IR 05000528/2018002

NRC Integrated Inspection Report 05000528/2018002, 05000529/2018002, and 05000530/2018002

ML18218A583
Person / Time
Site:	Palo Verde
Issue date:	08/06/2018
From:	O'Keefe N NRC/RGN-IV/DRP
To:	Bement R Arizona Public Service Co
References
IR 2018002
Download: ML18218A583 (53)

Text

ust 6, 2018

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2018002, 05000529/2018002, AND 05000530/2018002

Dear Mr. Bement:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On July 12, 2018, the NRC inspectors discussed the results of this inspection with Ms. M. Lacal, Senior Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented three findings of very low safety significance (Green) in this report.

These findings involved violations of NRC requirements. The NRC is treating these violation as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Palo Verde Nuclear Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Neil OKeefe, Branch Chief Project Branch D Division of Reactor Projects Docket Nos. 50-528, 50-529, and 50-530 License Nos. NPF-41, NPF-51, and NPF-74

Enclosure:

Inspection Report 05000528/2018002, 05000529/2018002, and 05000530/2018002 w/ Attachments:

1. Supplemental Information 2. Inservice Inspection Document Request 3. O

Inspection Report

Docket Numbers: 05000528, 05000529, 05000530 License Numbers: NPF-41, NPF-51, NPF-74 Report Numbers: 05000528/2018002, 05000529/2018002, and 05000530/2018002 Enterprise Identifier: I-2018-002-0013 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: 5801 South Wintersburg Road, Tonopah, AZ 85354 Inspection Dates: April 1, 2018 to June 30, 2018 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, PhD, Resident Inspector D. You, Resident Inspector W. Sifre, Senior Reactor Inspector L. Carson II, Senior Health Physicist W. Cullum, Reactor Inspector J. Melfi, Project Engineer C. Stott, Reactor Inspector Approved By: Neil OKeefe, Chief, Project Branch D Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection report at Palo Verde Nuclear Generating Station, Units 1, 2, and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations Failure to Re-baseline Valve Stroke Times as Required by ASME OM Code Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.1] - Human 71111.12 -

Systems NCV 05000528/2018002-01 Performance, Maintenance Closed Avoid Effectiveness Complacency The inspectors identified a Green, non-cited violation of Palo Verde Technical Specification 5.5.8, Inservice Testing Program, which requires inservice testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). On October 22, 2017, the licensee failed to establish new stroke time reference values for Unit 1 safety injection (SI) valve 660 following maintenance which could affect the valves performance.

Failure to Implement and Maintain Procedures Regarding Breathing Air Quality Cornerstone Significance Cross-cutting Report Aspect Section Occupational Green [H.4] - Human 71124.03 -

Radiation NCV 05000528/2018002, Performance, In-Plant Safety 05000529/2018002,05000530/2018002-02 Teamwork Airborne Closed Radioactivity Control and Mitigation The inspectors identified a Green, non-cited violation of 10 CFR 20.1703 for failing to implement and maintain written procedures to ensure that respiratory protection equipment (air compressors and bubble hood suites) was supplied respirable air of grade D quality or better to radiation workers.

Failure to Assess the Operability of a Degraded or Nonconforming Structure, System, or Component Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.13] - Human 71152 -

Systems NCV 05000530/2018002-03 Performance, Problem Closed Consistent Identification Process and Resolution The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings for the failure of licensee personnel to evaluate conditions adverse to quality for impacts on the operability of the essential spray ponds.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On April 5, 2018, power was reduced to 40 percent as directed by Station Chemistry procedures to address sodium levels caused by leakage into the main condenser. Unit 1 returned to full power on April 12, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power. On May 23, 2018, the reactor tripped from full power when maintenance on the control element drive mechanism control system resulted in a dropped control rod. The dropped control rod caused a valid reactor trip signal for low departure from nucleate boiling ratio. Unit 2 restarted on May 25, 2018; however, a different control element drive mechanism control system problem occurred requiring power to be held at 10 percent for additional repairs. Unit 2 returned to full power on May 27, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 3 began the inspection period at rated thermal power. Unit 3 shut down for a planned refueling outage from April 6 through May 4, 2018. Unit 3 returned to full power on May 7, 2018. On June 27, 2018, Unit 3 the steam generator 1 economizer valve failed (main feedwater regulating valve). Operator performance issues in responding to this condition resulted in a main feedwater pump trip and reactor cutback, reactor trip caused by low steam generator water level, and a main steam isolation signal due to subsequent high steam generator water level. Unit 1 remained shut down for repairs during the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Summer Readiness

The inspectors evaluated summer readiness of offsite and alternate alternating current (AC)power systems on May 9, 2018.

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme summer temperatures on May 11, 2018.

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for impending summer monsoon storms on June 14, 2018.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 control element drive mechanism control system, on April 18, 2018

(2) Unit 2 diesel generator B, on May 30, 2018

(3) Unit 3 essential spray pond B, on June 21, 2018

(4) Unit 3 auxiliary feedwater pump B, on June 27, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 1 essential cooling water system, on May 14, 2018.

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 3, condensate storage tank combustible material controlled area, Fire Zone 83, on April 3, 2018

(2) Unit 1, control element drive mechanism control system room, Fire Zone 54, on April 18, 2018

(3) Unit 2, non-class battery and switchgear room, Fire Zone TB4, on May 10, 2018

(4) Unit 2, condensate storage tank combustible material controlled area, Fire Zone 83, on May 15, 2018

(5) Unit 2, essential cooling water pump B room, Fire Zone 34B, on May 16, 2018

(6) Unit 1, 120 auxiliary building corridor, Fire Zone 52A and 52D, on May 21, 2018

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated Unit 3 train A shutdown heat exchanger performance, on May 1, 2018

71111.08 - Inservice Inspection Activities

The inspectors directly observed the following non-destructive examinations:

(1) Dye Penetrant Examination a) Auxiliary feedwater, Weld 58-19, pipe to tee, Report 18-PT-3009 b) Reactor coolant, Weld 2-60-89, tube housing lower, Report 18-PT-3014 c) Reactor coolant, Weld 2-59-89, control element drive mechanism tube housing lower, Report 18-PT-3017 d) Safety injection, Weld 74-1, elbow to shutdown cooling heat exchanger (SDCHX) an outlet nozzle, Report 18-PT-3006 e) Steam generator, Weld 58-1, nozzle extension to nozzle, Report 18-PT-3012

(2) Ultrasonic Examination a) Charging system, Weld 13-11, nozzle to safe end, Report VE-18-3007 b) Reactor coolant, Weld 9-11, nozzle to safe end, Report VE-18-3001 c) Reactor coolant, Weld 10-18, nozzle to safe end, Report VE-18-3004

(3) Visual Examination a) Reactor coolant, Weld 5-2-IR, nozzle inner radius, Report 18-VT-3174 The inspectors reviewed the following non-destructive examination records:

(1) Dye Penetrant Examination a) Steam generator, Weld 58-1, nozzle extension to nozzle, Report 18-PT-3012 b) Steam generator, Weld 61-15, pipe to valve, Report 18-MT-3003

(2) Ultrasonic Examination a) Charging system, Weld 13-11, nozzle to safe end, Report VE-18-3007 b) Reactor coolant, Weld 9-11, nozzle to safe end, Report VE-18-3001 c) Reactor coolant, Weld 10-18, nozzle to safe end, Report VE-18-3004

(3) Magnetic Particle Examination a) Steam generator, Weld 50-19, pipe to Sweepolet, Report 18-MT-3011 b) Steam generator, Weld 61-16, valve to pipe, Report 18-MT-3004 c) Steam generator, Weld 61-17, pipe to penetration, Report 18-MT-3005 The inspectors directly observed a portion of the following welding activity:

(1) Gas Tungsten Arc Weld a) Reactor coolant flex hose lines, Report 18-316 to 18-323 Vessel Upper Head Penetration Inspection Activities The licensee did not perform a bare metal head inspection on the Unit 3 reactor vessel upper head penetrations.

Boric Acid Corrosion Control Inspection Activities Inspection Scope The inspectors evaluated the licensees boric acid control program performance.

Steam Generator Tube Inspection Activities Inspection Scope The inspectors reviewed the steam generator tube eddy current (EC) examination scope and expansion criteria to determine whether these criteria met technical specification requirements, Electric Power Research Institute (EPRI) guidelines, and commitments made to the NRC. The inspectors also reviewed whether the EC inspection scope included areas of degradations that were known to represent potential EC test challenges such as the top of tube sheets, tube support plates, and U-bends. The licensee preventatively plugged 31 tubes in steam generator 31 and 19 tubes in steam generator 32. The licensee identified and removed Flexitallic gasket parts in the secondary side of the steam generators.

Identification and Resolution of Problems The inspectors reviewed 45 condition reports which dealt with inservice inspection activities and found the corrective actions for inservice inspection issues were appropriate.

==71111.11Q - Operator Requalification Program and Licensed Operator Performance Operator Requalification (1Sample)

The inspectors observed and evaluated Phoenix Risk Monitor demonstration and training.

Phoenix Risk Monitor is a new software system that will be used to implement the technical specifications risk informed completion time program, as well as 10CFR 50.65(a)(4) risk online management process.

Operator Performance==

The inspectors observed and evaluated Unit 1 operators perform a power reduction from 100 percent to 40 percent in order to repair a leak in the 1B condenser hotwell on April 5, 2018.

