ML073120025

Correction to Audit of Licensee Regulatory Commitment Management Program (TAC Nos. MD6157, MD6158 and MD6159)

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 staff's 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 Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007

Mr. Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770

Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 40 Buckeye, AZ 85326

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003

Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040

Mr. Scott Bauer, Director Regulatory Affairs Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034

Mr. Dwight C. Mims Vice President Regulatory Affairs and Plant Improvement Palo Verde Nuclear Generating Station Mail Station 7605 P.O. Box 52034 Phoenix, AZ 85072-2034

Mr. Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004

Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224

Mr. Geoffrey M. Cook Southern California Edison Company 5000 Pacific Coast Hwy Bldg D21 San Clemente, CA 92672

Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251

Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901

Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100

Mr. Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326

Ms. Karen O'Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 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 le tter, 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 demonstr ate 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