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| issue date = 04/30/2008
| issue date = 04/30/2008
| title = IR 05000528-07-012, 05000529-07-012, and 05000530-07-012, Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Final Significance Determination for a Preliminary White Finding
| title = IR 05000528-07-012, 05000529-07-012, and 05000530-07-012, Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Final Significance Determination for a Preliminary White Finding
| author name = Caniano R C
| author name = Caniano R
| author affiliation = NRC/RGN-IV/DRS
| author affiliation = NRC/RGN-IV/DRS
| addressee name = Edington R K
| addressee name = Edington R
| addressee affiliation = Arizona Public Service Co
| addressee affiliation = Arizona Public Service Co
| docket = 05000528, 05000529, 05000530
| docket = 05000528, 05000529, 05000530
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:April 30, 2008
[[Issue date::April 30, 2008]]


EA-08-003 Randall K. Edington, Executive Vice President, Nuclear and 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 - NRC INSPECTION REPORT 05000528/2007012, 05000529/2007012, AND 05000530/2007012, FINAL SIGNIFICANCE DETERMINATION FOR A PRELIMINARY WHITE FINDING


SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC INSPECTION REPORT 05000528/2007012, 05000529/2007012, AND 05000530/2007012, FINAL SIGNIFICANCE DETERMINATION FOR A PRELIMINARY WHITE FINDING
==Dear Mr. Edington:==
The purpose of this letter is to provide you the final results of our significance determination of the preliminary White finding identified in the subject inspection report (ADAMS accession number ML080320562) and by letter dated February 1, 2008 (ADAMS accession number ML080320590). The inspection finding was preliminarily characterized as White (i.e., a finding with low to moderate increased importance to safety that may require additional U. S.
 
Nuclear Regulatory Commission (NRC) inspections) using Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process. This preliminary White finding, and associated apparent violation of NRC requirements, involved the failure of the Palo Verde Nuclear Generating Station personnel to correct an identified weakness in the performance of senior reactor operators. Specifically, when evaluated during training evolutions beginning in May 2007, a high percentage of senior operators incorrectly classified a general emergency for simulated plant conditions that required a site area emergency declaration, and corrective actions were not completed until October 2007.


==Dear Mr. Edington:==
At your request, a Regulatory Conference was held on March 25, 2008, to further discuss your views on this issue. A copy of the presentation you provided at this meeting is attached to the Regulatory Conference Meeting Summary dated April 10, 2008 (ADAMS accession number ML081020348). During the meeting, your staff described your assessment of the significance of the findings and detailed corrective actions to address the failure to correct the weakness in senior reactor operator performance. Specifically,  
The purpose of this letter is to provide you the final results of our significance determination of the preliminary White finding identified in the subject inspection report (ADAMS accession number ML080320562) and by letter dated February 1, 2008 (ADAMS accession number ML080320590). The inspection finding was preliminarily characterized as White (i.e., a finding with low to moderate increased importance to safety that may require additional U. S. Nuclear Regulatory Commission (NRC) inspections) using Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process." This preliminary White finding, and associated apparent violation of NRC requirements, involved the failure of the Palo Verde Nuclear Generating Station personnel to correct an identified weakness in the performance of senior reactor operators. Specifically, when evaluated during training evolutions beginning in May 2007, a high percentage of senior operators incorrectly classified a general emergency for simulated plant conditions that required a site area emergency declaration, and corrective actions were not completed until October 2007.


At your request, a Regulatory Conference was held on March 25, 2008, to further discuss your views on this issue. A copy of the presentation you provided at this meeting is attached to the Regulatory Conference Meeting Summary dated April 10, 2008 (ADAMS accession number ML081020348). During the meeting, your staff described your assessment of the significance of the findings and detailed corrective actions to address the failure to correct the weakness in senior reactor operator performance. Specifically, Arizona Public Service Company - 2 -  
UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 611 RYAN PLAZA DRIV E, SUITE 400 ARLINGTON, TEXAS 76011-4005
* You agreed that beginning on May 2, 2007, Palo Verde Nuclear Generating Station personnel identified a knowledge deficiency among senior operators regarding their evaluation of the reactor coolant fission product barrier and knowledge of the definition of 'prolonged release,' that the station corrective action program was not effectively used when the knowledge deficiency was identified, and that the knowledge deficiency was not corrected until October 25, 2007.