71111.12Q - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Structural integrity of the Unit 1 spray ponds below the waterline, on May 15, 2018

(2) Essential cooling water heat exchangers performance monitoring and aging management program, on May 17, 2018

(3) Performance of the Unit 1 safety injection A combined minimum flow recirculation valve, on June 26, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 3 elevated risk during high pressure safety injection pump A unavailability, on April 2, 2018

(2) Unit 3 emergent risk for corrective maintenance for stuck open vent valve SI-608 on safety injection tank 1B, on May 8, 2018

(3) Unit 2 weekly risk assessment for the week of May 21, 2018, including scheduled train unavailability for auxiliary feedwater B and containment spray B and elevated trip initiator risk for control element drive mechanism fuse replacements, on May 25, 2018

(4) Unit 2 weekly risk assessment for the week of June 11 including scheduled train unavailability for high pressure safety injection B, auxiliary feedwater B, and diesel generator B, on June 15, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 safety injection tank 1A vent valve SI-633 loss of remote shutdown function, on April 2, 2018

(2) Unit 2 diesel generator A fuel leak on 7L metering rod, on April 4, 2018

(3) Unit 3 auxiliary feedwater pump N Doble testing results exceeding power factor criteria, on April 12, 2018

(4) Unit 1 D-Panel class 1E circuit breaker doors inhibited from closing by tagout hangers, on April 26, 2018

(5) Reactor coolant pumps 3-1A, 2-1B, 1-1A, 3-2A, 2-1A, 2-2A, 3-1B, 1-2B anti reverse rotation device secured with different types of bolts, on April 27, 2018

(6) Unit 3 transition from mode 5 to mode 4 with an inoperable containment sump using Technical Specification 3.0.4.b, on May 2, 2018

(7) Unit 3 reactor vessel head inner o-ring leakage and reactor head vent system leakage, on May 8, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 3 degraded voltage under voltage relay replacement, Modification PB-1655

(2) Unit 3 main transformer lead differential protection upgrade, Modification MA-1679

71111.19 - Post-Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) Unit 1 diesel fuel oil transfer pump power cable replacement, on April 11, 2018

(2) Unit 3 auxiliary feedwater pump B megger testing, on April 11, 2018

(3) Unit 3 in core instrument replacements, on May 8, 2018

(4) Unit 3 safety injection tank 1B vent valve replacement, on May 8, 2018

(5) Unit 2 control element assembly 51 ACTM card replacement, on May 26, 2018

71111.20 - Refueling and Other Outage Activities

(1) Unit 3 the inspectors evaluated refueling outage 3R20 activities from April 7-May 4, 2018

(2) Unit 2 the inspectors evaluated activities during an unplanned outage to enact repairs to the control element drive mechanism control system from May 23-25, 2018

(3) Unit 3 the inspectors evaluated activities during an unplanned outage to enact repairs to the steam generator 1 economizer valve from June 27-July 1, 2018

===71111.21N - Design Bases Assurance Inspection (Programs)

Programs (Environmental Qualification)

The inspectors evaluated environmental qualification program implementation through the sampling of the following components from May 7-24, 2018:

Component ===

(1) Unit 2 containment penetration, 2JSEANE0001A a) Inspectors performed a walkdown to visually inspect the containment penetration b) Inspectors reviewed the work package for a neutron detector replacement and the post-maintenance testing associated with the detector replacement c) Inspectors reviewed the equipment qualification data package

(2) Unit 1 train B Low pressure safety injection pump motor, MSBIP01 a) Inspectors reviewed maintenance and replacement records for the Low Pressure Safety Injection pump motor b) Inspectors performed a walkdown to visually inspect the pump c) Inspectors reviewed the equipment qualification data package d) Inspectors reviewed the calculations associated with equipment qualification

(3) Unit 3 steam generator 1 main steam isolation valve controls, solenoid valve JSGAUY0170 a) Inspectors reviewed the high energy line break calculations for the area containing the component b) Inspectors reviewed solenoid valve maintenance and testing records c) Inspectors reviewed the solenoid valve equipment qualification data package d) Inspectors reviewed the calculations for component heat-up during design basis events

(4) Unit 3 instrument air supply containment isolation gate valve, 3JIAAUV0002 a) Inspectors reviewed thermal life and post-accident operating time b) Inspectors reviewed environmental tests performed with associated differences between the component as tested and as installed c) Inspectors reviewed purchase, storage, and maintenance requirements d) Inspectors walked down the component as installed in the plant and the storage facility where spare components are stored e) Inspectors reviewed the applicable vendor technical manual and the environmental qualification package with applicable environmental testing f) Inspectors reviewed operational experience and generic communications concerning the same and similar components

(5) Unit 3 containment pressure monitoring transmitter channel C, 3JHCCPT0351C a) Inspectors reviewed thermal life and post-accident operating time b) Inspectors reviewed environmental tests performed with associated differences between the component as tested and as installed c) Inspectors reviewed purchase, storage, and maintenance requirements d) Inspectors walked down the component as installed in the plant and the storage facility where spares are stored e) Inspectors reviewed the applicable vendor technical manual and the environmental qualification package with applicable environmental testing f) Inspectors reviewed operational experience and generic communications concerning the same and similar components at the site and in the industry

(6) Unit 3 train A low pressure safety injection discharge header containment isolation valve to reactor coolant loop 1B motor, 3JSIAUV0645 a) Inspectors reviewed thermal life and post-accident operating time b) Inspectors reviewed environmental tests performed with associated differences between the component as tested and as installed c) Inspectors reviewed purchase, storage, and maintenance requirements d) Inspectors reviewed the applicable vendor technical manual and the environmental qualification package with applicable environmental testing e) Inspectors reviewed operational experience and generic communications concerning the same and similar components at the site and in the industry

(7) Unit 2 safety injection tank 1B discharge isolation valve position switch, JSIAZSL0644 a) Inspectors reviewed thermal life and post-accident operating time b) Inspectors reviewed environmental tests performed with associated differences between the component as tested and as installed c) Inspectors reviewed purchase, storage, and maintenance requirements

(8) Unit 1 train A containment pressure transmitter, JHCAPT0353A a) Inspectors reviewed thermal life and post-accident operating time b) Inspectors reviewed environmental tests performed with associated differences between the component as tested and as installed c) Inspectors reviewed purchase, storage, and maintenance requirements

Component Located within Primary Containment (1 Sample)

(1) Unit 3 A&B containment sump level indicator A, JSIALE0706 a) Inspectors reviewed photographs of the containment sump level indicators since a walkdown of the component was not practical b) Inspectors reviewed indicator maintenance and testing records c) Inspectors reviewed indicator equipment qualification data packages d) Inspectors reviewed storage requirements for the replacement components

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) Unit 3 train A integrated safeguards testing, on April 9, 2018

(2) Unit 3 low power physics testing, on May 4, 2018

Containment Isolation Valve (1 Sample)

(1) Unit 3 local leak rate test for containment fire water penetration, on April 23,

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment

The inspectors evaluated radiological hazards assessments and controls Instructions to Workers

The inspectors evaluated worker instructions

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection (RP)technician proficiency

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls

The inspectors evaluated airborne controls and monitoring

Use of Respiratory Protection Devices

The inspectors evaluated respiratory protection Self-Contained Breathing Apparatus for Emergency Use (1 Sample)

The inspectors evaluated the licensees self-contained breathing apparatus program

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (April 1, 2017-March 31, 2018)

(2) MS07: High Pressure Injection Systems (April 1, 2017-March 31, 2018)

(3) MS08: Heat Removal Systems (April 1, 2017-March 31, 2018)

(4) MS09: Residual Heat Removal Systems (April 1, 2017-March 31, 2018)

(5) MS10: Cooling Water Support Systems (April 1, 2017-March 31, 2018)

(6) OR01: Occupational Exposure Control Effectiveness Sample (October 1, 2017-March 31, 2018)

(7) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Sample (October 1, 2017-March 31, 2018)

71152 - Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue.

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

(1) The inspectors evaluated a Unit 2 reactor trip caused by an inadvertent dropped control rod (CEA 64) during planned maintenance and licensees response and recovery, on May 23, 2018.

(2) The inspectors evaluated a Unit 3 reactor trip and main steam isolation actuation caused by operator errors in responding to a steam generator economizer valve hardware failure and the licensees response and recovery, on June 27-28,

INSPECTION RESULTS

Observation

71152 - Problem

Identification and Resolution The inspectors reviewed the licensees program for controlling potential tornado borne missiles (PTBMs) within the vicinity of the essential spray ponds. As described in UFSAR 3.5.1.4, tornado missile protection is not provided for the essential spray ponds nozzles because the licensee demonstrated with a probabilistic analysis that the probability of the loss of the ultimate heat sink safety function was acceptably low. In order to maintain the assumptions used in the probabilistic analysis, the licensee must administratively control the potential tornado borne missiles near the essential spray ponds. Procedure 01DP-0XX01, Control and Monitoring of Potential Tornado Borne Missiles, provides the requirements and guidance for licensee personnel to identify and control potential missile hazards.

During the inspection period, the inspectors identified multiple non-compliances with the licensees PTBM control program. These non-compliances included:

• PTBMs not tagged nor tracked within the licensees database

• PTBM painted exclusion boundary markings missing

• Clusters of multiple PTBMs staged within the PTBM exclusion area

• PTBMs not shielded from the essential spray pond nozzles in accordance with procedure 01DP-0XX01

• Groups of PTBMs not bundled in accordance with Procedure 01DP-0XX01 The inspectors shared their observations with licensee management. The individual non-compliances were entered into the licensees corrective action program and addressed. In response to the inspectors observations, the licensee wrote CR 18-05858 that identified another trend of an increase in non-compliances with PTBM requirements during refueling outages. The licensee planned to add a pre-outage challenge board for evaluating what controls will be implemented during the outage to ensure compliance with the PTBM program as part of the outage planning process. The licensee also issued two site wide communications to reinforce the expectations of the PTBM control program and has designated area owners for each of the PTBM monitoring zones.

