regulatory commitment management program every 3 years. This audit was conducted at Palo Verde on July 31 and August 1, 2007, and the results were discussed on August 1, 2007, with Mr. Scott Bauer, APS Director of Regulatory Affairs, and other members of your staff.

Page 4 of the audit report incorrectly cited the APS Palo Verde Action Request (PVAR) No. as being 304663 when the actual document reference is PVAR No. 3046633. The language in the same sentence was also corrected to indicate that the licensee issued PVAR No. 3046633, rather than referring to it as a pending or planned action. These errors do not change the NRC staffs conclusions regarding the APS commitment management program. Enclosed is a corrected version of page 4 of the NRC audit report, with the corrections denoted by a vertical bar. Please discard the associated page from the previous audit report and replace it with the enclosed page.

If you have any questions, please call me at (301) 415-5723.

Sincerely,

/RA/

Michael T. Markley, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosure:

As stated cc w/encl: See next page

ML073120025 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME MMarkley JBurkhardt THiltz DATE 11/12/07 11/9//07 11/13/07 Palo Verde Nuclear Generating Station cc:

Mr. Steve Olea Mr. Matthew Benac Arizona Corporation Commission Assistant Vice President 1200 W. Washington Street Nuclear & Generation Services Phoenix, AZ 85007 El Paso Electric Company 340 East Palm Lane, Suite 310 Mr. Douglas Kent Porter Phoenix, AZ 85004 Senior Counsel Southern California Edison Company Mr. John Taylor Law Department, Generation Resources Public Service Company of New Mexico P.O. Box 800 2401 Aztec NE, MS Z110 Rosemead, CA 91770 Albuquerque, NM 87107-4224 Senior Resident Inspector Mr. Geoffrey M. Cook U.S. Nuclear Regulatory Commission Southern California Edison Company P.O. Box 40 5000 Pacific Coast Hwy Bldg D21 Buckeye, AZ 85326 San Clemente, CA 92672 Regional Administrator, Region IV Mr. Robert Henry U.S. Nuclear Regulatory Commission Salt River Project Harris Tower & Pavillion 6504 East Thomas Road 611 Ryan Plaza Drive, Suite 400 Scottsdale, AZ 85251 Arlington, TX 76011-8064 Mr. Jeffrey T. Weikert Chairman Assistant General Counsel Maricopa County Board of Supervisors El Paso Electric Company 301 W. Jefferson, 10th Floor Mail Location 167 Phoenix, AZ 85003 123 W. Mills El Paso, TX 79901 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency Mr. John Schumann 4814 South 40 Street Los Angeles Department of Water & Power Phoenix, AZ 85040 Southern California Public Power Authority P.O. Box 51111, Room 1255-C Mr. Scott Bauer, Director Los Angeles, CA 90051-0100 Regulatory Affairs Palo Verde Nuclear Generating Station Mr. Brian Almon Mail Station 7636 Public Utility Commission P.O. Box 52034 William B. Travis Building Phoenix, AZ 85072-2034 P.O. Box 13326 1701 North Congress Avenue Mr. Dwight C. Mims Austin, TX 78701-3326 Vice President Regulatory Affairs and Plant Improvement Ms. Karen O'Regan Palo Verde Nuclear Generating Station Environmental Program Manager Mail Station 7605 City of Phoenix P.O. Box 52034 Office of Environmental Programs Phoenix, AZ 85072-2034 200 West Washington Street Phoenix AZ 85003

ENCLOSURE CORRECTED PAGE 4 TO OCTOBER 31, 2007, NRC AUDIT REPORT FOR PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSEE REGULATORY COMMITMENT PROGRAM

safety issues pertinent to the associated commitment. The licensee issued Palo Verde Action Request (PVAR) No. 3046633 to reexamine the NRC-identified variances from NEI 99-04 and Palo Verde Procedure 93DP-0LC08.

2.3 Use of Regulatory Commitment Tracking System (RCTS)

Palo Verde Procedure 93DP-0LC08 states that a regulatory commitment is "[a]n explicit, written, docketed statement by PVNGS [Palo Verde] agreeing or volunteering to take specific action(s).

A regulatory commitment is an intentional undertaking by a licensee to (1) restore compliance with regulatory requirements, or (2) complete a specified action to address an NRC issue or concern (e.g., generic letter, bulletin, order, etc.). Regulatory Commitments will be clearly annotated as commitments in letters issued by PVNGS." Palo Verde Procedure 93DP-0LC08 requires commitments to be identified as Active Y or Active N in RCTS Regulatory Commitment Tracking System Action Item (RCTSAI).

• An Active Y commitment is an action which must be maintained in station documents to ensure continued compliance with the regulatory commitment.

Active Y commitments are maintained via the Site Work Management System (SWMS).

• An Active N is a one-time commitment. Active N commitments are maintained via the Administrative Control Process (work control).

The NRC reviewed a representative sample of both Active Y and Active N commitments to ensure that outputs associated with these licensing activities were complete, accurate, and timely. Although the RCTS is difficult to use, licensee personnel were knowledgeable of the system and were able to demonstrate the status of open and closed commitments, traceability of changes, and the actions leading to closure. During review with the NRC, licensee personnel had difficulty in finding two commitments because of data entry errors. The licensee was able to reconcile the errors during the course of the audit.

Based on the sample of commitments reviewed, the NRC concluded that the license had, when appropriate, provided written notification to NRC of changes to commitment schedules and that those changes were accurately reflected in the RCTS.

2.4 APS Self-Assessment of the Regulatory Commitment Management Program The NRC staff requested information from APS regarding any self-assessments performed on the regulatory commitment management program. The NRC staff learned that a self-assessment had been performed at Palo Verde on July 24-27, 2007. The self-assessment was performed by the APS regulatory affairs staff and issued on July 30, 2007, as SWMS Report No. 3043220. The self-assessment was intended as a snapshot or sample of the program and did not attempt to explore all program features. The self-assessment concluded that overall the commitment management program at Palo Verde was working and did not identify any significant deficiencies. The self-assessment determined that there was some ambiguous wording in commitment letters that impacted the scope of the RCTSAI documentation. The self-assessment also concluded that APS procedures establish sufficient process control and that