Arizona Public Service Company
- 2 -
*
You agreed that beginning on May 2, 2007, Palo Verde Nuclear Generating Station personnel identified a knowledge deficiency among senior operators regarding their evaluation of the reactor coolant fission product barrier and knowledge of the definition of prolonged release, that the station corrective action program was not effectively used when the knowledge deficiency was identified, and that the knowledge deficiency was not corrected until October 25, 2007.
* You discussed your analysis of the job performance measure that identified the knowledge deficiency, and concluded that the job performance measure was incomplete and technically flawed.
* You discussed your analysis of the job performance measure that identified the knowledge deficiency, and concluded that the job performance measure was incomplete and technically flawed.
* You discussed your view that the failure by Palo Verde Nuclear Generating Station personnel to promptly correct the identified knowledge deficiency had very low safety significance because the knowledge deficiency could not result in an incorrect emergency classification during an actual plant event involving a steam generator tube rupture and use of the atmospheric dump valves for reactor coolant temperature control.
* You discussed your view that the failure by Palo Verde Nuclear Generating Station personnel to promptly correct the identified knowledge deficiency had very low safety significance because the knowledge deficiency could not result in an incorrect emergency classification during an actual plant event involving a steam generator tube rupture and use of the atmospheric dump valves for reactor coolant temperature control.
* You discussed corrective actions that included requiring the operations training department to enter errors discovered in operator examination materials and operator failures on examinations and job performance measures into the corrective action program, initiating routine trending of weaknesses in operator performance during training, and requiring the concurrence of the emergency preparedness department on examinations and job performance measures used to test operator knowledge of emergency preparedness topics.
* You discussed corrective actions that included requiring the operations training department to enter errors discovered in operator examination materials and operator failures on examinations and job performance measures into the corrective action program, initiating routine trending of weaknesses in operator performance during training, and requiring the concurrence of the emergency preparedness department on examinations and job performance measures used to test operator knowledge of emergency preparedness topics.
* Following the conference you provided additional information (ADAMS accession number ML081130231), in response to our request, describing the simulator scenarios that formed the basis for your determination that the knowledge deficiency could not result in an incorrect classification during a steam generator tube rupture event.
* Following the conference you provided additional information (ADAMS accession number ML081130231), in response to our request, describing the simulator scenarios that formed the basis for your determination that the knowledge deficiency could not result in an incorrect classification during a steam generator tube rupture event.


After considering the information you provided during and following the conference, the NRC has concluded that the knowledge deficiency identified among senior operators would not likely result in an incorrect emergency classification during a steam generator tube rupture event.
After considering the information you provided during and following the conference, the NRC has concluded that the knowledge deficiency identified among senior operators would not likely result in an incorrect emergency classification during a steam generator tube rupture event.


Specifically, the NRC concluded that, given the identified knowledge weakness, an incorrect classification of a steam generator tube rupture event with atmospheric dump valves in operation can only occur with a concurrent potential loss of the fuel clad barrier, and that under these conditions all credible scenarios resulting in potential losses of the fuel clad barrier also cause loss of the reactor coolant barrier. The combination of a potential loss of the fuel clad barrier, loss of reactor coolant barrier, and the loss of containment barrier which results from operating the atmospheric dump valves, results in a general emergency condition, irrespective of the operator's knowledge of whether a prolonged release is occurring. The NRC has determined your analysis of steam generator tube rupture events reasonably bounds the possible scenarios leading to a potential loss of the fuel clad barrier.
Specifically, the NRC concluded that, given the identified knowledge weakness, an incorrect classification of a steam generator tube rupture event with atmospheric dump valves in operation can only occur with a concurrent potential loss of the fuel clad barrier, and that under these conditions all credible scenarios resulting in potential losses of the fuel clad barrier also cause loss of the reactor coolant barrier. The combination of a potential loss of the fuel clad barrier, loss of reactor coolant barrier, and the loss of containment barrier which results from operating the atmospheric dump valves, results in a general emergency condition, irrespective of the operators knowledge of whether a prolonged release is occurring. The NRC has determined your analysis of steam generator tube rupture events reasonably bounds the possible scenarios leading to a potential loss of the fuel clad barrier.
 