Failure to Re-baseline Valve Stroke Times as Required by ASME OM Code Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Systems Green [H.1] - Human

71111.12 - NCV 05000528/2018002-01 Performance, Maintenance

Closed Avoid Effectiveness Complacency The inspectors identified a Green, non-cited violation of Palo Verde Technical Specification 5.5.8, Inservice Testing Program, which requires inservice testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). On October 22, 2017, the licensee failed to establish new stroke time reference values for Unit 1 safety injection (SI) valve 660 following maintenance which could affect the valves performance.

Description:

During Unit 1 refueling outage 1R20, the valve services group replaced SI valve 660 under work order 3470020. SI valve 660, safety injection combined recirculation to refueling water tank (RWT) isolation valve, is a normally open solenoid-operated valve that performs a passive safety function in the open position to provide a minimum recirculation flow path for the train A high pressure, low pressure, and containment spray pumps. SI valve 660 also performs an active function to close on a recirculation actuation signal to prevent containment sump water from being pumped to the RWT.

Following the valves replacement, the licensee successfully performed a post-maintenance test on October 22, 2017, using procedure 73ST-9XI53, Train A HPSI Injection and Miscellaneous SI Valves - Cycle - Inservice Test, Revision 8. The test consisted of stroking the valve closed, then open, and comparing the stroke times to Technical Specification limits.

The licensee is committed to requirements of the ASME Operation and Maintenance Code 2012 edition. ASME OM Code section ISTC-3310, Effects of Valve Repair, Replacement, of Maintenance on Reference Values, requires the following:

When a valve or its control system has been replaced, repaired, or has undergone maintenance that could affect the valves performance, a new reference value shall be determined or the previous value reconfirmed by an inservice test run before the time it is returned to service or immediately if not removed from service. This test is to demonstrate that performance parameters that could be affected by the replacement, repair, or maintenance are within acceptable limits. Deviations between the previous and new reference values shall be identified and analyzed.

The inspectors identified that the licensee did not establish new stroke time reference values after SI valve 660 was replaced in October 2017. The inservice testing engineering group was unaware that the valve had been replaced until January 2018. During its quarterly inservice test on January 4, 2018, SI valve 660 was tested using procedure 73ST-9XI13, Train A HPSI Injection and Miscellaneous SI Valves - Quarterly - Inservice Test, Revision 31. The licensee identified a valve position indication issue during this test and valve technicians performed a limit switch adjustment to correct the indication issue. Because the limit switch adjustment was maintenance that could potentially affect the stroke time by changing the length of the measured valve stroke, valve service technicians initiated condition report 18-00197 to request a post-maintenance review by the inservice testing program manager. The IST engineering group then established new reference values based upon the as-left stroke times following the limit switch adjustment.

The inspectors reviewed the licensees evaluation that determined the new stroke time reference values and questioned why the valve had not been previously been re-baselined following its replacement in October 2017. The licensee generated CR 2018-07443 to document this concern and initiate an evaluation.

Two different testing procedures were used to perform the two inservice testing activities in October 2017 and January 2018. Test procedure 73ST-9XI13 (an online-only test) includes step 7.2 that directs operators to write a condition report when the procedure is being performed as a post-maintenance test. Procedure 73ST-9XI53 (an outage-only test) lacked this step. Consequently, when SI valve 660 was replaced in October 2017, during refueling outage 1R20, the inservice testing engineering group was not notified to perform the post-maintenance review that would have established new stroke time reference values.

Corrective Action: The licensee revised the test instructions for procedure 73ST-9XI53 to ensure that the inservice testing engineering group receives post-maintenance review requests.

Corrective Action Reference: Condition Report 18-07443

Performance Assessment:

Performance Deficiency: The licensees failure to establish new stroke time reference values in accordance with ASME OM Code after replacing Unit 1 SI valve 660 is a performance deficiency.

Screening: The performance deficiency is more-than-minor and a finding because if left uncorrected, it could lead to a more significant safety concern. Specifically, the failure to establish new reference values for SI valve 660 stroke time testing could have delayed the identification of a degrading trend in the valves stroke times due to the continued erroneous use of a wider range of acceptable valve operation.

Significance: The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions and determined that the finding was of very low safety significance (Green) because the finding did not represent a design or qualification deficiency, a loss of system or function, an actual loss of safety function of a single train for greater that its technical specification allowed outage time, or an actual loss of function for non-Technical Specification equipment.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area human performance associated with the resources aspect. Specifically, licensee leaders did not ensure that adequate inservice testing procedures were available to support successfully recognizing that new reference values needed to be established for SI valve 660 [H.1].

Enforcement:

Violation: Palo Verde Technical Specification 5.5.8, Inservice Testing Program, requires the inservice testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operations and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition. OM Code section ISTC-3310 requires, in part, that when a valve has undergone maintenance that could affect the valves performance, a new reference value shall be determined by an inservice test before it is returned to service.

Contrary to the above, prior to February 2, 2018, the licensee did not perform inservice test Unit 1 SI valve 660, an ASME Code Class 2 component, in accordance with the ASME Code for Operations and Maintenance of Nuclear Power Plants 2012 Edition. Specifically, after replacing Unit 1 SI valve 660 on October 18, 2017, a maintenance activity that could affect the valves performance, the licensee failed to determine a new reference value with which to monitor the valves performance, as required by ASME OM Code Section ISTC-3310.

Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Implement and Maintain Procedures Regarding Breathing Air Quality Cornerstone Significance Cross-cutting Report Aspect Section Occupational Green [H.4] - Human

71124.03 - Radiation NCV 05000528/2018002, Performance, In-Plant Safety

05000529/2018002,05000530/2018002-02 Teamwork Airborne Closed Radioactivity Control and Mitigation The inspectors identified a Green, non-cited violation of 10 CFR 20.1703 for failing to implement and maintain written procedures to ensure that respiratory protection equipment (air compressors and bubble hood suites) supplied respirable air of grade D quality or better to radiation workers.

Description:

From April 19-26, 2016, during the Unit 1 Refueling Outage 19 (1RF19), the Unit 1 service air header was used to supply breathing air to respirators for 10 radiation workers performing steam generator nozzle dam activities in an airborne radioactivity area. The licensee used rented portable compressors to supply air to the service air header. The inspectors determined that, in addition to use during 1RF19, the portable compressor was infrequently used to supply the service air header with breathing air for respiratory protection on all three units in 2017 and 2018. The inspectors requested records associated with breathing air quality analyses from January 2017 through April 2018 and for the 1RF19 timeframe, in order to verify that the breathing air quality was analyzed to ensure that it was at least grade D.

However, the licensee could not find any records that demonstrated they had analyzed or otherwise evaluated the breathing air quality.

Licensees are subject to 10 CFR 20.1703 when permitting the use of respiratory protection equipment to limit the intake of radioactive material. According to 10 CFR 20.1703(c)(4),licensees shall implement and maintain a respiratory protection program that includes, among other things, written procedures regarding breathing air quality. Breathing air quality is specified in 10 CFR 20.1703(g), which requires that atmosphere-supplying respirators be supplied with respirable air of grade D quality or better as defined by the Compressed Gas Association in publication G-7.1, "Commodity Specification for Air," 1997. Grade D quality air criteria are specified by this regulation and include:

(1) Oxygen content (v/v) of 19.5-23.5%;

(2) Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less;

(3) Carbon monoxide content of 10 ppm or less;

(4) Carbon dioxide content of 1,000 ppm or less; and

(5) Lack of noticeable odor.

The inspectors reviewed the following licensee procedures used for the respiratory protection program:

• 01DP-0IS10, PVNGS Respiratory Protection Program, Revisions 11 and 12

• 01DP-0IS08, PVNGS Respiratory Protection Equipment Usage, Revisions 20 and 21

• 14FT-9FP79, Compressed Air Cylinder Inspection and Repair, Revision 0 The inspectors determined that the licensees procedures require the coating facility compressor system and the system for filling SCBA bottles to be tested to ensure grade E quality breathing air (better than grade D). However, the procedures did not require them to verify that portable compressors providing breathing air to workers met the breathing air quality requirement. Specifically, Procedure 01DP-0IS08, Section 4.2.1.13, states, in part, that portable air compressors supplying breathing air do not have to be tested for air quality as long as the units use in-line filtration and carbon monoxide detection systems. While these measures may address specific components of breathing air quality, the licensee did not establish by testing or evaluation/analysis of the system design that the breathing air quality being provided was grade D or better.

Discussions with licensee personnel determined that the Industrial Health and Safety (IH&S)group had responsibility for administration of the sites respiratory protection program. The IH&S staff believed that OSHA requirements took precedence over NRC requirements with respect to respiratory protection. As a result, Radiation Protection staff were unaware that the air produced by portable compressors and used as breathing air for workers in supplied-air respirators in airborne radioactivity areas was not being tested to demonstrate compliance with NRC requirements.

The inspectors concluded that the licensees written procedures did not adequately address breathing air quality, as defined in 10 CFR 20.1703(g), in that no guidance was provided to establish that grade D quality air was supplied to the service air header by portable compressors and, thereby, atmosphere-supplying respirators.

Corrective Action(s): Any immediate safety concern was addressed when the inspectors verified that, although the licensee had used the portable compressor to provide air to the service air header, the licensee had not used the system as a source of breathing air since the April 2016 Unit 1 refueling outage. Corrective actions will be determined during evaluation of Condition Report CR-18-07010.

Corrective Action Reference: Condition Report CR-18-07010

Performance Assessment:

Performance Deficiency: The failure to implement and maintain adequate procedures to ensure breathing air quality for compressors supplying air to the breathing air system, and thereby workers using air-supplied respirators, is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it is associated with the Occupational Radiation Safety Cornerstone attribute of Plant Facilities/Equipment and Instrumentation. The performance deficiency adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation or radioactive material, in that, failure to provide acceptable breathing air quality could lead to respiratory distress and/or workers removing their respiratory protection equipment, and the potential inhalation of radioactive material.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. This finding was not related to as low as reasonably achievable (ALARA) planning, did not involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not compromised. For these reasons, the inspectors concluded that the finding is of very low safety significance (Green).

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with teamwork because individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained [H.4]. Specifically, staff in Industrial Health and Safety did not communicate and coordinate with Radiation Protection staff regarding the requirements associated with respiratory protection involving radioactive materials.

Enforcement:

Violation: 10 CFR 20.1703(c) requires, in part, that the licensee shall implement and maintain a respiratory protection program that includes written procedures regarding breathing air quality. Contrary to the above, from April 19, 2016, to present, the licensee failed to implement and maintain a respiratory protection program that included written procedures regarding breathing air quality. Specifically, licensee Procedure 01DP-01S10, PVNGS Respiratory Protection Program, explicitly excluded portable compressors from testing to ensure breathing air quality. As a result, the Unit 1 service air header was used to supply breathing air to respirators for ten individuals working with steam generator nozzle dams in an airborne radioactivity area in April 2016 during 1RF19.

Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Assess the Operability of a Degraded or Nonconforming Structure, System, or Component Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.13] -

71152 - Systems NCV 05000530/2018002-03 Human Problem

Closed Performance, Identification Consistent and Process Resolution The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to evaluate conditions adverse to quality for impacts on the operability of the essential spray ponds.

Description:

On April 20, 2018, the inspectors performed a walkdown of the Unit 3 essential spray ponds and observed a localized concentration of approximately 150 items that represented potential tornado borne missile (PTBM) hazards per the licensees program located northwest of the Unit 3 essential spray ponds. The hazards included pieces of metal conduit, wooden pallets, electrical cable spools, metal plates, and other miscellaneous items.

The licensee wrote Condition Report (CR) 18-06666 to document and address this condition.

The essential spray ponds function as the ultimate heat sink. Spray nozzles, located above the surface of the essential spray ponds, are used to maintain post-accident design temperatures within safety analysis assumptions. The spray nozzles have no protective features to prevent damage from airborne missiles and, as a result, they are vulnerable to airborne missiles generated during a high wind event. During original plant licensing, the licensee used a probabilistic analysis to justify not providing tornado missile protection for the essential spray pond nozzles. This probabilistic approach is described in UFSAR 3.5.1.4.

Two key inputs into this analysis are the maximum average missile density and the maximum localized missile density. Both limits are assumed inputs into the probabilistic analysis. The license basis average density limit for PTBMS is 20 missiles per 10,000 square feet averaged over a defined area around the essential spray pond and a localized limit of 60 missiles in any one 10,000 square foot area. The probabilistic analysis justifies that a tornado event will not cause the loss of the heat removal function of the essential spray ponds so long as the licensee stays within these transient missile limits. If either PTBM limit is exceeded, the presumption of essential spray pond operability following a tornado event is no longer valid.

The licensee uses an administrative procedure, Procedure 01DP-0XX01, Control and Monitoring of Potential Tornado Borne Missiles, Revision 4, to maintain the license basis average and local density limits for PTBM hazards. Appendix E of Procedure 01DP-0XX01 identifies the average and localized density limits. Step 4.9.3 states that a non-compliance with the design basis occurs when either the average missile density or a localized missile cluster exceeds the maximum allowable limits.

The licensee uses Procedure 40DP-9OP26, Operations Condition Reporting Process and Operability Determination/Functional Assessment, Revision 44, for evaluating the operability of structures, systems, or components (SSCs) when a condition is identified that could impact a SSCs safety function. Operations personnel performed an immediate operability determination (IOD) to assess the condition described in CR 18-06666. Appendix J of Procedure 40DP-9OP26 describes the uses of the Not Applicable (N/A) trend code. Per step J.1.1, the use of the N/A trend is appropriate for conditions identified which are clearly not degraded or nonconforming. Appendix J lists several examples of Not Applicable trend coding. A CR written to identify a PTBM not tagged of tracked in an area which has margin to the maximum number of PTBMs is described as an example of an administrative issue that should not be considered a degraded or nonconforming condition.

In the IOD, the shift technical advisor assessed the PTBMs in CR 18-06666 against the average density limit, which was not exceeded, but did not consider the localized limit, which was exceeded. The shift technical advisor erroneously concluded that Because there is not an identified degraded or nonconforming condition.this CR is trend coded N/A in accordance with Appendix J of 40DP-9OP26. However, the inspectors determined that the condition described in CR 18-0666 should have been considered a degraded or non-conforming because it was outside the limits of the license basis calculation. Because the shift technical advisor did not recognize that the local PTBM limit had been exceed, he did not evaluate whether the Unit 3 essential spray pond would have been able to perform its design basis function in its nonconforming condition.

The inspectors identified two additional recent examples in which operations personnel inappropriately applied the N/A trend code when clusters of PTBMs were identified with the vicinity of the essential spray ponds. CR 18-05094 documented pieces of PVC pipe near the Unit 2 spray ponds on April 1, 2018, and CR 17-17024 documented spray pond filter media bags and pallets near the Unit 3 spray pond on November 27, 2017. The IODs performed for each of these conditions also failed to recognize that the localized PTBM limits had been exceeded and both were trend coded as N/A.

Corrective Action: The licensee took immediate corrective action by removing the transient PTBMs from the vicinity of the essential spray ponds.

Corrective Action Reference: Condition Report 18-06666

Performance Assessment:

Performance Deficiency: The failure to evaluate all license basis limits when assessing the operability of the essential spray ponds is a performance deficiency.

Screening: The performance deficiency is more-than-minor and a finding because it is associated with the protection against external factors attribute of the mitigating systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the ultimate heat sink to respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to recognize that they were outside the analyzed limits for which the essential spray ponds would be presumed to remain operable following a tornado event.

Significance: The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings at Power, Exhibit 4, External Events Screening Questions. Step 1.a. which required a senior reactor analyst to perform a detailed risk evaluation because if the equipment or safety function is assumed to be completely failed or unavailable, it would degrade one or more trains of a system that supports a risk significant system or function.

A regional senior reactor analyst performed a detailed risk evaluation and determined that the finding was of very low safety significance (Green). The analyst used the tornado missile frequency of 1.74E-6 tornados per year for the Palo Verde site developed from tornado data from January 1, 1950 - December 31, 2006, within 100 kilometers of the plant and reviewed per Review of Methods for Estimation of High Wind and Tornado Hazard Frequencies, dated December 2012.

A postulated tornado at this frequency was assumed to cause a switchyard-centered loss of offsite power which could not be recovered within a 24-hour probabilistic risk assessment mission time. The analyst then set the failure to start basic events for both essential spray pond motor driven pumps to TRUE, thereby totaling failing both essential service water spray ponds in the Palo Verde SPAR model, Version 8.50, run on SAPHIRE, Version 8.1.8. This failure resulted in an increase in the conditional core damage probability of 7.1E-2 during the postulated tornado event.

The analyst then applied the assumed exposure time of three months to the tornado frequency and the increase in the conditional core damage probability to obtain a bounding estimate of the increase in core damage frequency from the performance deficiency of 3.1E-8 per year. This estimate made the significance Green or of very low safety significance for core damage frequency. Because not all of the spray nozzles would be damaged and some heat exchange capability would likely remain, the actual increase in core damage frequency would be expected to be less than this estimated value. Since the increase in core damage frequency was less than 1.0E-7, increase in large early release frequency was not analyzed.

Losses of offsite power initiated by tornados were the dominant core damage sequences which were mitigated by the remaining auxiliary feedwater system and diesel generators.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area human performance associated with the consistent process aspect. Specifically, operations personnel did not demonstrate an understanding of the decision-making process regarding the identification and evaluation of non-compliances with the control of potential tornado borne missile programs [H.13].

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, requires that activities affecting quality be prescribed by instruction, procedures, or drawings, and be accomplished in accordance with those instructions, procedures, or drawings. The assessment of operability of the Unit 3 essential spray pond was an activity affecting quality and implemented by Procedure 40DP-9OP26, Revision 44. Procedure 40DP-9OP26, Step E.5 requires that operators identify current licensing basis requirements that may be impacted.

Contrary to the above, on April 20, 2018, licensee operators failed to identify current licensing basis requirements that may be impacted. Specifically, when assessing a potential tornado borne missile cluster, operators did not identify the localized density limit, a current license basis limit, had been exceeded. Therefore, the licensee did not fully evaluate whether the Unit 3 essential spray pond would have been able to perform its design basis function.

Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

On April 19, 2018, the inspectors presented the inservice inspection results to Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On April 27, 2018, the inspectors presented the radiation safety inspection results to Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On May 24, 2018, the inspectors presented the Design Bases Assurance (Programs) inspection results to Mr. B. Rash, Vice President Nuclear Engineering, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On July 12, 2018, the inspectors presented the quarterly resident inspector inspection results to Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

40OP-9ZZ19 Hot Weather Protection 7

40AO-9ZZ21 Acts of Nature 37

40AL-9RK1B Panel B01B Alarm Responses 4

40DP-9OP34 Switchyard Administrative Control 21

40AO-9ZZ12 Degraded Electrical Power 72

40ST-9ZZ37 Inoperable Power Sources Action Statement 1

Condition Reports (CRs)

2879765 2873519

Work Orders (WOs)

3050186

Miscellaneous

Number Title Revision

ODP 10 Operations Department External Communications Practices 5

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

40OP-9SF01 Control Element Drive Mechanism Control System 30

(CEDMCS) Operation

40AL-9SF01 Local Alarm Panel J-SFN-C01D Responses 10

40OP-9SP02 Essential Spray Pond (SP) B 52

40ST-9AF08 Auxiliary Feedwater Pump AFB-P01 Monthly Valve 6

Alignment

Drawings

Number Title Revision

01-M-EWP-001 P&I Diagram Essential Cooling Water System 32

01-P-EWF-201 Auxiliary Bldg. Isometric Essential Cooling Water System 4

ECWS Pump Loop - Train A

01-P-EWF-202 Auxiliary Bldg. Isometric Essential Cooling Water System 5

ECWS Pump Loop - Train B

01-P-EWF-301 Control Building Isometric Essential Cooling Water System 3

01-M-SPP-001 P&I Essential Spray Pond System 63

01-M-AFP-001 P&I Diagram Auxiliary Feedwater System 43

Condition Reports (CRs)

18-06844 16-20392

Section 1R05: Fire Protection

Procedures

Number Title Revision

18FT-9FP38 Functional Test of Appendix R Fire/HELB Doors 1

14DP-0FP33 Control of Transient Combustibles 30

Condition Reports (CRs)

18-05400 18-05170

Miscellaneous

Number Title Revision

PVNGS Pre-Fire Strategies Manual 26

Section 1R07: Heat Sink Performance

Procedures

Number Title Revision

70DP-0MR01 Maintenance Rule 44

Miscellaneous

Number Title Date

18-0252 Eddy Current Examination Report: U3 Shutdown Cooling A April 18, 2018

Section 1R08: Inservice Inspection Activities

Procedures

Number Title Revision

30DP09MP23 Foreign Material Exclusion Controls 5

70TI-9ZC01 Boric Acid Walkdown Leak Detection 20

73DP-9WP04 Welding and Brazing Control 19

73DP-9WP05 Weld Filler Material Control 10

73DP-9ZC01 Boric Acid Corrosion Control Program 8

73TI-0EE01 Ultrasonic Instrument Calibration 5

73TI-0ZZ02 Ultrasonic Thickness Measurement 13

73TI-0ZZ13 Radiographic Examination 19

73TI-9RC01 Steam Generator Eddy Current Examinations 32

73TI-9ZZ05 Dry Magnetic Particle Examination 18

73TI-9ZZ06 Wet Magnetic Particle Examination 18

73TI-9ZZ07 Liquid Penetrant Examination 18

73TI-9ZZ09 Ultrasonic Examination of Pipe and Vessel Welds 17

73TI-9ZZ10 Ultrasonic Examination of Welds in Ferritic Components 14

73TI-9ZZ17 Visual Examination of Welds, Bolting, and Components 14

73TI-9ZZ18 Visual Examination of Component Supports 14

73TI-9ZZ22 Visual Examination for Leakage 12

73WP-0ZZ05 Welding of Ferritic and Martensitic Steels 15

81DP-0CC28 Classification of Structures, Systems, and Components 15

81DP-0CC28 Classification of Structures, Systems, and Components 0

81DP-9RC01 Palo Verde Nuclear Generating Station Steam Generator 18

Management Program

NS-FS-FSO-WI- Palo Verde Nuclear Generating Station Steam Generator 6.1

0006 Visual Examination (Rolls-Royce Proprietary)

PDI-UT-1 Performance Demonstration Initiative (PDI) Generic Procedure 1

for the Ultrasonic Examination of Ferritic Pipe Welds

Procedures

Number Title Revision

PDI-UT-10 PDI Generic Procedure for the Ultrasonic Examination of 1

Dissimilar Metal Welds

PDI-UT-11 PDI Generic Procedure for the Ultrasonic Examination of 0

Reactor Pressure Vessel Nozzle-to-Shell Welds and the Nozzle

Inner Corner Radius

PDI-UT-2 PDI Generic Procedure for the Ultrasonic Examination of 2

Austenitic Pipe Welds

PDI-UT-3 PDI Generic Procedure for Ultrasonic Through-Wall Sizing in 2

Pipe Welds

PDI-UT-8 PDI Generic Procedure for the Ultrasonic Examination of Weld 2

Overlaid Similar and Dissimilar Metal Welds

Drawings

Number Title Revision/Date

03-M-PCP-00, Piping and Instrumentation Diagram (P&ID) Fuel Pool 32

Sheet 1 of 2 Cooling and Cleanup System

03-M-PCP-00, P&ID Fuel Pool Cooling and Cleanup System 32

Sheet 2 of 2

03-M-PCP-0001 P&ID Fuel Pool Cooling and Cleanup System 32

03-P-SGF-120 Containment Building Isometric Main Steam System 4

Feedwater Lines

13-C-ZCS-504 Containment Internals Refueling Pool Liner, Sheet 5 16

13-C-ZCS-504 Containment Internals Refueling Pool Stainless Steel 16

Liner, Sheet 5

13-C-ZFS-0422 Fuel Building Liner Plate, Sections and Details, Sheet 3 14

13-C-ZFS-422 Fuel Building Liner Plate, Sections and Details, Sheet 3 14

C-113-4046 48 Inch Double Non-Equalizing Expansion Joint with March 26, 1979

Weld Ends

D-SYS80-630- Transfer Tube Weldment and Flange 1

054

E-SYS80-630- Fuel Transfer Tube Assembly 6

055, Sheet 1 of 2

Condition Reports (CRs)

14-00265 15-00956 16-03169 16-16086 16-16502

16-16768 16-17216 16-18718 16-19536 16-19841

Condition Reports (CRs)

17-01511 17-01923 17-02845 17-03101 17-03169

17-03539 17-04004 17-07081 17-07127 17-07234

17-07340 17-07341 17-07345 17-10119 17-13749

17-13750 17-14594 17-14620 17-14621 17-16352

17-16534 17-16929 17-17070 17-18467 18-00088

18-00090 18-00547 18-03285 18-05569 18-05816

18-05835 18-06064 18-06274 18-06277 18-06350

Work Orders (WOs)

4304410 4664172 466713

Miscellaneous

Number Title Revision/Date

EPRI 1000975 Boric Acid Corrosion Guidebook, Revision 1 November 2001

03-MS-A146 Steam Generator Condition Monitoring Evaluation, April 12, 2015

Unit 3, Cycle 18

03-MS-A155 U3R19 Steam Generator Degradation October 1, 2016

Assessment/Operational Assessment Review

17-09564 Welding Program Self-Assessment June 30, 2017

N001-5.03- Transfer Tube Weldment and Flange 1

00052-1

N001-5.03- General Engineering Specification for Fuel Transfer June 6, 1984

00399- Tube

SDOC N001- Fuel Transfer Tube Assembly 6

0503-00053(2)

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Miscellaneous

Number Title Revision

40DP-9OP02 Conduct of Operations 72

40OP-9ZZ05 Power Operations 148

Standard Maneuver Plan: 150 EFPD 100 to 40% 0

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

40OP-9SP02 Essential Spray Pond B 52

Condition Reports (CRs)

18-05261 18-05886 17-17403

Miscellaneous

Number Title Revision/Date

Palo Verde Maintenance Rule Database

Unit 1A Inspection Video

16-13764-002 MRFF Evaluation for 3JEWALC0091 September 14,

2016

17-17403-003 MRFF Determination for Unit 2 NC Leakage into EW-A January 2,

2018

18-05261-002 Engineering Evaluation April 11, 2018

01-M-SPP-001 P&I Diagram: Essential Spray Pond System 63

Essential Cooling Water System Health Report 2nd Quarter

2018

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

40DP-9RS01 Operations Department Online Nuclear Risk Management 4

Mode 1 and 2

40DP-9OP02 Conduct of Operations 72

Drawings

Number Title Revision

21010-9 Solenoid Operated Valve Soft Seated Energize to Open B

Sizes 3/8 through 2

03-M-SIP-002 P&I Diagram Safety Injection and Shutdown Cooling 36

System

Miscellaneous

Number Title Date

Schedulers Evaluation for PV Unit 3 May 7, 2018

Palo Verde EOOS software

Schedulers Evaluation for PV Unit 2 May 25, 2018

Shutdown Safety Function Assessment for Unit 2 May 25, 2018

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

40AO-9ZZ19 Control Room Fire 35

Condition Reports (CRs)

18-05906 18-03664 18-05232 18-02334 18-07701

18-07751

Work Orders (WOs)

4980753

Miscellaneous

Number Title Revision/Date

2018-R002 Licensing Document Change Request: TRM Component March 30, 2018

Lists T7.0.100 and T7.0.200

18-00619-008 Engineering Evaluation May 3, 2018

18-00619-007 Engineering Evaluation May 2, 2018

Palo Verde Technical Specifications April 6, 2018

18-05906-002 Engineering Evaluation April 17, 2018

18-03664-003 Level 3 Evaluation Report March 28, 2018

227427 Engineering Evaluation of EDG fluid leakage and 2

potential operability concerns

Section 1R18: Plant Modifications

Procedures

Number Title Revision

40OP-9SA01 BOP-ESFAS Modules Operation 32

Work Orders (WOs)

4989102 4690453 4728616 4544651

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

73ST-9DF01 Diesel Fuel Oil Transfer Pumps - Inservice Test 34

2MT-9ZZ21 4.16kV Motor Operational Testing 6

73ST-9SI37 Safety Injection Tank Nitrogen Vent Valves- Inservice Test 8

Condition Reports (CRs)

18-05813 18-08963

Work Orders (WOs)

26942 4381898 4981134 4850125 4852867

4852923 5007848

Miscellaneous

Number Title Revision/Date

78MT-9RI01 Withdrawal, Cutup, Installation and Insertion of Incore 25

Instrument (ICI) Assemblies

Section 1R20: Refueling and Other Outage Activities

Condition Reports (CRs)

18-05402

Miscellaneous

Number Title Revision/Date

4467778 Engineering Evaluation October 30, 2013

Outage Plan Unit 3 20th Refueling Outage C

13-CN-0380 Scaffold Specification 24

388046 Clearance for SIT 2A outage

Section 1R21N: Design Bases Assurance Inspection (Programs)

