ML071720526

Confirmatory Action CAL-4-07-004 Letter Dated 6/21/07

ML071720526
Person / Time
Site:	Palo Verde
Issue date:	06/21/2007
From:	Mallett B Region 4 Administrator
To:	Edington R Arizona Public Service Co
References
CAL-4-07-004
Download: ML071720526 (8)

Text

June 21, 2007 CAL-4-07-004 Randall K. Edington, Senior Vice President, Nuclear Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

CONFIRMATORY ACTION LETTER

Dear Mr. Edington:

This letter is to confirm the initial actions and the approach to identify additional future actions that we agree are necessary to address performance problems at Palo Verde Nuclear Generating Station (PVNGS). Additional actions are expected to be identified during your self assessment activities and potentially in our supplemental inspection. As necessary, any additional actions will be incorporated in subsequent revisions to this confirmatory action letter.

In our Annual Assessment Letter dated March 2, 2007, we informed you that PVNGS Unit 3 was placed in the Multiple/Repetitive Degraded Cornerstone Column (Column IV) of the NRC's Action Matrix. In accordance with NRC Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program, this decision was made on the basis of two separate safety significant inspection findings (one Yellow and one White) in the Mitigating Systems cornerstone. The Yellow finding, open since the fourth quarter 2004, involved a significant section of containment sump safety injection piping that was void of water at all three PVNGS units. The White finding, open since the fourth quarter 2006, involved two failures of the Unit 3, Train A emergency diesel generator.

One of our actions in response to your entering Column IV will be to perform Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input. Since the root and contributing causes are programmatic and site-wide, the NRC is evaluating your correction of performance issues for the entire site. As discussed with you on June 6, 2007, during a public meeting conducted in Tonopah, Arizona, we understand that you are performing an in-depth evaluation of your performance deficiencies. In addition, we understand that you are modifying the existing performance improvement plan to sustain performance improvement initiatives currently ongoing until a comprehensive site integrated improvement plan can be developed and implemented. We have determined that enough information regarding your performance deficiencies is known from our inspections and your root cause evaluations to identify initial actions that can be agreed upon at this time to address performance problems at PVNGS.

Those actions were identified as a result of special inspections for the Yellow and White findings, and have been discussed in our mid cycle and annual assessment letters.

Arizona Public Service Company To address the performance problem areas that resulted in the entry into Column IV of the NRCs Action Matrix, Arizona Public Service Company will:

1. Complete actions to address root and contributing causes identified in your evaluations in response to the Yellow finding associated with the voided containment sump suction piping for all three units, and the White finding associated with the Unit 3 Train A emergency diesel generator electrical relay problems, including:

• Ineffective resolution of emerging technical issues, (e.g., thoroughness of evaluations, troubleshooting)

• Failure to routinely question the validity of engineering assumptions used to support operability decisions for degraded equipment

• Lack of consistently notifying operations personnel of immediate operability concerns

• Inadequate performance monitoring measures (e.g., metrics) necessary to fully assess the effectiveness of the corrective actions.

2. Complete corrective actions that will result in sustained improved performance in the crosscutting areas of human performance and problem identification and resolution. Specific areas to address are:

• PVNGS operability determination process

• Timeliness and thoroughness for evaluations of conditions/significant conditions adverse to quality

• Engineering quality

3. Complete an independent (third party) safety culture assessment by September 15, 2007.

4. Incorporate the results of your in-depth evaluations and your safety culture assessments described in Item 3 above into a modified improvement plan.

5. Submit the portions of the modified improvement plan that impacts the Reactor Safety strategic performance area, including safety culture improvement initiatives by November 30, 2007.

In our Annual Assessment Letter, we indicated that we would monitor your improvement efforts in addressing the substantive crosscutting issues through baseline inspections, and perform a detailed assessment following your notification to us of readiness for closure verification.

Instead, we have determined that it will be more efficient to address the substantive crosscutting issues within the IP 95003 supplemental inspection and followup process, since these issues are integral to the performance deficiencies being addressed by your staff. We plan to also address your corrective actions for the Yellow and White findings as part of our IP 95003 inspection.

IMC 0305 specifies that removal from Column IV will be governed by completion of the actions to address the specific findings which caused entry into Column IV. IMC 0305 also states that

Arizona Public Service Company the NRC may utilize some of the regulatory controls for Column IV for a period of up to one year following closeout of the specific findings in order to ensure the appropriate level of oversight of licensee improvement initiatives. Based on this manual chapter, we will conduct inspections to verify completion of the actions listed in this Confirmatory Action Letter and to determine their effectiveness in addressing performance issues.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:

1) Notify me immediately if your understanding differs from that set forth above;

2) Notify me if for any reason you cannot complete the actions within the specified schedule (Items 3 and 5) and advise me in writing of your modified schedule in advance of the change; and

3) Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.

This Confirmatory Action Letter provides the initial actions needed to address PVNGS performance problems. An update to this initial Confirmatory Action Letter will be issued to document any additional commitments that we agree are needed to effect the necessary performance improvements. We expect this update will occur after completion of our IP 95003 supplemental inspection.

Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and any response you provide will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted

Arizona Public Service Company copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Sincerely,

/RA/

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

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 Scott Bauer, Acting 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 51111, 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 Geoffrey M. Cook Southern California Edison Company 5000 Pacific Coast Hwy, Bldg. N50 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 & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052

Arizona Public Service Company Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRP Deputy Director (AXV)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (GXW2)

Branch Chief, DRP/D (NFO)

Senior Project Engineer, DRP/D (GEW)

Senior Project Engineer, DRP/D (RLN1)

Team Leader, DRP/TSS (CJP)

RITS Coordinator (MSH3)

J. Dyer (JED2)

E. Collins (EEC)

S. Richards (SAR)

J. Andersen (JWA)

C. Haney (CXH)

C. Carpenter (CAC)

D. Solorio (DLS2)

D. Starkey (DRS)

T. Hiltz (TGH)

M. Markley (MTM)

M. Tonacci (MET)

K. Fuller (KSF)

M. Vasquez (GMV)

V. Dricks (VLD)

W. Maier (WAM)

T. Pruett (TWP)

M. Kunowski (MAK3)

SUNSI Review Completed: NFO ADAMS: / Yes G No Initials: NFO

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