IR 05000528/2018004

NRC Integrated Inspection Report 05000528/2018004, 05000529/2018004, and 05000530/2018004

ML19031B145
Person / Time
Site:	Palo Verde
Issue date:	01/29/2019
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-D
To:	Bement R Arizona Public Service Co
References
IR 2018004
Download: ML19031B145 (41)

Text

ary 29, 2019

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2018004, 05000529/2018004, AND 05000530/2018004

Dear Mr. Bement:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On January 2, 2019, the NRC inspectors discussed the results of this inspection with Mr. Bruce Rash and other members of your staff. The results of this inspection are documented in the enclosed report.

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

Both of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. Further, inspectors documented a licensee-identified violation which was determined to be Severity Level IV in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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 or a finding not associated with a regulatory requirement 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 F. OKeefe, 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 05000528/2018004, 05000529/2018004, 05000530/2018004 w/Attachments:

1. Documents Reviewed 2. Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000528, 05000529, 05000530 License Numbers: NPF-41, NPF-51, NPF-74 Report Numbers: 05000528/2018004, 05000529/2018004, and 05000530/2018004 Enterprise Identifier: I-2018-004-0013 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: 5801 South Wintersburg Road, Tonopah, AZ 85354 Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, PhD, Resident Inspector D. You, Resident Inspector W. Sifre, Senior Reactor Inspector J. Drake, Senior Reactor Inspector C. Osterholtz, Senior Operations Engineer C. Smith, Reactor Inspector C. Stott, Reactor Inspector S. Hedger, Emergency Preparedness Inspector N. Hernandez, Operations Engineer Approved By: N. OKeefe, Chief Project Branch D, Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting baseline inspections 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.

NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.

List of Findings and Violations Failure to Properly Preplan Corrective Maintenance Cornerstone Significance Cross-cutting Inspection Aspect Procedure Initiating Green [H.5] - 71111.13 Event NCV 05000529/2018004-001 Human Closed Performance, Maintenance Work Risk and Management Emergent Work Control The inspectors reviewed a Green, self-revealing, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, while planning replacement of an automatic control element drive mechanism timer module (ACTM) card, the licensee failed to provide instructions that would prevent unseating the adjacent ACTM card and losing electrical continuity or else plan the work for a plant mode that would not result in a plant transient. This caused a control element assembly to drop to the bottom of the core resulting in an automatic reactor trip.

Failure to Establish an Adequate Procedure for Control of Potential Tornado Borne Missiles Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green [H.3] - 71111.20 Systems NCV 05000529/2018004-002 Human Refueling and Closed Performance, Other Outage Change Activities Management 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 prescribe instructions appropriate to the circumstances for the control and monitoring of transient missile hazards that have the potential to affect the operability of the essential spray ponds.

PLANT STATUS

Units 1 and 3 operated at or near full power for the entire inspection period.

Unit 2 operated at full power with the exception of a planned refueling outage which lasted from October 6, 2018 - December 3,

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. [Include for integrated report: 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

71111.04Equipment Alignment Partial Walkdown

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

(1) Unit 2 shutdown cooling system A, on October 12, 2018

(2) Unit 3 high pressure injection system A, on November 14, 2018

(3) Unit 1 Class 1E 480V motor control centers system A, on December 20, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

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

(1) Unit 3 electrical penetration rooms, Fire Zones 42 A and 42B, on October 1, 2018

(2) Unit 2 main steam support structure 140 elevation, Fire Zones 74A and 74B, on October 3, 2018

(3) Unit 2 containment near steam generator #2 economizer line, Fire Zone 63A, on October 17, 2018

(4) Unit 3 fuel building, Fire Zones 27, 28, and 29, on October 18, 2018

(5) Unit 1 main control room, Fire Zone 17 on November 16, 2018

71111.07Heat Sink Performance Heat Sink (Triennial)

The inspectors evaluated exchanger/sink performance on the following components November 6, 2018, to November 9, 2018:

(1) Unit 2 Essential Cooling Water Heat Exchanger B, Section 02.02b

(2) Unit 1 Essential Chiller A, Section 02.02c

(3) Unit 1 Fuel Pool Cooling Heat Exchanger B, Section 02.02c

(4) Unit 3 Auxiliary Feedwater Pump Turbine Oil Cooler, Section 02.02c

71111.08Inservice Inspection Activities (Unit 2)

The inspectors evaluated non-destructive examination activities by observing the following activities:

(1) Ultrasonic Examinations a) Data Sheet 2-053-013 on steam to auxiliary feedwater system b) Data Sheet 2-054-006A on Steam Generator 1 feedwater system c) Data Sheet 2-054-010A on Steam Generator 1 feedwater system

