ML080320590
| ML080320590 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/01/2008 |
| From: | Caniano R Division of Reactor Safety IV |
| To: | Edington R Arizona Public Service Co |
| Shared Package | |
| ml080310447 | List: |
| References | |
| EA-08-003, IR-07-012 | |
| Download: ML080320590 (6) | |
See also: IR 05000528/2007012
Text
February 1, 2008
Randall K. Edington Senior Vice President, Nuclear Mail Station 7602
Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT: PALO VERDE NUCLEAR GENERATING STATION: INSPECTION REPORT 05000528/2007012, 05000529/2007012, AND 05000530/2007012; PRELIMINARY WHITE FINDING
Dear Mr. Edington:
This letter discusses a finding that appears to have low-to-moderate safety significance. As described in Section 5.7 of NRC Inspection Report 05000528/2007012, 05000529/2007012,
and 05000530/2007012, weaknesses in senior operators' ability to implement Emergency Action Level 1-7 (potential loss of the reactor coolant system barrier) were identified by Palo Verde Nuclear Generating Station during emergency response organization training for operators, and the weaknesses were not corrected in a timely manner appropriate to the significance of the knowledge deficiencies. Specifically, when evaluated during training
evolutions beginning in May 2007, a high percentage of senior operators incorrectly declared a general emergency for simulated plant conditions that would require only a site area emergency declaration, and corrective actions were not completed until October 2007.
The NRC determined that weaknesses associated with the senior operators' implementation of Emergency Action Level 1-7 were identified on or about May 2, 2007, during Licensed Operator Continuing Training, Cycle 3. Subsequently, the same weaknesses were observed during an initial license examination in July 2007, and again during the subject NRC inspection in October 2007. The NRC determined that the weaknesses were not entered into the Palo Verde Nuclear Generating Station's corrective action program until August 2007, and corrective actions to address the weaknesses for on-watch senior operators were not implemented until October 2007. The NRC determined that corrective actions were implemented to correct the
weaknesses of those senior operators and senior operator candidates whose implementation of Emergency Action Level 1-7 were specifically evaluated; however, actions to ensure the correct implementation of Emergency Action Level 1-7 by all on-shift senior operators were not performed in a timely manner when the weakness was identified (reference NRC Manual Chapter 0609, Appendix B, Section 5.0). UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4005
Randall K. Edington - 2 -
This finding was assessed based on the best available information, including influential assumptions, using the applicable significance determination process and was preliminarily determined to be a White finding. The final resolution of this finding will convey the increment in the importance to safety by assigning the corresponding color, i.e., (WHITE) a finding with some increased importance to safety, which may require additional NRC inspection. The finding has
a low-to-moderate safety significance because the identified senior operator performance weakness in implementing an emergency action level was associated with risk significant planning standard 10 CFR 50.47(b)(4). Part 50.47(b)(4) is a risk significant planning standard as described in Manual Chapter 0612, Appendix B, Section 2.0. The performance deficiency constituted a planning standard functional failure because Palo Verde Nuclear Generating
Station failed to correct a performance deficiency associated with a risk significant planning standard within a time appropriate to its significance.
The finding is also an apparent violation of NRC requirements 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, IV.F.2.g., and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is available on the NRC's Web site at www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The apparent violation and underlying performance deficiency was discussed during a conference call between Messrs. S. Bauer, Department Leader, Regulatory Affairs; E. O'Neil, Department Leader, Emergency Preparedness; and R. Lantz, Chief, Operations Branch, NRC Region IV, on January 9, 2008.
Before we make a final decision on this matter, we are providing you an opportunity, (1) to present to the NRC at a Regulatory Conference your perspectives on the facts and assumptions used by the NRC to arrive at the finding and its significance, or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within
30 days of the receipt of this letter and we encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. If a Regulatory Conference is held, it will be open for public observation. If you decide to submit only a written response, such submittal should be sent to the NRC within 30 days of receiving this letter.
Please contact Mr. Ryan E. Lantz, Chief, Operations Branch, Division of Reactor Safety, at (817) 860-8159, within 10 business days of the date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision, and you will be advised by separate correspondence
of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of apparent violations described in the subject inspection report may change as a result of further NRC review.
Randall K. Edington - 3 - In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site (the Public Electronic Reading Room).
Sincerely,
/RA/ Roy J. Caniano, Director
Division of Reactor Safety
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
Scott Bauer, Director Regulatory Affairs Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034
Randall K. Edington - 4 - Mr. Dwight C. Mims Vice President, 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
Eric J. Tharp Director of Generation Los Angeles Department of Water & Power
Southern California Public Power Authority P.O. Box 51111, Room 1255 Los Angeles, CA 90051-5700
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. D21 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
Karen O' Regan
Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003
Randall K. Edington - 5 - 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
Randall K. Edington - 6 - Electronic distribution by RIV: Regional Administrator (EEC) DRP Director (ATH) DRS Director (DDC) DRS Deputy Director (RJC1) Senior Resident Inspector (GXW2)
Branch Chief, DRP/D (TWP) Senior Project Engineer, DRP/D (GEW) Team Leader, DRP/TSS (CJP) RITS Coordinator (MSH3) M. Vasquez
V. Dricks W. Maier D. Starkey, OE N. Hilton, OE Mary Ann Ashley, NRR R. Kahler, NSIR K. Williams, NSIR
SUNSI Review Completed: ___Y___ADAMS: Yes No Initials: _REL_____ Publicly Available Non-Publicly Available Sensitive Non-Sensitive
S:DRS\reports\PV white letter.doc C:OB C:PBD NSIR ACES D:DRS RELantz/lmb TPruett KWilliams MVasquez RJCaniano /RA/ /RA/ /RA/ E /RA/ /RA/
1/15/08 1/17/08 1/28/08 1/25/08 1/29/08 / 2/1/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax