IR 05000528/2012007

IR 05000528-12-007, 05000529-12-007, 05000530-12-007; October 22 Through November 9, 2012; Palo Verde Nuclear Generating Station; Biennial Baseline Inspection of the Identification and Resolution of Problems.

ML12349A184
Person / Time
Site:	Palo Verde
Issue date:	12/13/2012
From:	Kellar R L Division of Reactor Safety IV
To:	Edington R K Arizona Public Service Co
References
IR-12-007
Download: ML12349A184 (19)

Text

December 13, 2012

Randal K. Edington, Executive Vice President, Nuclear/CNO Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000528/2012007, 05000529/2012007, AND 05000530/2012007

Dear Mr. Edington:

On November 9, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The enclosed report documents the inspection results, which were discussed on November 9, 2012, with Dwight Mims, Senior Vice President, Nuclear Regulatory and Oversight, and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification and resolution of problems, safety and compliance with the Commission's rules and regulations and with the conditions of your operating license. The team reviewed selected procedures and records, observed activities, and interviewed personnel. The team also interviewed a representative sample of personnel regarding the condition of your safety conscious work environment.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Palo Verde was effective. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were effectively prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were effectively implemented in a timely manner. Corrective actions were effectively implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate. Audits and self-assessments were generally used to identify problems and appropriate actions.

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) 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 at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety

Dockets: 05000528, 05000529, 05000530 Licenses: NPF-41, NPF-51, NPF-74 Enclosure: Inspection Report 05000528/2012007, 05000529/2012007 and 05000530/2012007 w/Attachments:

1. Supplemental Information 2. Information Request - August 22, 2012

SUMMARY

OF ISSUES

IR 05000528/2012007, 05000529/2012007, 05000530/2012007; October 22 through November 9, 2012; Palo Verde Nuclear Generating Station; "Biennial Baseline Inspection of the Identification and Resolution of Problems."

The inspection was conducted by a regional senior reactor inspector, two regional reactor inspectors, and a resident inspector. No findings of significance were identified during this inspection.

Identification and Resolution of Problems

The team reviewed approximately 300 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team found that licensee was generally effective at identifying problems and putting them into the corrective action program; however, there were a few instances identified during the assessment period where the licensee had missed identification of problems. The licensee was also generally effective in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions notwithstanding three instances identified early in the assessment period where the licensee failed to perform prompt operability assessments. These failures do not appear to represent current performance. The licensee's corrective action process was generally found to be effective in documenting and tracking problems to resolution although it was somewhat disjointed due to having a separate processes for documenting the identification, evaluation, and correcting problems. Corrective actions were generally implemented in a timely manner. Licensee audits and assessments were found to be effective and highlighted areas of ineffective corrective actions similar to weaknesses identified by the team. Operating experience usage was also found to be effective. Self assessment results adequately identified problems. On the basis of focus group interviews and an independent safety culture survey, workers at the site felt free to raise safety concerns using the corrective action program, their management and chain of command, and to the NRC without fear of retaliation.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on a sample of the corrective action documents that were initiated in the assessment period, which ranged from December 17, 2010, to the end of the on-site portion of the inspection on November 9, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 300 Palo Verde Action Requests (PVARs), Condition Report/Disposition Requests (CRDRs), and Condition Report Action Items (CRAIs) and associated root cause, apparent cause, and direct cause evaluations, that had been issued between December 2010 and November 2012 to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Concerns enter the licensee's corrective action process as a PVAR which include all manner of issues and concerns, both safety-related and non-safety-related. During the assessment per iod, the licensee init iated 50,492 PVARs of which 11,314 or approximately 22% were classified as conditions adverse to quality.

The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team evaluated the licensee's efforts in establishing the scope of problems by reviewing selected logs, work requests, self-assessments results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed work requests and attended the licensee's daily management review committee meetings - Condition Review Group (CRG) to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observing the interfaces with the operability assessment and work control processes when applicable. The team's review included verifying the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems. The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action

program. The team also reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective action addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate

and timely.

The team considered risk insights from both the NRC's and Palo Verde's risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the following risk significant systems: essential chill water, emergency diesel generator, safety and non-safety related inverters, and emergency core cooling pumps. The samples reviewed by the team focused on, but were not limited to, these systems. The team also expanded their review to include five years of evaluations involving the essential chill water system to determine whether problems were being effectively addressed. The team conducted a walkdown of this system to assess whether problems were identified and entered into the corrective action program.

b.

