IR 05000528/2018002
| 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
August 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:
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
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 Aspect Report Section Mitigating Systems
Green NCV 05000528/2018002-01 Closed
[H.1] - Human Performance,
Avoid Complacency 71111.12 -
Maintenance Effectiveness 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 Aspect Report Section Occupational Radiation Safety Green NCV 05000528/2018002, 05000529/2018002,05000530/2018002-02 Closed
[H.4] - Human Performance,
Teamwork 71124.03 -
In-Plant Airborne 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 Aspect Report Section Mitigating Systems
Green NCV 05000530/2018002-03 Closed
[H.13] - Human Performance,
Consistent Process 71152 -
Problem Identification 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness (1 Sample)
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 (4 Samples)
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 (6 Samples)
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 (1 Sample)
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:
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 (1 Sample)
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 (3 Samples)
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,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls
Instructions to Workers (1 Sample)
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 (1 Sample)
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 (1 Sample)
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 Aspect Report Section Mitigating Systems
Green NCV 05000528/2018002-01 Closed
[H.1] - Human Performance, Avoid Complacency
71111.12 - Maintenance
Effectiveness 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 Aspect Report Section Occupational Radiation Safety Green NCV 05000528/2018002, 05000529/2018002,05000530/2018002-02 Closed
[H.4] - Human Performance, Teamwork
71124.03 - In-Plant
Airborne 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 Aspect Report Section Mitigating Systems
Green NCV 05000530/2018002-03 Closed
[H.13] -
Human Performance, Consistent Process
71152 - Problem
Identification 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 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
Hot Weather Protection
Acts of Nature
Panel B01B Alarm Responses
Switchyard Administrative Control
Degraded Electrical Power
Inoperable Power Sources Action Statement
Condition Reports (CRs)
2879765
2873519
Work Orders (WOs)
3050186
Miscellaneous
Number
Title
Revision
ODP 10
Operations Department External Communications Practices
Section 1R04: Equipment Alignment
Procedures
Number
Title
Revision
Control Element Drive Mechanism Control System
(CEDMCS) Operation
Local Alarm Panel J-SFN-C01D Responses
Essential Spray Pond (SP) B
Auxiliary Feedwater Pump AFB-P01 Monthly Valve
Alignment
Drawings
Number
Title
Revision
01-M-EWP-001
P&I Diagram Essential Cooling Water System
01-P-EWF-201
Auxiliary Bldg. Isometric Essential Cooling Water System
ECWS Pump Loop - Train A
01-P-EWF-202
Auxiliary Bldg. Isometric Essential Cooling Water System
ECWS Pump Loop - Train B
01-P-EWF-301
Control Building Isometric Essential Cooling Water System
01-M-SPP-001
P&I Essential Spray Pond System
01-M-AFP-001
P&I Diagram Auxiliary Feedwater System
Condition Reports (CRs)
18-06844
16-20392
Section 1R05: Fire Protection
Procedures
Number
Title
Revision
Functional Test of Appendix R Fire/HELB Doors
Control of Transient Combustibles
Condition Reports (CRs)
18-05400
18-05170
Miscellaneous
Number
Title
Revision
PVNGS Pre-Fire Strategies Manual
Section 1R07: Heat Sink Performance
Procedures
Number
Title
Revision
Maintenance Rule
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
Boric Acid Walkdown Leak Detection
Welding and Brazing Control
Weld Filler Material Control
Boric Acid Corrosion Control Program
Ultrasonic Instrument Calibration
Ultrasonic Thickness Measurement
Radiographic Examination
