IR 05000528/2008002
| ML081430175 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/20/2008 |
| From: | Hay M NRC/RGN-IV/DRP/RPB-D |
| To: | Edington R Arizona Public Service Co |
| References | |
| IR-08-002 | |
| Download: ML081430175 (6) | |
Text
May 20, 2008
SUBJECT:
ERRATA FOR PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2008002, 05000529/2008002, AND 05000530/2008002
Dear Mr. Edington:
This errata corrects the decision basis for the significance determination for Noncited Violation 05000528; 05000529;05000530/2008002-04, "Failure To Maintain Adequate Staffing Levels Results in Heavy Use of Overtime to Maintain Adequate Shift Coverage," described in Section 4OA2 of the subject inspection report. Please replace page 4 of the Summary of Findings and page 30 of NRC Inspection Report 05000528/2008002, 05000529/2008002, and 05000530/2008008, dated May 9, 2008, with the enclosed revised pages. We regret any inconvenience this may have caused.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) 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), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
/RA/
Michael C. Hay, Chief
Projects Branch D
Division of Reactor Projects
UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125
Arizona Public Service Company
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Dockets:
50-528 50-529 50-530
Licenses:
cc w/Enclosure:
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
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
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
Arizona Public Service Company
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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
Arizona Public Service Company
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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)
Only inspection reports to the following:
J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)
P. Lougheed, OEDO RIV Coordinator (Patricia.Lougheed@nrc.gov)
ROPreports PV Site Secretary (Patricia.Coleman@nrc.gov)
SUNSI Review Completed: MCH ADAMS: / Yes No Initials: MCH__
/ Publicly Available Non-Publicly Available Sensitive / Non-Sensitive R:\\_REACTORS\\_PV\\2008\\PV2008-02Errata-GGW.doc ML0801430175 RIV:RI:DRP/D RI:DRP/D RI:DRP/D RI:DRP/D RI:DRP/D RI:DRP/D JHBashore MPCatts JFMelfi GGWarnick
RITreadway GBMiller
/RA/
/RA/
/RA/
/RA/ MCHay for /RA/ E-mailed /RA/
05/20/2008 05/19/2008 05/20/2008 05/20/2008 05/19/2008 05/192008 RI:DRP/E C:DRP/D
JEJosey MLHay
/RA/
/RA/
05/20/2008 05/19/2008
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
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Enclosure
and maintenance personnel failed to incorporate the adequate level of detail into their troubleshooting plans for the Unit 3 auxiliary feedwater trip and throttle Valve AFA-HV-0054 when it failed to fully close upon demand from the control room hand switch, and for the Unit 3 log power Channel A when induced noise was present. These issues were entered into the licensee's corrective action program as Palo Verde Action Requests 3120075 and 3118744.
This finding is greater than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Using the Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheets, the finding is determined to have very low safety significance because it did not represent a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. Both examples have a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not obtain appropriate interdisciplinary input and reviews on safety-significant or risk-significant decisions H.1(a). (Section 1R19)
- Green. The inspectors identified a noncited violation of Technical Specification 5.2.2.d involving the routine use of excessive overtime for operations personnel that performed safety-related functions. Specifically, between January 1 and December 31, 2007, operations personnel routinely used excessive overtime. This issue was entered into the licensees corrective action program as Condition Report/Disposition Request 3112231.
The finding is greater than minor because if left uncorrected the finding would become a more significant safety concern in that the routine use of excessive work hours increases the likelihood of operator errors. Using the Manual Chapter 0609, "Significance Determination Process," Appendix M, the finding is determined to have very low safety significance because there were no recent instances where findings of low to moderate (White) or greater significance were attributed to the increased use of overtime by operating personnel. The finding has a crosscutting aspect in the area of human performance associated with resources because the licensee failed to maintain sufficient qualified operations personnel to maintain working hours within guidelines without the excessive use of overtime H.2(b) (Section 4OA2).
- Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure of engineering personnel to ensure that potentially nonconforming conditions associated with the Class 1E 125 Vdc system were reviewed for operability.
Specifically, between September 29, 2007 and March 7, 2008, engineering personnel failed to ensure all relevant information was reviewed for operability when it was determined that vendor recommended preventative maintenance tasks were not being performed on the Class 1E 125 Vdc system. This issue was entered into the licensee's corrective action program as Palo Verde Action Request 3144707.
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Enclosure
2003 2004 2005 2006 2007 Control Room Supervisor 7.32 8.92 10.53 14.13 20.87 Reactor Operator 10.43 13.84 16.25 20.96 27.65 Shift Manager 8.81 10.29 12.12 17.51 20.28
Since 2003, overtime, as a percent of regular hours worked, has increased steadily and substantively for control room operators. The inspectors noted that the increase in overtime rates for operations department positions appeared to be largely the result of a decrease in staffing, rather than the result of an increase in the total number of person-hours expended. The inspectors also noted that the 2007 overtime rates were more than double the overtime rates of 2003.
During their review the inspectors noted that Technical Specification 5.2.2.d, Organization - Unit Staff, requires that administrative procedures shall be developed and implemented to limit the working hours of unit staff that perform safety-related functions, as well as requiring that the controls shall include guidelines on working hours that ensure adequate shift coverage shall be maintained without routine heavy use of overtime. Station procedure 01DP-9EM01, Overtime Limitations, Revision 6, is the licensees administrative procedure used to control unit staff working hours in accordance with facility Technical Specifications. Section 2.1 of this procedure requires that department leaders ensure that adequate shift coverage is maintained without the routine heavy use of overtime. The objective is to have personnel work a nominal 40-hour week while the plant is operating.
The inspectors determined that the licensee had several missed opportunities to identify this issue. Specifically, during their review the inspectors noted that the licensee had not been issuing and reviewing Technical Specification required excess overtime reports from approximately June 2006 through July 2007. The purpose of these reports was to facilitate identification of excess overtime usage by site management. However, due to changing computer software the reports were not generated and reviewed. Also, the inspector noted that several CRDRs written that identified the metric window for operations overtime were red for most of 2007. The inspectors determined that these were indicators of the use of excessive overtime and these indicators were missed by the licensee.
Analysis. The performance deficiency associated with this finding involved excessive routine use of heavy amounts of overtime for operations personnel that perform safety-related functions. The finding is greater than minor because if left uncorrected the finding would become a more significant safety concern in that the routine use of excessive work hours increases the likelihood of operator errors. Using the Manual Chapter 0609, "Significance Determination Process,"
Appendix M, the finding is determined to have very low safety significance because there were no recent instances where findings of low to moderate (White) or greater significance were attributed to the increased use of overtime by operating personnel. The finding has a crosscutting aspect in the area of human performance associated with resources because the licensee failed to maintain sufficient qualified operations personnel to maintain working hours within guidelines without heavy use of overtime H.2(b).