Assessments 1. Assessment - Effectiveness of Problem Identification The team concluded that the licensee identified issues and adverse conditions in accordance with the licensee's corrective action program guidance and NRC requirements. The team noted that licensee personnel had a very low threshold for entering issues into PVARs (corrective action program) as evidenced by the more than 50 thousand PVARs issued during the two year review cycle. While there were three findings identified during the assessment period and two similar observations during the inspection in which the licensee had failed to identify conditions adverse to quality, the team concluded that the license was generally identifying problems at a low threshold.

These examples include:

• The licensee failed to identify a weakness during a biennial exercise (non-cited violation 2011003-04) in that the Technical Support Center did not understand the radiological release path and had developed ineffective mitigation strategies based on their inaccurate understanding. The licensee failed to identify a performance issue completely and accurately.

• The licensee failed to promptly identify and correct a condition adverse to quality (non-cited violation 2012002-05) in that more frequent biocide additions to the essential chilled water systems resulted in significant bacterial off gassing and voiding in the systems in all three units. The licensee failed to trend and assess information from the corrective action program and other assessments to identify this common cause problem.

• The licensee failed to follow corrective action program procedures (non-cited violation 2012002-01) to generate a Palo Verde Action Request when significant delays in completing maintenance on safety related components occurred.

• Two additional examples were identified during the inspection where the licensee failed to initiate a PVAR contrary to Procedure 01PR0AP04. These examples included failing to document the failure of an essential chill water chiller to load in October 2012 and failing to document problems identified with the bench setup for calibrating an inverter circuit board. In both cases, the licensee had been investigating other conditions adverse to quality. Once identified by the NRC, the licensee documented these in their corrective action program as PVARS. These examples were considered to be minor because the failures to document these conditions did not result in any safety consequences. These failures to comply with Procedure 01PR0AP04 constitute minor violations that are not subject to enforcement action in accordance with the NRC's Enforcement Policy.

2.

Assessment - Effectiveness of Prioritization and Evaluation of Issues The team concluded that the licensee was generally effective in the prioritization and evaluation of conditions adverse to quality dur ing this assessment period. The team reviewed corrective action documents that involved operability reviews to assess the quality, timeliness, and prioritization of operability assessments. While the team noted three findings had been documented during the assessment period where the licensee had failed to promptly evaluate the operability of safety-related systems with identified deficiencies, these findings were identified during the first part of the assessment period and no additional findings were identified during the inspection. The team concluded that operability assessments were generally completed in an appropriate manner.

• The licensee failed to promptly evaluate the operability of the essential chill water system (non-cited violation 2011004-02) after identifying gas voids in the system.

• The licensee failed to promptly evaluate the operability of the diesel fuel oil transfer system (non-cited violation 2011003-02) following identification that the system leakage test method did not conform to ASME Code Section XI testing requirements.

• The licensee failed to promptly evaluate the operability of safety-related structures, systems and components (non-cited violation 2011002-02) following discovery of a degraded and nonconforming condition associated with a potential manufacturing defect in K-600S 480 VAC Class 1E circuit breakers. The team monitored the licensee's action request review committee and the corrective action review board. The team found that the licensee was effectively reviewing and prioritizing conditions adverse to quality.

3.

Assessment - Effectiveness of Corrective Action Program Overall, the team concluded that the licensee had an effective corrective action program where conditions adverse to quality were promptly identified, prioritized, evaluated, and corrected in a timely manner commensurate to safety significance. The team noted that the licensee's corrective action process was somewhat disjointed due to having a separate processes and numbering systems for documenting the identification, the evaluation, and the correction of problems. The team noted that the licensee had made notable progress in reducing the backlog of issues and reducing the average time to address condition reports.

Over the assessment period, several findings were documented associated with the adequacy of the corrective action program although the team concluded that this was not indicative of program weaknesses. Some of the findings include:

• The licensee failed to promptly correct a condition adverse to quality (non-cited violation 2010005-04) in that between July 2008 and November 2010, corrective actions for high vibrations in the Unit 3 essential cooling water system train A room cooler blower failed to promptly address the incorrect shaft dimensions at the bearing shaft interface.