Steam Generator Eddy Current Examinations
Dry Magnetic Particle Examination
Wet Magnetic Particle Examination
Liquid Penetrant Examination
Ultrasonic Examination of Pipe and Vessel Welds
Ultrasonic Examination of Welds in Ferritic Components
Visual Examination of Welds, Bolting, and Components
Visual Examination of Component Supports
Visual Examination for Leakage
Welding of Ferritic and Martensitic Steels
Classification of Structures, Systems, and Components
Classification of Structures, Systems, and Components
Palo Verde Nuclear Generating Station Steam Generator
Management Program
NS-FS-FSO-WI-
0006
Palo Verde Nuclear Generating Station Steam Generator
Visual Examination (Rolls-Royce Proprietary)
6.1
PDI-UT-1
Performance Demonstration Initiative (PDI) Generic Procedure
for the Ultrasonic Examination of Ferritic Pipe Welds
Procedures
Number
Title
Revision
PDI-UT-10
PDI Generic Procedure for the Ultrasonic Examination of
PDI-UT-11
PDI Generic Procedure for the Ultrasonic Examination of
Reactor Pressure Vessel Nozzle-to-Shell Welds and the Nozzle
Inner Corner Radius
PDI-UT-2
PDI Generic Procedure for the Ultrasonic Examination of
Austenitic Pipe Welds
PDI-UT-3
PDI Generic Procedure for Ultrasonic Through-Wall Sizing in
Pipe Welds
PDI-UT-8
PDI Generic Procedure for the Ultrasonic Examination of Weld
Overlaid Similar and Dissimilar Metal Welds
Drawings
Number
Title
Revision/Date
03-M-PCP-00,
Sheet 1 of 2
Piping and Instrumentation Diagram (P&ID) Fuel Pool
Cooling and Cleanup System
03-M-PCP-00,
Sheet 2 of 2
P&ID Fuel Pool Cooling and Cleanup System
03-M-PCP-0001 P&ID Fuel Pool Cooling and Cleanup System
03-P-SGF-120
Containment Building Isometric Main Steam System
Feedwater Lines
13-C-ZCS-504
Containment Internals Refueling Pool Liner, Sheet 5
13-C-ZCS-504
Containment Internals Refueling Pool Stainless Steel
Liner, Sheet 5
13-C-ZFS-0422
Fuel Building Liner Plate, Sections and Details, Sheet 3
13-C-ZFS-422
Fuel Building Liner Plate, Sections and Details, Sheet 3
C-113-4046
Inch Double Non-Equalizing Expansion Joint with
Weld Ends
March 26, 1979
D-SYS80-630-
054
Transfer Tube Weldment and Flange
E-SYS80-630-
055, Sheet 1 of 2
Fuel Transfer Tube Assembly
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,
Unit 3, Cycle 18
April 12, 2015
03-MS-A155
U3R19 Steam Generator Degradation
Assessment/Operational Assessment Review
October 1, 2016
17-09564
Welding Program Self-Assessment
June 30, 2017
N001-5.03-
00052-1
Transfer Tube Weldment and Flange
N001-5.03-
00399-
General Engineering Specification for Fuel Transfer
Tube
June 6, 1984
SDOC N001-
0503-00053(2)
Fuel Transfer Tube Assembly
Section 1R11: Licensed Operator Requalification Program and Licensed Operator
Performance
Miscellaneous
Number
Title
Revision
Conduct of Operations
Power Operations
148
Standard Maneuver Plan: 150 EFPD 100 to 40%
Section 1R12: Maintenance Effectiveness
Procedures
Number
Title
Revision
Essential Spray Pond B
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
Essential Cooling Water System Health Report
2nd Quarter
2018
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
Number
Title
Revision
Operations Department Online Nuclear Risk Management
Mode 1 and 2
Conduct of Operations
Drawings
Number
Title
Revision
21010-9
Solenoid Operated Valve Soft Seated Energize to Open
Sizes 3/8 through 2
B
03-M-SIP-002
P&I Diagram Safety Injection and Shutdown Cooling
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
Control Room Fire
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
Lists T7.0.100 and T7.0.200
March 30, 2018
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
potential operability concerns
Section 1R18: Plant Modifications
Procedures
Number
Title
Revision
BOP-ESFAS Modules Operation
Work Orders (WOs)
4989102
4690453
28616
4544651
Section 1R19: Post-Maintenance Testing
Procedures
Number
Title
Revision
Diesel Fuel Oil Transfer Pumps - Inservice Test
4.16kV Motor Operational Testing
Safety Injection Tank Nitrogen Vent Valves-Inservice Test
Condition Reports (CRs)
18-05813
18-08963
Work Orders (WOs)
26942
4381898
4981134
4850125
