The team identified a Green non-cited violation of
10 CFR Part 50, Appendix B, Criterion XVI, for the licensees failure to document
conditions adverse to quality in the corrective action program. Previous similar failures to initiate condition reports led to, or contributed to, two
significant conditions adverse to quality over the last 15 months. The failure of the operations department to document identified
conditions adverse to quality in condition reports, as required by Procedure
01DP-0AP12, Condition Reporting Process, Revision 23, was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, on two other occasions since January 2015, failures by operations personnel to write condition reports for equipment-related problems resulted in or contributed to
significant conditions adverse to quality. This performance deficiency demonstrated a continued gap within Palo Verde Nuclear Generation Stations operations department in understanding condition report initiation criteria. This performance deficiency is associated with the
mitigating systems cornerstone. Using NRC
Inspection Manual Chapter 0609, Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not affect the operability or functionality of a mitigating structure, system, or component. This finding has a resolution cross-cutting aspect in the area of problem identification and resolution because the licensee failed to take effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).