• The licensee failed to perform functionality assessment for safety-related buildings (non-cited violation 2012002-07) after identifying a potential for insufficient drainage for safety related building roofs and failed to assess the non-conforming condition with the current licensing basis.

• The licensee failed to promptly identify and correct a condition adverse to quality (non-cited violation 2011004-03) associated with an inadequate plant operating procedure used to operate the essential chiller at low load conditions. As a result, the chiller was declared inoperable six times between July 27, 2011, and September 5, 2011.

• The licensee failed to correct and prevent recurrence of a significant condition adverse to quality (violation 2010008-01) associated with the Emergency Diesel Generator Fuel Oil Transfer Pumps. Specifically, from April 2009 to September 2010, the licensee failed to correct a water intrusion path to the motor termination box for the Unit 2 emergency diesel generator fuel oil transfer pumps, resulting in degraded electrical connections.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self assessments. A sample size of 12 operating experience notifications that had been issued during the assessment period were reviewed to assess whether the licensee had appropriately evaluated the notification for relevance to the facility. The team then examined whether the licensee had entered those items into their corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry-operating experience.

b. Assessment Overall, the team determined that the licensee was adequately evaluating industry operating experience for relevance to the facility. The licensee had generally entered applicable items in the corrective action program in accordance with station procedures. However, during the assessment period, findings were documented associated with the licensee's inadequate incorporation of operating experience (both internal and external). These include:

• Failure of reactor coolant pump motor junction box (finding 2011005-03) due to inadequate work instructions. As a result, water leakage from an open nuclear cooling system vent valve entered the enclosure, resulting in a ground fault on the energized electrical conductors, explosion, and subsequent declaration of an Unusual Event. While the licensee had previous experience with water penetration in electrical enclosures following maintenance, this operating experience had not been incorporated into revised work instructions.

• The licensee failed to promptly identify and correct a condition adverse to quality (non-cited violation 2011004-03) associated with an inadequate plant operating procedure used to operate the essential chiller at low load conditions. As a result, the chiller was declared inoperable six times between July 27, 2011, and September 5, 2011, due to low oil level caused by oil migration into the refrigerant, a known phenomenon that occurs during low load conditions.

• The licensee failed to adequately classify and evaluate conditions adverse to quality (non-cited violation 2011004-01) involving the installation of an automatic voltage regulator card in an emergency diesel generator that was potentially defective and had been previously reported under Part 21.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of five licensee self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self- and third party assessments, the role of the quality assurance department, and the role of the performance improvement group related to licensee performance. The specific self-assessment documents reviewed are listed in the Attachment.

b. Assessment The team found that the internal self-assessments and audits were generally thorough, detailed, indepth and critical. The team found that the effectiveness of corrective actions initiated to address self-assessment findings was not always effective. The licensee acknowledged that they had also identified this and had initiated actions to perform effectiveness reviews for self-assessment corrective actions earlier this year. The team acknowledged this and concluded that it there was insufficient data to assess whether the licensee's effectiveness reviews would reduce the number of repeat findings documented.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team conducted five focus group interviews with typically 8 - 10 individuals per group.

The focus groups consisted of workers from operations, security, engineering, instrumentation and controls, and health physics. Individuals were randomly selected to assure representative outcomes for the interviews. The inspection team also conducted individual interviews. The interviewees represented various functional organizations and ranged across staff, and supervisor levels. The team conducted these interviews to assess whether conditions existed that would challenge the establishment of a safety conscious work environment at Palo Verde Nuclear Generating Station. The team also reviewed the most recent safety culture survey results conducted by an independent organization in 2010.

b. Assessment Based upon the results of these interviews and survey results, the team concluded that the licensee had established a safety-conscious work environment where individuals felt free to raise safety concerns both to the lic ensee and the NRC without fear of retaliation. None of the individuals interviewed knew of anyone who had suffered retaliation for having raised safety concerns and all indicated that they felt comfortable raising safety concern to their supervisor, the corrective actions program, to the employee concerns program, to the NRC, or using their chain of command although they indicated that they had not had the need to raise concerns beyond their supervisor or the corrective action program. Responses to questions and topics during the focus group sessions did not reveal any sense that safety was not the highest priority. All organizations indicated that the work environment had changes significantly over the past several years.