Procedures

Number Title Revision

2DP-0MC25 Stores 34

87DP-0MC39 Commercial Grade Dedication (CGD) Process 0

Drawings

Number Title Revision

03-P-SGF-155 M.S.S.S. Isometric Main Steam 4

03-E-SGF-023, Control Wiring Diagram Main Steam System Main Steam 11

Sh. 2 Isolation Valve 3J-SGE-UV-170

F-5160 Logic Diagram for Anchor/Darling Hydraulic Actuator F-5157 B

and F-5160

Condition Reports (CRs)

14-01293 14-01510 14-01552 14-01798 14-03626

14-02193 15-05733 15-00467 15-01120 15-12438

15-02141 15-03049 16-00209 16-07016 16-14037

17-01524 17-01674 17-07867 17-09374 17-00175

17-12722 17-15592 18-02412 18-04544 18-08729

18-07966 18-07967 18-07972 18-08049 18-08669

18-08136 18-08556

Work Orders (WOs)

4892262 4852899 4789318 4678418 4715350

4678231 4678228 4495917 4489944 4474094

4198033 4813518 4784920 4779316 2981517

4680630 4657058 4537000 4537003 4474107

4416771 4416747 4181331 4177198 4062583

4698710 4661775 4634826 4535185 4495917

4813306 4795912 4795833 4775518 4151394

4785792 4769854 4616096 4612918 4498447

4537801 4495917 4709169 4678884 4474084

4678409 4678124 4641446 4490438 4652465

Work Orders (WOs)

4489937 4198697 4198071 3576632 4836432

3535238 4836464

Miscellaneous

Number Title Revision/

Date

EEQ-B389-001 Qualification Tests of Electrical Cables in a Simulated Steam 0

Line Break (SLB) and Loss-of-Coolant Accident (LOCA)

Environment

EEQ-T020-002 Electrical Equipment Qualification Data File - Target Rock - 13

2EE-001 & 76HH Series with Soft Seats and 98F-002 with

Hard Seats - Solenoid Valves

EEQ-B389-001 Electrical Equipment Qualification Data File - Brand-Rex 9

Corporation - 600 Volt, XLPE (Ultrol) Insulation, Hypalon or

Neoprene Jacket - Power and Control Cable and SIS Wire

EEQ-I206-001 Electrical Equipment Qualification Data File - ITT General 8

Controls - NH-95 - Hydramotor Actuator

EEQ-A385-001 Electrical Equipment Qualification Data File - Anaconda 10

Company, Wire and Cable Division - 600 Control Cable with

FREP Insulation, CPE

Jacket - Cable

EEQ-R369-002 Electrical Equipment Qualification Data File - Rosemount - 19

1153 Series B - Transmitter

Equipment Qualification Program Manual 26

SWMS No. 17- Assessment of the Environmental Qualification Program March 2,

01524 IP 71111.21N Readiness Inspection Self-Assessment 2018

PVNGS Operations Quality Assurance Program Description 0

EEQ-W120-003 Electrical Equipment Qualification Data File - Westinghouse - 12

WL-24202 and WL-24279 - PAMI EX-CORE Neutron Flux

Detector and Preamplifier Filter

EEQ-W120-004 Electrical Equipment Qualification Data File - Westinghouse 8

Motor Company - Life Line D (LLD) - Large AC Motors

EEQ-R098-002 Electrical Equipment Qualification Data File - Raychem - 12

NMCK8-1L, NMCK8-2L, NMCK8-1Y and NHVT - 5-8kV In-Line

and Wye Motor Connection Kit and 5kV Nuclear High Voltage

Termination

EEQ-S124-001 Electrical Equipment Qualification Data File - Skinner Valve 13

Division, Honeywell, Inc. - V5H Series - Solenoid Valves

Miscellaneous

Number Title Revision/

Date

EEQ-R098-004 Electrical Equipment Qualification Data File - Raychem 10

Corporation - WCSF-N - In-Line Splice

EEQ-D089-001 Electrical Equipment Qualification Data File - Transamerica 17

Delaval, Inc. Gems Sensor Division - XM-54852 and XM-54853

- Liquid Level Transmitter

EEQ-R352-001 Electrical Equipment Qualification Data File - Rockbestos - 11

Firewall III Irradiation and Chemically XLPE - 600 Volt Power,

Control and Instrumentation Cables and SIS Wire

EEQ-L200-001 Limitorque Valve Actuator Qualification for Nuclear Power 0

Station Service - Report 80058 - Tests Conducted Per IEEE

2-197Z, 323-1974, 344-1975

EEQ-C515-004 Electrical Equipment Qualification Data File - CONAX - 7371- 20

11000 Series - ECSA (Electric Conductor Seal Assembly)

EEQ-N007-001 Electrical Equipment Qualification Data File - Namco Controls - 21

EA180-Series - Limit Switches

MEE-00266 Shelf Life for Elastomers, Capacitors, Lubricants and other 13

limited shelf-life items

MEE-02212 Commodity Substitution Evaluation 3

MEE-00267 Shelf Life Extension Guidelines 7

VTD-R369- Rosemount Model 1153 Series B Alphaline Pressure 5

00012 Transmitters for Nuclear Service

13-NC-MS-0007 MSSS Equipment Qualification Thermal Lag Analysis 5

VTD-SI24-0009 Skinner Valve Options 0

VTD-I204-00036 ASCO General Controls (Formerly ITT Barton, Formerly ITT 5

General Controls) Installation and Maintenance Instructions for

NH90 Series Hydramotor Actuators, Model B & Model B1

EEQ-B389-001 Qualification Tests of Electrical Cables in a Simulated Steam 0

Line Break (SLB) and Loss-of-Coolant Accident (LOCA)

Environment

EEQ-T020-002 Electrical Equipment Qualification Data File - Target Rock - 13

2EE-001 & 76HH Series with Soft Seats and 98F-002 with

Hard Seats - Solenoid Valves

EEQ-B389-001 Electrical Equipment Qualification Data File - Brand-Rex 9

Corporation - 600 Volt, XLPE (Ultrol) Insulation, Hypalon or

Neoprene Jacket - Power and Control Cable and SIS Wire

EEQ-I206-001 Electrical Equipment Qualification Data File - ITT General 8

Controls - NH-95 - Hydramotor Actuator

Miscellaneous

Number Title Revision/

Date

EEQ-A385-001 Electrical Equipment Qualification Data File - Anaconda 10

Company, Wire and Cable Division - 600 Control Cable with

FREP Insulation, CPE

Jacket - Cable

EEQ-R369-002 Electrical Equipment Qualification Data File - Rosemount - 19

1153 Series B - Transmitter

Equipment Qualification Program Manual 26

SWMS No. 17- Assessment of the Environmental Qualification Program March 2,

01524 IP 71111.21N Readiness Inspection Self-Assessment 2018

PVNGS Operations Quality Assurance Program Description 0

EEQ-W120-003 Electrical Equipment Qualification Data File - Westinghouse - 12

WL-24202 and WL-24279 - PAMI EX-CORE Neutron Flux

Detector and Preamplifier Filter

EEQ-W120-004 Electrical Equipment Qualification Data File - Westinghouse 8

Motor Company - Life Line D (LLD) - Large AC Motors

EEQ-R098-002 Electrical Equipment Qualification Data File - Raychem - 12

NMCK8-1L, NMCK8-2L, NMCK8-1Y and NHVT - 5-8kV In-Line

and Wye Motor Connection Kit and 5kV Nuclear High Voltage

Termination

EEQ-S124-001 Electrical Equipment Qualification Data File - Skinner Valve 13

Division, Honeywell, Inc. - V5H Series - Solenoid Valves

EEQ-R098-004 Electrical Equipment Qualification Data File - Raychem 10

Corporation - WCSF-N - In-Line Splice

EEQ-D089-001 Electrical Equipment Qualification Data File - Transamerica 17

Delaval, Inc. Gems Sensor Division - XM-54852 and XM-54853

- Liquid Level Transmitter

EEQ-R352-001 Electrical Equipment Qualification Data File - Rockbestos - 11

Firewall III Irradiation and Chemically XLPE - 600 Volt Power,

Control and Instrumentation Cables and SIS Wire

EEQ-L200-001 Limitorque Valve Actuator Qualification for Nuclear Power 0

Station Service - Report 80058 - Tests Conducted Per IEEE

2-197Z, 323-1974, 344-1975

EEQ-C515-004 Electrical Equipment Qualification Data File - CONAX - 7371- 20

11000 Series - ECSA (Electric Conductor Seal Assembly)

EEQ-N007-001 Electrical Equipment Qualification Data File - Namco Controls - 21

EA180-Series - Limit Switches

Miscellaneous

Number Title Revision/

Date

MEE-00266 Shelf Life for Elastomers, Capacitors, Lubricants and other 13

limited shelf-life items

MEE-02212 Commodity Substitution Evaluation 3

MEE-00267 Shelf Life Extension Guidelines 7

VTD-R369- Rosemount Model 1153 Series B Alphaline Pressure 5

00012 Transmitters for Nuclear Service

13-NC-MS-0007 MSSS Equipment Qualification Thermal Lag Analysis 5

VTD-SI24-0009 Skinner Valve Options 0

VTD-I204-00036 ASCO General Controls (Formerly ITT Barton, Formerly ITT 5

General Controls) Installation and Maintenance Instructions for

NH90 Series Hydramotor Actuators, Model B & Model B1

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

73ST-9CL01 Containment Leakage Type B and C Testing 45

73ST-9DG01 Class 1E Diesel Generator and Integrated Safeguards Test 29

Train A

2PY-9RX06 Low Power Physics Testing Using STAR 5

40OP-9ZZ02 Initial Reactor Startup Following Refuelings 61

Work Orders (WOs)