Arizona Public Service Company
- 3 -


Arizona Public Service Company - 3 -
Because the identified knowledge deficiency among senior operators would not likely result in an incorrect emergency classification during an actual plant event, the NRC has concluded the significance of the inspection finding is appropriately characterized as Green (i.e., a finding of very low safety significance).
Because the identified knowledge deficiency among senior operators would not likely result in an incorrect emergency classification during an actual plant event, the NRC has concluded the significance of the inspection finding is appropriately characterized as Green (i.e., a finding of very low safety significance).


The NRC has also determined the failure to correct an identified weakness in emergency preparedness performance with a promptness appropriate to its risk significance is a violation of 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, IV(F)(2)(g). The circumstances surrounding the violation are described in detail in the subject inspection report. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI of the NRC Enforcement Policy. Therefore, no response to this letter is necessary. However, if you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-001, with copies to; (1) the Regional Administrator, Region IV; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-001; and (3) the NRC Resident Inspector at Palo Verde.
The NRC has also determined the failure to correct an identified weakness in emergency preparedness performance with a promptness appropriate to its risk significance is a violation of 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, IV(F)(2)(g). The circumstances surrounding the violation are described in detail in the subject inspection report. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI of the NRC Enforcement Policy. Therefore, no response to this letter is necessary. However, if you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-001, with copies to; (1) the Regional Administrator, Region IV; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-001; and (3) the NRC Resident Inspector at Palo Verde.


In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made 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). 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.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 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.


Sincerely,/RA/
Sincerely,
Roy Caniano, Director Division of Reactor Safety Dockets: 50-528; 50-529; 50-530 Licenses: NPF-41; NPF-51; NPF-74
/RA/  


cc: Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007
Roy Caniano, Director


Arizona Public Service Company - 4 -
Division of Reactor Safety
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 Mr. Dwight C. Mims Vice President, Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7605 P.O. Box 52034 Phoenix, AZ 85072-2034  
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
 
Arizona Public Service Company
- 4 -
 
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  
 
Mr. Dwight C. Mims Vice President, Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7605 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  
Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901  
Line 65: Line 84:
Eric J. Tharp Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100  
Eric J. Tharp Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100  


Arizona Public Service Company - 5 -
Arizona Public Service Company  
James Ray 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  
- 5 -  
 
James Ray 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
 
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
- 6 -
 
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Greg.Warnick@nrc.gov)
Branch Chief, DRP/D (Michael.Hay@nrc.gov)
Senior Project Engineer, DRP/D (Greg.Werner@nrc.gov)
Senior Project Engineer, DRP/D (Geoff Miller@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
 
DISTRIBUTION:
via e-mail:
AHowell - ATH Fuller - KSF
 
C Maier - MCM1 Vasquez - GMV D Furst, NSIR Vegel - AXV
 
N Hilton, OE June Cai, OE Lantz - REL John Wray, OE
 
Warnick - GXW Coleman - PRC
 
Starkey, OE - DRS Mary Ann Ashley, NRR
 
M Burrell, OE Dricks - VLD


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 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
Wm Maier - WAM R Barnes, OE Robert Kahler