.5 Specific Issues Identified During This Inspection

None

4OA6 Meetings

Exit Meeting Summary

On November 9, 2012, the team presented the inspection results to Dwight Mims, Senior Vice President, Nuclear Regulatory and Oversight, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

None

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Amoroso Electrical Instrumentation and Controls Section Leader

G. Andrews Assistant Plant Manager

G. Archambault Information Technology Supervisor R. Barnes Director, Nuclear Regulatory Affairs R. Bramlett Security Programs

M. Brannin ISI Program Manager

C. Coles Nuclear Security Division

D. Coxon Operations Department Leader B. Doyle Senior Engineer E. Dutton Director, Nuclear Assurance

D. Elkinton Regulatory Affairs Consult Sr.

M. Fladager Department Leader Work Management

C. Goff Nuclear Section Leader D. Harrison Maintenance Section Leader A. Hartwig Electrical I&C Design Engineering Department Leader

M. Heider Department Lead PM Program

B. Kershaw Engineering Cause Analysis

K. Keyes Coordinator Senior

D. Leech Section Leader Nuclear Assurance B. Logue IT Manager N. Lossing Electrical Engineering Section Leader

R. Maner Senior Consulting Instrumentation and Controls Engineer

M. McGhee Manager Operations Support

L. McKinney Security Operations F. Oreshack Regulatory Affairs Consultant J. Rodriguez Engineer III

L. Sewell Site Rigging Material Coordinator

J. Skrtch Department Leader Work Management

C. Smith Auxiliary Equipment Operator

J. Sontchi Department Leader Nuclear Training B. Thiele Program Engineering Department Leader T. Tidyman PM Program Project Manager

D. Wheeler Acting Director, Performance Improvement

R. Wilferd Department Leader Nuclear Engineering

G. Zuniga Maintenance Team Leader

NRC Personnel

T. Brown Senior Resident Inspector

M. Baquera Resident Inspector

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

Procedures

NUMBER TITLE REVISION

40DP-9OPA4, App. B Area 4 Operator Logs, Modes 1-4 105 40DP-9OP06, App.

ZZ058 Quarterly Priority Work Aggregate Review 117 51DP-9OM09 Outage Planning and Implementation 15 40DP-9OP15 Operator Challenges and Discrepancy Tracking 26 40DP-9WP01, App. C Operating Processing of Work Orders 24 51DP-9OM03 Site Scheduling 27 01DP-0AP16 PVNGS Self-Assessment and Benchmarking 8 60DP-0QQ19 Internal Audits 23

60DP-0QQ25-01 Conduct of Nuclear Assurance Department 2 60DP-0QQ25 Nuclear Assurance Assessments 3 32MT-9ZZ58 Preventive Maintenance of Elgar Inverters 31 01DP-0AP12 Palo Verde Action Request Processing 17 90DP-0IP12 Root Cause CRDR Evaluation 10 73TI-0ZZ02 Ultrasonic Thickness Measurement 10

Attachment 1

Calculations

13-A-ZZD-002, Sh. 2

Typ. Penetration Seal Details Blockouts, Core Drills, and Pipe Sleeves

13-AC-ZZ-0200 Penetration Seal Qualifications 13

Drawings

02-E-PNA-001 Single Line Diagram 120V AC Class 1E Power System Ungrounded Vital Instr and Control Distr Panels 2E-PNA-D25 & 2E-PNC-D27

02-M-DFP-001 P & I Diagram Diesel Fuel Oil and Transfer System 10

Vendor Manuals Number Title Revision

VTD-E062-009 Yale Trolleys Operating and maintenance Instructions with Illustrated parts list for trolley Models FLP, FLG, FTP, and

FTG [PUB # 511]

Miscellaneous Documents

Number Title Revision/Date4145790 Permanent Intercom Communication Elevated Security Post 5/4/2012

ER 12-0016 Nuclear Assurance Evaluation Report on Security Programs 8/17/2012

3763945 Engineering Evaluation of EDG Overflow Piping Testing Methods 6/24/2011 12-0599 Ultrasonic Thickness Examination Report for Diesel Fuel Transfer System 'A' supply Line A-005-HBCB-2-inch

8/22/2012 12-0452 Ultrasonic Thickness Examination Report for Diesel Fuel Transfer System 'B' supply Line B-024-HBCB-2-inch