4852867
4852923
5007848
Miscellaneous
Number
Title
Revision/Date
Withdrawal, Cutup, Installation and Insertion of Incore
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
388046
Clearance for SIT 2A outage
Section 1R21N: Design Bases Assurance Inspection (Programs)
Procedures
Number
Title
Revision
Stores
Commercial Grade Dedication (CGD) Process
Drawings
Number
Title
Revision
03-P-SGF-155
M.S.S.S. Isometric Main Steam
03-E-SGF-023,
Sh. 2
Control Wiring Diagram Main Steam System Main Steam
Isolation Valve 3J-SGE-UV-170
F-5160
Logic Diagram for Anchor/Darling Hydraulic Actuator F-5157
and F-5160
B
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
Line Break (SLB) and Loss-of-Coolant Accident (LOCA)
Environment
EEQ-T020-002
Electrical Equipment Qualification Data File - Target Rock -
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
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
Controls - NH-95 - Hydramotor Actuator
EEQ-A385-001
Electrical Equipment Qualification Data File - Anaconda
Company, Wire and Cable Division - 600 Control Cable with
FREP Insulation, CPE
Jacket - Cable
EEQ-R369-002
Electrical Equipment Qualification Data File - Rosemount -
1153 Series B - Transmitter
Equipment Qualification Program Manual
SWMS No. 17-
01524
Assessment of the Environmental Qualification Program
IP 71111.21N Readiness Inspection Self-Assessment
March 2,
2018
PVNGS Operations Quality Assurance Program Description
EEQ-W120-003
Electrical Equipment Qualification Data File - Westinghouse -
WL-24202 and WL-24279 - PAMI EX-CORE Neutron Flux
Detector and Preamplifier Filter
EEQ-W120-004
Electrical Equipment Qualification Data File - Westinghouse
Motor Company - Life Line D (LLD) - Large AC Motors
EEQ-R098-002
Electrical Equipment Qualification Data File - Raychem -
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
Division, Honeywell, Inc. - V5H Series - Solenoid Valves
Miscellaneous
Number
Title
Revision/
Date
EEQ-R098-004
Electrical Equipment Qualification Data File - Raychem
Corporation - WCSF-N - In-Line Splice
EEQ-D089-001
Electrical Equipment Qualification Data File - Transamerica
Delaval, Inc. Gems Sensor Division - XM-54852 and XM-54853
- Liquid Level Transmitter
EEQ-R352-001
Electrical Equipment Qualification Data File - Rockbestos -
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
Station Service - Report 80058 - Tests Conducted Per IEEE
2-197Z, 323-1974, 344-1975
EEQ-C515-004
Electrical Equipment Qualification Data File - CONAX - 7371-
11000 Series - ECSA (Electric Conductor Seal Assembly)
EEQ-N007-001
Electrical Equipment Qualification Data File - Namco Controls -
EA180-Series - Limit Switches
MEE-00266
Shelf Life for Elastomers, Capacitors, Lubricants and other
limited shelf-life items
MEE-02212
Commodity Substitution Evaluation
MEE-00267
Shelf Life Extension Guidelines
VTD-R369-
00012
Rosemount Model 1153 Series B Alphaline Pressure
Transmitters for Nuclear Service
13-NC-MS-0007
MSSS Equipment Qualification Thermal Lag Analysis
VTD-SI24-0009
Skinner Valve Options
VTD-I204-00036 ASCO General Controls (Formerly ITT Barton, Formerly ITT
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
Line Break (SLB) and Loss-of-Coolant Accident (LOCA)
Environment
EEQ-T020-002
Electrical Equipment Qualification Data File - Target Rock -
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
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
Controls - NH-95 - Hydramotor Actuator
Miscellaneous
Number
Title
Revision/
Date
EEQ-A385-001
Electrical Equipment Qualification Data File - Anaconda
Company, Wire and Cable Division - 600 Control Cable with
FREP Insulation, CPE
Jacket - Cable
EEQ-R369-002
Electrical Equipment Qualification Data File - Rosemount -
1153 Series B - Transmitter
Equipment Qualification Program Manual
SWMS No. 17-
01524
Assessment of the Environmental Qualification Program
IP 71111.21N Readiness Inspection Self-Assessment
March 2,
2018
PVNGS Operations Quality Assurance Program Description
EEQ-W120-003
Electrical Equipment Qualification Data File - Westinghouse -