Arizona Public Service Company - 6 -
SUNSI Review Completed: __Yes___ ADAMS: U Yes G No Initials: __PJE__
Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov)
U Publicly Available G Non-Publicly Available G Sensitive U Non-Sensitive
DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (Greg.Warnick@nrc.gov) Branch Chief, DRP/D (Michael.Hay@nrc.gov) Senior Project Engineer, DRP/D (Greg.Werner@nrc.gov) Senior Project Engineer, DRP/D (Geoff Miller@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)
DISTRIBUTION: via e-mail: AHowell - ATH Fuller - KSF C Maier - MCM1 Vasquez - GMV D Furst, NSIR Vegel - AXV N Hilton, OE June Cai, OE Lantz - REL John Wray, OE Warnick - GXW Coleman - PRC Starkey, OE - DRS Mary Ann Ashley, NRR M Burrell, OE Dricks - VLD Wm Maier - WAM R Barnes, OE Robert Kahler


SUNSI Review Completed: __Yes___ ADAMS: Yes G No Initials: __PJE__ Publicly Available G Non-Publicly Available G Sensitive Non-Sensitive SEPI:OB ACES C:OB C:PBD OE ACES D:DRS PJElkmann/lmb MVasquez RELantz MHay JWray KFuller RJCaniano /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ 4/17/08 4/22/08 4/22/08 4/24/08 4/29/08 4/22/08 4/30/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
SEPI:OB ACES C:OB C:PBD OE ACES D:DRS PJElkmann/lmb MVasquez RELantz MHay JWray KFuller RJCaniano  
/RA/  
/RA/  
/RA/  
/RA/  
/RA/  
/RA/  
/RA/
4/17/08 4/22/08 4/22/08 4/24/08 4/29/08 4/22/08 4/30/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
}}
}}

Latest revision as of 16:56, 14 January 2025

IR 05000528-07-012, 05000529-07-012, and 05000530-07-012, Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Final Significance Determination for a Preliminary White Finding
ML081230561
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/30/2008
From: Caniano R
Division of Reactor Safety IV
To: Edington R
Arizona Public Service Co
References
EA-08-003 IR-07-012
Download: ML081230561 (6)
v • d • e


Text

April 30, 2008

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC INSPECTION REPORT 05000528/2007012, 05000529/2007012, AND 05000530/2007012, FINAL SIGNIFICANCE DETERMINATION FOR A PRELIMINARY WHITE FINDING

Dear Mr. Edington:

The purpose of this letter is to provide you the final results of our significance determination of the preliminary White finding identified in the subject inspection report (ADAMS accession number ML080320562) and by letter dated February 1, 2008 (ADAMS accession number ML080320590). The inspection finding was preliminarily characterized as White (i.e., a finding with low to moderate increased importance to safety that may require additional U. S.

Nuclear Regulatory Commission (NRC) inspections) using Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process. This preliminary White finding, and associated apparent violation of NRC requirements, involved the failure of the Palo Verde Nuclear Generating Station personnel to correct an identified weakness in the performance of senior reactor operators. Specifically, when evaluated during training evolutions beginning in May 2007, a high percentage of senior operators incorrectly classified a general emergency for simulated plant conditions that required a site area emergency declaration, and corrective actions were not completed until October 2007.

At your request, a Regulatory Conference was held on March 25, 2008, to further discuss your views on this issue. A copy of the presentation you provided at this meeting is attached to the Regulatory Conference Meeting Summary dated April 10, 2008 (ADAMS accession number ML081020348). During the meeting, your staff described your assessment of the significance of the findings and detailed corrective actions to address the failure to correct the weakness in senior reactor operator performance. Specifically,

UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 611 RYAN PLAZA DRIV E, SUITE 400 ARLINGTON, TEXAS 76011-4005

Arizona Public Service Company

- 2 -

You agreed that beginning on May 2, 2007, Palo Verde Nuclear Generating Station personnel identified a knowledge deficiency among senior operators regarding their evaluation of the reactor coolant fission product barrier and knowledge of the definition of prolonged release, that the station corrective action program was not effectively used when the knowledge deficiency was identified, and that the knowledge deficiency was not corrected until October 25, 2007.