5/16/2012 11-UT-2101 Ultrasonic Thickness Examination Report for 2PDFAV012

2-inch Diesel Fuel Line DFAL002 at Day Tank

6/30/2012 11-UT-2102 Ultrasonic Thickness Examination Report for 2-inch Diesel Fuel Line DFBL026 at Day Tank

7/5/2011 12-VT-3001 Pressure Test Report Diesel Fuel Transfer System 'A' supply Line Level Drop

DF-02

2/16/2012 12-VT-3002 Pressure Test Report Diesel Fuel Transfer System 'B' supply Line Level Drop

DF-05

2/16/2012

Attachment 1

Number Title Revision/Date12-VT-3016 Diesel Fuel Transfer system "A" Train Overflow Flow Verification Test Unit 3

3/9/2012 12-VT-3118 Diesel Fuel Transfer system "A" Train Overflow Flow Verification Test Unit 3

4/3/2012 11-VT-2173 Flow Verification Test of the Buried Portions of the diesel Fuel Oil Overflow Line to the diesel fuel Oil Storage Tank (A

Train) Unit 2

7/15/2011 11-VT-2174 Flow Verification Test of the Buried Portions of the diesel Fuel Oil Overflow Line to the diesel fuel Oil Storage Tank (B

Train) Unit 2

7/15/2011 11-VT-1132 Diesel Fuel Transfer system "A" Train Overflow Flow Verification Test Unit 1

2/7/2011 12-VT-1004 Diesel Fuel Transfer system "B" Train Overflow Flow Verification Test (DF-06) Unit 1

5/16/2012 11-0375 Ultrasonic Thickness Examination Report on 2-inch Diesel Fuel Lines DFAL002 and DFB026 at Day Tank Units 1,2, and 3 4/20/2011 11-0388 Ultrasonic Thickness Examination Report on 2-inch Diesel Fuel Lines DFAL002 and DFB026 at Day Tank Units 1,2, and 3 4/21/2011

3763945 Engineering Evaluation Regarding Testing of Buried Diesel Fuel Oil Piping

6/1/2011

PVNGS Master Assessment Plan - Operations PVNGS Master Assessment Plan - Corrective Action Condition Review Group meeting agenda 10/25/2012

Corrective Action Review Board meeting agenda 10/25/2012

Audits Number Title 2011-004 NAD Audit Report Nuclear Security 2011-010 Operations and Degraded/Non Conforming Audit 2012-004 Maintenance Audit

2012-010 Corrective Action Program 2010 Safety Culture Survey

Attachment 1

Work Orders

(WO)

3573217

3572228

3312923

3959799

3535025

2850830

4128257

4162709

Incidence Reports

INC09792 INC306404 INC316134 INC286757 INC316520 INC315296 INC293369 INC281707 INC288175 INC316721 INC317066 INC279887 INC276773 INC284091 INC321058 INC303342 INC322203 INC276773 INC316134

Palo Verde Action Requests (PVAR)

3704003

4275176

3660716

3654452

3705424

3705284

3705318

3705478

3705489

3705505

3677707

3705132

3705152

3705172

3705284

3705393

3705424

3705446

3705454

3705456

3706396

3571177

3705298

3705459

3705393

3705496

3705318

4033786

4228815

4233603

3387296

3616634

4036588

3898992

3573545

3573544

3908285

3938265

3946610

3950845

3953126

3970833

4180923

4178313

4001814

4182880

4182845

4182632

4186998

4187546

3898992

4201237

4201352

4204672

4208153

211941

4218303

4221416

4224574

4225972

4232724

4232731

4234430

4238443

4243930

4243931

4243932

4250651

4285984

4285537

285465

3565114

3570167

3564783

3564829

3566562

3567098

3567530

3570411

3824036

4271937

4272800

4274318

4274390

4284547

274568

4277934

4280932

4214180

4162692

4274178

4272955

4272902

4284621

4284380

Attachment 1

Condition Report

Action Items (CRAI)

3783518

3783519

3707775

3783521

3783535

3873648

3742872

3743859

3743860

3743861

3706679

3783536

3743862

4039661

3574521

3980229

3952235

3574515

4189979

4230038

4247010

3696643

3696692

3697136

3697192

3697212

3697232

3703313

4042815

3573522

23552

4216265

Condition Report

Disposition Requests (CRDR)