WL-24202 and WL-24279 - PAMI EX-CORE Neutron Flux
Detector and Preamplifier Filter
EEQ-W120-004
Electrical Equipment Qualification Data File - Westinghouse
Motor Company - Life Line D (LLD) - Large AC Motors
EEQ-R098-002
Electrical Equipment Qualification Data File - Raychem -
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
Division, Honeywell, Inc. - V5H Series - Solenoid Valves
EEQ-R098-004
Electrical Equipment Qualification Data File - Raychem
Corporation - WCSF-N - In-Line Splice
EEQ-D089-001
Electrical Equipment Qualification Data File - Transamerica
Delaval, Inc. Gems Sensor Division - XM-54852 and XM-54853
- Liquid Level Transmitter
EEQ-R352-001
Electrical Equipment Qualification Data File - Rockbestos -
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
Station Service - Report 80058 - Tests Conducted Per IEEE
2-197Z, 323-1974, 344-1975
EEQ-C515-004
Electrical Equipment Qualification Data File - CONAX - 7371-
11000 Series - ECSA (Electric Conductor Seal Assembly)
EEQ-N007-001
Electrical Equipment Qualification Data File - Namco Controls -
EA180-Series - Limit Switches
Miscellaneous
Number
Title
Revision/
Date
MEE-00266
Shelf Life for Elastomers, Capacitors, Lubricants and other
limited shelf-life items
MEE-02212
Commodity Substitution Evaluation
MEE-00267
Shelf Life Extension Guidelines
VTD-R369-
00012
Rosemount Model 1153 Series B Alphaline Pressure
Transmitters for Nuclear Service
13-NC-MS-0007
MSSS Equipment Qualification Thermal Lag Analysis
VTD-SI24-0009
Skinner Valve Options
VTD-I204-00036 ASCO General Controls (Formerly ITT Barton, Formerly ITT
General Controls) Installation and Maintenance Instructions for
NH90 Series Hydramotor Actuators, Model B & Model B1
Section 1R22: Surveillance Testing
Procedures
Number
Title
Revision
Containment Leakage Type B and C Testing
Class 1E Diesel Generator and Integrated Safeguards Test
Train A
Low Power Physics Testing Using STAR
Initial Reactor Startup Following Refuelings
Work Orders (WOs)
4852735
4972486
4847637
Section 2RS01: Radiological Hazard Assessment and Exposure Controls
Procedures
Number
Title
Revision
Radiation Protection (RP) Program Overview
Radioactive Contamination Control
Managing Radiological Risk
Radiation Exposure and Access Control
Radiological Posting and Labeling
Procedures
Number
Title
Revision
Radiation Work Permits
Radiological Surveys and Air Sampling
Conduct of RP Operations
Radioactive Source Control
Control of High Radiation Areas, Locked High Radiation
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.
1-1523
Temp Mat Insulation Fiber Inspection
3-3306
Primary Side Steam Generator Maintenance
3-3319
Reactor Coolant Pump Maintenance
3-3521
Inboard Loop Discharge Check Valve Work
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
Basis: PVNGS Respiratory Protection Equipment Usage
21a
PVNGS Respiratory Protection Equipment Usage
20, 21
Basis: PVNGS Respiratory Protection Program
2a
PVNGS Respiratory Protection Program
11,12
Control of Ventilation Units and HEPA Vacuums
Control of Portable Air Filtration Systems
Compressed Air Cylinder Inspection and Repair
Respiratory Protection Equipment Inspection and Repair
Operation of the AMS-4 CAM
Radiological Surveys and Air Sampling
Containment Purge System
Auxiliary Building HVAC
Fuel Building HVAC
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
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
Section 4OA2: Problem Identification and Resolution
Procedures
Number
Title
Revision
Control and Monitoring of Potential Tornado Borne Missiles
Operations Condition Reporting Process and Operability
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
Calculation of Estimated Critical Condition
CEA Malfunctions
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.
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: JDixon
Yes No
Publicly Available
Sensitive
OFFICE
DRP/SRI
DRP/RI
DRP/RI
C:DRS/EB1
C:DRS/EB2
C:DRS/OB
NAME
CPeabody
DReinert
DYou
TFarnholtz
JDrake
VGaddy
SIGNATURE
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
DATE
08/06/18
08/06/2018
08/06/2018