4852735 4972486 4847637

Section 2RS01: Radiological Hazard Assessment and Exposure Controls

Procedures

Number Title Revision

75DP-0RP01 Radiation Protection (RP) Program Overview 12

75DP-0RP02 Radioactive Contamination Control 23

75DP-0RP08 Managing Radiological Risk 03

75DP-9RP01 Radiation Exposure and Access Control 21

75RP-0RP01 Radiological Posting and Labeling 35

Procedures

Number Title Revision

75RP-9RP02 Radiation Work Permits 32

75RP-9RP07 Radiological Surveys and Air Sampling 30

75RP-9RP10 Conduct of RP Operations 36

75RP-9RP26 Radioactive Source Control 17

75RP-9OP02 Control of High Radiation Areas, Locked High Radiation 31

Areas, and Very High Radiation Areas

Condition Reports (CRs)

17-15529 17-15451 17-15162 17-14592 17-15529

17-14592

Audits, Self-Assessments, and Surveillances

Title Date

2016 Annual ALARA Report June 23, 2017

Final 2016 Annual RP Program Summary Report July 27, 2018

Radiation Work Permits

Number Title Revision

3-1004 General Tours, Inspections, and Job Planning Walkdowns. 00

1-1523 Temp Mat Insulation Fiber Inspection 00

3-3306 Primary Side Steam Generator Maintenance 00

3-3319 Reactor Coolant Pump Maintenance 00

3-3521 Inboard Loop Discharge Check Valve Work 00

Miscellaneous

Title Date

Daily Plant Status Package April 23, 2018

Radioactive Source Inventory: Units 1, 2, and 3 (Source TRAX) January 18, 2018

LHRA/VHRA Key Control Inventory for Unit 3 April 23, 2018

Section 2RS03: In-Plant Airborne Radioactivity Control and Mitigation

Procedures

Number Title Revision

01DP-0IS08 Basis: PVNGS Respiratory Protection Equipment Usage 21a

01DP-0IS08 PVNGS Respiratory Protection Equipment Usage 20, 21

01DP-0IS10 Basis: PVNGS Respiratory Protection Program 12a

01DP-0IS10 PVNGS Respiratory Protection Program 11,12

75DP-9RP20 Control of Ventilation Units and HEPA Vacuums 4

75RP-0RP05 Control of Portable Air Filtration Systems 6

14FT-9FP79 Compressed Air Cylinder Inspection and Repair 0

14FT-9FP78 Respiratory Protection Equipment Inspection and Repair 3

75RP-9EE07 Operation of the AMS-4 CAM 23

75RP-9RP07 Radiological Surveys and Air Sampling 30

40OP-9CP01 Containment Purge System 27

40OP-9HA01 Auxiliary Building HVAC 32

40OP-9HF01 Fuel Building HVAC 34

Condition Reports (CRs)

16-06099 16-06578 17-01573 17-12846 17-15387

17-15451 18-01854

Audits, Self-Assessments, and Surveillances

Number Title Date

16-06578-008 SA Self-Assessment: Portable Air Filtration July 19, 2016

2016 Annual ALARA Report June 23, 2017

Final 2016 Annual RP Program Summary Report July 27, 2017

Ventilation System HEPA Filter Test

Work Orders Title Date

4609100 U3 Aux. Bldg. Normal Exhaust Ventilation May 17, 2017

4679401 U1 Aux. Bldg. Normal Exhaust Ventilation November 16, 2016

4682902 U1 Aux. Bldg. Normal Exhaust Ventilation October 25, 2016

Ventilation System HEPA Filter Test

Work Orders Title Date

4643239 U2 Aux. Bldg. Normal Exhaust Ventilation July 11, 2016

4715991 U2 Aux. Bldg. Normal Exhaust Ventilation February 6, 2017

4676166 U3 Aux. Bldg. Normal Exhaust Ventilation July 10, 2017

Miscellaneous

Number Title

WO 4845756 Supply Temporary Breathing Air

Nantel: Generic Respiratory Protection Training Student Guide

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number Title Revision

13-NS-C075 MSPI Basis Document 9

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

01DP-0XX01 Control and Monitoring of Potential Tornado Borne Missiles 4

40DP-9OP26 Operations Condition Reporting Process and Operability 44

Determination/Functional Assessment

Condition Reports (CRs)

18-06666 18-06827 18-08278 18-05192 18-07882

18-05427 18-07882 18-09032 18-05858

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

Number Title Revision

2OP-9RX01 Calculation of Estimated Critical Condition 31

40AO-9ZZ11 CEA Malfunctions 26

Condition Reports (CRs)

18-08965 18-08963 18-08952 18-08955 18-08909

18-08762 18-08748 18-10686

Miscellaneous

Title Date

CEAC1 data printout May 23, 2018

Event History Report May 23, 2018

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control

Number 31500011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

.

Information Request

February 12, 2018

Notification of Inspection and Request for Information

Palo Verde Nuclear Generating Station Unit 3

NRC Inspection Report 05000530/2018002

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: April 9-20, 2018

Inspector: James Melfi

A. Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or electronic

format (ims.certrec.com preferred), in care of James Melfi, by March 26, 2018, to facilitate

the selection of specific items that will be reviewed during the onsite inspection week. The

inspectors will select specific items from the information requested below and then request

from your staff additional documents needed during the onsite inspection week (Section B

of this enclosure). We ask that the specific items selected from the lists be available and

ready for review on the first day of inspection. Please provide requested documentation

electronically if possible. If requested documents are large and only hard copy formats are

available, please inform the inspector, and provide subject documentation during the first

day of the onsite inspection.

If you have any questions regarding this information request, please call the inspector as

soon as possible.

On April 9-20, 2018, a reactor inspector from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline inservice inspection at

Palo Verde Nuclear Generating Station, Unit 3, using NRC Inspection

Procedure 71111.08, "Inservice Inspection Activities. Experience has shown that this

inspection is a resource intensive inspection both for the NRC inspector and your staff.

The date of this inspection may change dependent on the outage schedule you provide.

In order to minimize the impact to your onsite resources and to ensure a productive

inspection, we have enclosed a request for documents needed for this inspection. These

documents have been divided into two groups. The first group (Section A of the

enclosure) identified information to be provided prior to the inspection to ensure that the

inspector is adequately prepared. The second group (Section B of the enclosure)

identifies the information the inspector will need upon arrival at the site. It is important that

all of these documents are up to date and complete in order to minimize the number of

additional documents requested during the preparation and/or the onsite portions of the

inspection.

We have discussed the schedule for these inspection activities with your staff and

understand that our regulatory contact for this inspection will be Ms. Lorraine Weaver of

your licensing organization. The tentative inspection schedule is as follows:

Preparation week: April 2-6, 2017

Onsite weeks: April 9-20, 2017

Our inspection dates are subject to change based on your updated schedule of outage

activities. If there are any questions about this inspection or the material requested,

please contact the lead inspector James Melfi at (817) 200-1523. (email to:

Jim.Melfi@nrc.gov).

A.1 ISI/Welding Programs and Schedule Information

1. A detailed schedule (including preliminary dates) of:

1.1. Nondestructive examinations planned for ASME Code Class Components

performed as part of your ASME Section XI, risk informed (if applicable), and

augmented inservice inspection programs during the upcoming outage.

1.2. Examinations planned for Alloy 82/182/600 components that are not included in

the Section XI scope (If applicable)

1.3. Examinations planned as part of your boric acid corrosion control program (Mode

walkdowns, bolted connection walkdowns, etc.)

1.4. Welding activities that are scheduled to be completed during the upcoming outage

(ASME Class 1, 2, or 3 structures, systems, or components)

2. A copy of ASME Section XI Code Relief Requests and associated NRC safety

evaluations applicable to the examinations identified above.

2.1. A list of ASME Code Cases currently being used to include the system and/or

component the Code Case is being applied to.

3. A list of nondestructive examination reports which have identified recordable or

rejectable indications on any ASME Code Class components since the beginning of

the last refueling outage. This should include the previousSection XI pressure test(s)

conducted during start up and any evaluations associated with the results of the

pressure tests.

4. A list including a brief description (e.g., system, code class, weld category,

nondestructive examination performed) associated with the repair/replacement

activities of any ASME Code Class component since the beginning of the last outage

and/or planned this refueling outage.

5. If reactor vessel weld examinations required by the ASME Code are scheduled to

occur during the upcoming outage, provide a detailed description of the welds to be

examined and the extent of the planned examination. Please also provide reference

numbers for applicable procedures that will be used to conduct these examinations.

6. Copy of any 10 CFR Part 21 reports applicable to structures, systems, or components

within the scope of Section XI of the ASME Code that have been identified since the

beginning of the last refueling outage.

7. A list of any temporary non-code repairs in service (e.g., pinhole leaks).

8. Please provide copies of the most recent self-assessments for the inservice

inspection, welding, and Alloy 600 programs.

9. Copy of the procedures for welding techniques, and NDE that will be used during the

outage.

A.2 Boric Acid Corrosion Control Program

1. Copy of the procedures that govern the scope, equipment and implementation of the

inspections required to identify boric acid leakage and the procedures for boric acid

leakage/corrosion evaluation.

2. Please provide a list of leaks (including code class of the components) that have been

identified since the last refueling outage and associated corrective action

documentation. If during the last cycle, the unit was shut down, please provide

documentation of containment walkdown inspections performed as part of the boric

acid corrosion control program.

A.3 Steam Generator Tube Inspections

1. A detailed schedule of:

• Steam generator tube inspection, data analyses, and repair activities for the

upcoming outage (if occurring).

• Steam generator secondary side inspection activities for the upcoming outage (if

occurring).

2. Copy of SG history documentation given to vendors performing eddy current (ET)

testing of the SGs during the upcoming outage.