202639

3660716

3706679

3706691

3706716

3709557

3706668

3706669

3703707

3706712

3706672

3706753

3706676

3706714

3706682

3706683

3706684

3706724

3706722

3706688

4039660

4042815

3616634

3905265

3573504

3573232

3574514

3574518

3787750

3917689

28245

3929016

3932992

3946693

3948593

3952234

3956931

3973259

3973259

4003718

4015434

4180550

4181960

4184976

4185860

4185944

4189978

4194984

4195338

4202639

2712378

3584689

3680383

3742118

3783748

3805134

3845137

3874528

4116970

4078014

3571530

4113175

4136342

4205029

4164802

4215702

4190788

4200926

Attachment 2

Information Request August 22, 2012

Biennial Problem Identification and Resolution Inspection -

Palo Verde Nuclear Generating Station Inspection Report Number 05000528/529/530-2012007

This inspection will cover the period from December 17, 2010, to October 13, 2012.

All requested information should be limited to this period unless otherwise specified.

To the extent possible, the requested information should be provided electronically in Adobe PDF or Microsoft Office format.

Lists of documents should be provided in Microsoft Excel or a similar sort-able format.

Please provide the information on a compact disc (one for each team member), if possible.

Please provide the following no later than September 28, 2012:

1. Copies of the corporate and site level procedures and sub-tier procedures associated with the corrective action program. This should include procedures related to:

a. Corrective action process; b. Operating experience program; c. Employee concerns program;

d. Self-assessment program;

e. Maintenance rule program and implementing procedures;

f. Operability determination process;

g. Degraded/non-conforming condition process (e.g.,

RIS 2005-20); h. System Health process or equivalent equipment reliability improvement programs; i. Operational Decision Making (ODMI) process.

2. Scheduled date/time/location of all meetings associated with implementation of the corrective action program, such as screening meetings, corrective action review board meetings, etc.

3. List of all condition report disposition request (CRDR) generated sorted by priority, with the following information: number; priority; title/description; date initiated; and status (open or closed). The CRDRs should be grouped by the initiating department (operations, maintenance, engineering, radiation protection, emergency preparedness, and security).

4. Listing of the total number of CRDRs generated annually, sorted by the above departments.

5. A copy of all root, apparent, and common cause evaluations.

6. A list of CRDRs generated as a result of identified trends. The list should be sorted by priority and have the following information: number, title/description, date initiated, status and initiating department.

7. A list of outstanding corrective actions, sorted by priority, with a title/description, initiating date and due date. Please also identify and list any associated due date extensions.

8. List of control room deficiencies and operator work-arounds, sorted by priority, with a brief description and corresponding CRDR and/or work order number.

Attachment 2

9. A chronological list of all nuclear Quality Assurance/Nuclear Oversight audits and department/station self-assessments.

10. A copy of all system health reports.

11. All assessments or evaluations (internal or external) regarding station or department safety-culture.

2. A list of all operability determinations and ODMIs performed with the following information: date initiated, initiating IR and status (open or closed).

13. A list of maintenance preventable functional failures (MPFFs) of risk-significant systems (include actions completed and current status).

A list of current Maintenance Rule a(1) systems and a list of those systems that entered a(1) within the last two years, but which were returned to a(2) status.

Include a copy of the current system health report for those

systems now in a(1).

14. Copy of the latest corrective action program statistics such as the number initiated by department, human performance errors by department, backlog, corrective action timeliness and others as may be available.

15. Any performance indicators associated with backlog of corrective maintenance items.

16. List of industry operating experience evaluated by the site. Additionally, list of all NRC generic communications (information notices, generic letters, etc.) evaluated by the site for applicability to the station regardless of the determination of applicability.

17. A list of condition reports where the NRC wa

s the identifying organizat ion. This list should include non-cited and minor violations, and findings, regardless of whether there was an associated violation. Please provide the IR number, title, date initiated and status.

18. A chronological list of all Licensee Event Reports, with a brief description of the affected components or systems.

19. A listing of the top 10 risk-significant systems, components, and operator manual actions.

This information may be uploaded on the Certrec IMS website; however, CDs or DVDs are still requested and should be sent via overnight carrier to:

U.S. NRC Region IV

1600 E. Lamar Blvd. Arlington,

TX 76011-4511

Attention: Harry Freeman

A supplemental information request will likely be sent during the week of October 8, 2012.

Please note that the NRC is not currently able to accept electronic documents on thumb drives or other similar digital media.