  • You discussed your view that the failure by Palo Verde Nuclear Generating Station personnel to promptly correct the identified knowledge deficiency had very low safety significance because the knowledge deficiency could not result in an incorrect emergency classification during an actual plant event involving a steam generator tube rupture and use of the atmospheric dump valves for reactor coolant temperature control.
  • You discussed corrective actions that included requiring the operations training department to enter errors discovered in operator examination materials and operator failures on examinations and job performance measures into the corrective action program, initiating routine trending of weaknesses in operator performance during training, and requiring the concurrence of the emergency preparedness department on examinations and job performance measures used to test operator knowledge of emergency preparedness topics.
  • Following the conference you provided additional information (ADAMS accession number ML081130231), in response to our request, describing the simulator scenarios that formed the basis for your determination that the knowledge deficiency could not result in an incorrect classification during a steam generator tube rupture event.

After considering the information you provided during and following the conference, the NRC has concluded that the knowledge deficiency identified among senior operators would not likely result in an incorrect emergency classification during a steam generator tube rupture event.

Specifically, the NRC concluded that, given the identified knowledge weakness, an incorrect classification of a steam generator tube rupture event with atmospheric dump valves in operation can only occur with a concurrent potential loss of the fuel clad barrier, and that under these conditions all credible scenarios resulting in potential losses of the fuel clad barrier also cause loss of the reactor coolant barrier. The combination of a potential loss of the fuel clad barrier, loss of reactor coolant barrier, and the loss of containment barrier which results from operating the atmospheric dump valves, results in a general emergency condition, irrespective of the operators knowledge of whether a prolonged release is occurring. The NRC has determined your analysis of steam generator tube rupture events reasonably bounds the possible scenarios leading to a potential loss of the fuel clad barrier.

Arizona Public Service Company

- 3 -

Because the identified knowledge deficiency among senior operators would not likely result in an incorrect emergency classification during an actual plant event, the NRC has concluded the significance of the inspection finding is appropriately characterized as Green (i.e., a finding of very low safety significance).

The NRC has also determined the failure to correct an identified weakness in emergency preparedness performance with a promptness appropriate to its risk significance is a violation of 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, IV(F)(2)(g). The circumstances surrounding the violation are described in detail in the subject inspection report. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI of the NRC Enforcement Policy. Therefore, no response to this letter is necessary. However, if you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-001, with copies to; (1) the Regional Administrator, Region IV; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-001; and (3) the NRC Resident Inspector at Palo Verde.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 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.

Sincerely,

/RA/

Roy 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

Arizona Public Service Company

- 4 -

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

Mr. Dwight C. Mims Vice President, Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7605 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 Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100

Arizona Public Service Company

- 5 -

James Ray 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

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

- 6 -

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Greg.Warnick@nrc.gov)

Branch Chief, DRP/D (Michael.Hay@nrc.gov)

Senior Project Engineer, DRP/D (Greg.Werner@nrc.gov)

Senior Project Engineer, DRP/D (Geoff Miller@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

DISTRIBUTION:

via e-mail:

AHowell - ATH Fuller - KSF

C Maier - MCM1 Vasquez - GMV D Furst, NSIR Vegel - AXV

N Hilton, OE June Cai, OE Lantz - REL John Wray, OE

Warnick - GXW Coleman - PRC

Starkey, OE - DRS Mary Ann Ashley, NRR

M Burrell, OE Dricks - VLD

Wm Maier - WAM R Barnes, OE Robert Kahler

SUNSI Review Completed: __Yes___ ADAMS: U Yes G No Initials: __PJE__

U Publicly Available G Non-Publicly Available G Sensitive U Non-Sensitive

SEPI:OB ACES C:OB C:PBD OE ACES D:DRS PJElkmann/lmb MVasquez RELantz MHay JWray KFuller RJCaniano

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

4/17/08 4/22/08 4/22/08 4/24/08 4/29/08 4/22/08 4/30/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

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