3. Copy of procedure containing screening criteria used for selecting tubes for in-situ

pressure testing and the procedure to be used for in-situ pressure testing.

4. Copy of previous outage SG tube operational assessment. Also include a copy of the

following documents as they become available:

• Degradation assessment

• Condition monitoring assessment

5. Copy of the document defining the planned SG ET scope (e.g., 100 percent of

unrepaired tubes with bobbin probe and 20 percent sample of hot leg expansion

transition regions with rotating probe) and identify the scope expansion criteria, which

will be applied. Also identify and describe any deviations in this scope or expansion

criteria from the EPRI Guidelines.

6. Copy of the document describing the ET acquisition equipment to be applied including

ET probe types. Also identify the extent of planned tube examination coverage with

each probe type (e.g., rotating probe -0.080 inches, 0.115 inches pancake coils and

mid-range +point coil applied at the top-of-tube-sheet plus 3 inches to minus

inches).

7. Identify and quantify any SG tube leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and corrective

actions completed and planned for this condition.

8. Copy of steam generator eddy current data analyst guidelines and site validated eddy

current technique specification sheets. Additionally, please provide a copy of EPRI

Appendix H, Examination Technique Specification Sheets, qualification records.

9. Provide past history of the condition and issues pertaining to the secondary side of the

steam generators (including items such as loose parts, fouling, top of tube sheet

condition, crud removal amounts, etc.).

10. Indicate where the primary, secondary, and resolution analyses are scheduled to take

place.

A.4 Additional Information Related to all Inservice Inspection Activities

1. A list with a brief description of inservice inspection, and boric acid corrosion control

program related issues (e.g., PVAR) entered into your corrective action program since

the beginning of the last refueling outage. For example, a list based upon data base

searches using key words related to piping such as inservice inspection, ASME Code,

Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric acid, or errors

in piping examinations.

2. Provide training (e.g., Scaffolding, Fall Protection, FME, Confined Space) if they are

required for the activities described in A.1 through A.3.

3. Please provide names and phone numbers for the following program leads:

Inservice inspection (examination, planning)

Containment exams

Reactor pressure vessel head exams

Snubbers and supports

Repair and replacement program

Licensing

Site welding engineer

Boric acid corrosion control program

Steam generator inspection activities (site lead and vendor contact)

B. Information to be Provided Onsite to the Inspector(s) at the Entrance Meeting (April 9,

2017):

B.1 Inservice Inspection / Welding Programs and Schedule Information

1. Updated schedules for inservice inspection/nondestructive examination activities,

including planned welding activities, and schedule showing contingency repair plans, if

available.

2. For ASME Code Class welds selected by the inspector from the lists provided from

section A of this enclosure, please provide copies of the following documentation for

each subject weld:

• Weld data sheet (traveler).

• Weld configuration and system location.

• Applicable Code Edition and Addenda for weldment.

• Applicable Code Edition and Addenda for welding procedures.

• Applicable welding procedures used to fabricate the welds.

• Copies of procedure qualification records (PQRs) supporting the weld procedures

from B.1.b.v.

• Copies of welders performance qualification records (WPQ).

• Copies of the nonconformance reports for the selected welds (If applicable).

• Radiographs of the selected welds and access to equipment to allow viewing

radiographs (if radiographic testing was performed).

• Copies of the preservice examination records for the selected welds.

• Readily accessible copies of nondestructive examination personnel qualifications

records for reviewing.

3. For the inservice inspection related corrective action issues selected by the inspector

from section A of this enclosure, provide a copy of the corrective actions and

supporting documentation.

4. For the nondestructive examination reports with relevant conditions on ASME Code

Class components selected by the inspector from Section A above, provide a copy of

the examination records, examiner qualification records, and associated corrective

action documents.

5. A copy of (or ready access to) most current revision of the inservice inspection

program manual and plan for the current interval.

6. For the nondestructive examinations selected by the inspector from section A of this

enclosure, provide a copy of the nondestructive examination procedures used to

perform the examinations (including calibration and flaw characterization/sizing

procedures). For ultrasonic examination procedures qualified in accordance with

ASME Code,Section XI, Appendix VIII, provide documentation supporting the

procedure qualification (e.g., the EPRI performance demonstration qualification

summary sheets). Also, include qualification documentation of the specific equipment

to be used (e.g., ultrasonic unit, cables, and transducers including serial numbers) and

nondestructive examination personnel qualification records.

B.2 Boric Acid Corrosion Control Program

1. Please provide boric acid walk down inspection results, an updated list of boric acid

leaks identified so far this outage, associated corrective action documentation, and

overall status of planned boric acid inspections.

2. Please provide any engineering evaluations completed for boric acid leaks identified

since the end of the last refueling outage. Please include a status of corrective actions

to repair and/or clean these boric acid leaks. Please identify specifically which known

leaks, if any, have remained in service or will remain in service as active leaks.

B.3 Steam Generator Tube Inspections

1. Copies of the Examination Technique Specification Sheets and associated justification

for any revisions.

2. Please provide a copy of the eddy current testing procedures used to perform the

steam generator tube inspections (specifically calibration and flaw

characterization/sizing procedures, etc.).

3. Copy of the guidance to be followed if a loose part or foreign material is identified in

the steam generators.

4. Identify the types of SG tube repair processes which will be implemented for defective

SG tubes (including any NRC reviews/evaluations/approvals of this repair process).

Provide the flaw depth sizing criteria to be applied for ET indications identified in the

SG tubes.

5. Copy of documents describing actions to be taken if a new SG tube degradation

mechanism is identified.

6. Provide procedures with guidance/instructions for identifying (e.g. physically locating

the tubes that require plugging) and plugging SG tubes.

7. List of corrective action documents generated by the vendor and/or site with respect to

steam generator inspection activities.

B.4 Codes and Standards

1. Ready access to (i.e., copies provided to the inspector(s) for use during the inspection

at the onsite inspection location, or room number and location where available):

• Applicable Editions of the ASME Code (Sections V, IX, and XI) for the inservice

inspection program and the repair/replacement program.

2. Copy of the performance demonstration initiative (PDI) generic procedures with the

latest applicable revisions that support site qualified ultrasonic examinations of piping

welds and components (e.g., PDI-UT-1, PDI-UT-2, PDI-UT-3, PDI-UT-10, etc.).

3. Boric Acid Corrosion Guidebook Revision 1 - EPRI Technical Report 1000975.

The following items are requested for the

Occupational Radiation Safety Inspection

at Palo Verde Nuclear Generating Station

April 23-27, 2018

Integrated Report 2018002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before April 17, 2018

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817)200-1221,

Louis.Carson@nrc.gov or Shawn Money at (817) 200-1466, Shawn.Money@nrc.gov

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: October 16, 2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since date of last inspection, related to this

inspection area

D. Procedure indexes for the radiation protection procedures

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radworker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and subtiered systems) since

date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

If not covered above, a summary of corrective action documents since date of last

inspection involving unmonitored releases, unplanned releases, or releases in which any

dose limit or administrative dose limit was exceeded (for Public Radiation Safety

Performance Indicator verification in accordance with IP 71151)

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

I. Radioactive source inventory list

a. All radioactive sources that are required to be leak tested

b. All radioactive sources that meet the 10 CFR Part 20, Appendix E, Category 2 and

above threshold. Please indicate the radioisotope, initial and current activity (w/assay

date), and storage location for each applicable source.

J. The last two leak test results for the radioactive sources inventoried and required to be

leak tested. If applicable, specifically provide a list of all radioactive source(s) that have

failed its leak test within the last two years

K. A current listing of any non-fuel items stored within your pools, and if available, their

appropriate dose rates (Contact / @ 30cm)

L. Computer printout of radiological controlled area entries greater than 100 millirems since

the previous inspection to the current inspection entrance date. The printout should

include the date of entry, some form of worker identification, the radiation work permit

used by the worker, dose accrued by the worker, and the electronic dosimeter dose

alarm setpoint used during the entry (for Occupational Radiation Safety Performance

Indicator verification in accordance with IP 71151).

3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection: April 22, 2016

A. List of contacts and telephone numbers for the following areas:

1. Respiratory Protection Program

2. Self-contained breathing apparatus

B. Applicable organization charts

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support

(SCBA), and LERs, written since date of last inspection related to:

1. Installed air filtration systems

2. Self-contained breathing apparatuses

D. Procedure index for:

1. Use and operation of continuous air monitors

2. Use and operation of temporary air filtration units

3. Respiratory protection

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Respiratory protection program

2. Use of self-contained breathing apparatuses

3. Air quality testing for SCBAs

4. Use of installed plant systems, such as containment purge, spent fuel pool

ventilation, and auxiliary building ventilation

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection, related to the Airborne Monitoring program

including:

1. Continuous air monitors

2. Self-contained breathing apparatuses

3. Respiratory protection program

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. List of SCBA qualified personnel - reactor operators and emergency response personnel

H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant

for use since date of last inspection.

I. SCBA training and qualification records for control room operators, shift supervisors,

STAs, and OSC personnel for the last year.

A selection of personnel may be asked to demonstrate proficiency in donning, doffing,

and performance of functionality check for respiratory devices

J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,

and model.

ML18218A583

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JDixon Yes No Publicly Available Sensitive NRC-002

OFFICE DRP/SRI DRP/RI DRP/RI C:DRS/EB1 C:DRS/EB2 C:DRS/OB

NAME CPeabody DReinert DYou TFarnholtz JDrake VGaddy

SIGNATURE CAP DRR DDY TRF JFD vgg

DATE 8/1/18 8/1/18 8/1/18 08/06/2018 08/02/2018 8/2/2018

OFFICE C:DRS/PS2 TL:IPAT C:DRP/D

NAME HGepford GGeorge NOKeefe

SIGNATURE HJG GAG NFO

DATE 08/06/18 08/06/2018 08/06/2018