(2) Dye Penetrant Examinations a) Data Sheet 2-054-005-NW-1-18-PT-2003 on Steam Generator 1 feedwater system b) Data Sheet 2-054-006A-18-PT-2004 on Steam Generator 1 feedwater system

(3) Phased Array Ultrasonic Examinations Data Sheet 2-027-009-011 on Pressurizer Spray 1A

(4) Radiography Examination Data Sheet 18-946 on Steam Generator 1 feedwater system The inspector evaluated non-destructive examination activities by reviewing the following activities:

(1) Ultrasonic Examinations a) Data Sheet 2-058-001-NW-1 on Steam Generator 1 auxiliary feedwater system b) Data Sheet 2-058-004-NW-1 on Steam Generator 1 auxiliary feedwater system c) Data Sheet 2-058-019 on Steam Generator 1 auxiliary feedwater system

(2) Dye Penetrant Examinations a) Data Sheet 2-058-001-NW-1-18-PT-2007 on Steam Generator 1 auxiliary feedwater system b) Data Sheet 2-058-004-NW-1-18-PT-2006 on Steam Generator 1 auxiliary feedwater system c) Data Sheet 2-058-019-18-PT-2001 on Steam Generator 1 auxiliary feedwater system

(3) Magnetic Particle Examinations a) Data Sheet 2-053-013-18-MT-2012 on steam to auxiliary feedwater system b) Data Sheet 2-054-010A-18-MT-2011 on Steam Generator 2 feedwater system

(4) Phased Array Ultrasonic Examinations a) Data Sheet 2-032-008-018 on Reactor Coolant Loop 1A drain a) Data Sheet 2-033-010-018 on Reactor Coolant Loop 1B drain b) Data Sheet 2-028-011-011 on Pressurizer Spray 1B c) Data Sheet 2-037-013-011 on Charging 2A d) Data Sheet 2-034-012-018 on Reactor Coolant Loop 2A drain e) Data Sheet 2-036-014-018 on Letdown 2B The inspector evaluated welding activities by reviewing the following records:

Gas Tungsten Arc Welding (GTAW)a) Weld Data Sheet 5024637 on Steam Generator 1 feedwater system b) Weld Data Sheet 5024646 on Steam Generator 2 feedwater system The Inspector evaluated the licensees boric acid control program performance.

The licensee did not perform a bare metal head inspection on the Unit 2 reactor vessel upper head penetrations.

The licensee did not perform steam generator tube eddy current examinations on the Unit 2 steam generators.

The Inspector evaluated a sample of condition reports associated with inservice inspection activities.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated licensed operator continuing training simulator scenario on November 28, 2018. The inspectors assessed the performance of the operators and control room simulator.

Operator Performance (1 Sample)

The inspectors observed and evaluated operators performing a planned reactor coolant system cooldown for a refueling outage on October 6, 2018, and synchronizing the main generator to the grid following a stator rewind on December 3, 2018.

Operator Exams (1 Sample)

The inspectors reviewed and evaluated requalification examination results on December 27, 2018.

Operator Requalification Program (1 Sample)

The inspectors evaluated the operator requalification program from September 24, 2018, to December 27, 2018.

71111.12Maintenance Effectiveness Quality Control

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Unit 2 polar crane replacement parts acceptance review, on October 30, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control

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

(1) Unit 1 emergent risk assessment due to the failure of safety injection system valve 660, on October 4, 2018

(2) Units 1, 2, and 3, emergent risk due to unplanned loss of the west switchyard bus, on October 4, 2018

(3) Unit 2 outage risk assessment during reactor coolant system lowered inventory, on October 12, 2018

(4) Unit 2 reactor trip due to dropped control element assembly, on May 23, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 high pressure safety injection pump B operability during refueling water tank recirculation, on October 16, 2018

(2) Unit 2 reactor coolant system operability following the identification of reactor head O-ring groove indication, on November 15, 2018

(3) Unit 2 control room envelope allowable open area during maintenance/modification on the control room envelope boundary, on November 16, 2018

(4) Unit 2 evaluation of visual indications on fuel assemblies, on November 16, 2018

71111.18Plant Modifications

The inspectors evaluated the permanent modification DMWO 3282819 Polar Crane Upgrade on November 5, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) 73ST-9ZZ25, Unit 2 boration flow path check valve testing following disassembly and inspection, on October 29, 2018

(2) 73ST-9XI33, Unit 2 high pressure safety injection pump B full flow test and vibration readings, on October 30, 2018

(3) 40ST-9DG01, Unit 3 diesel generator A surveillance test following spray pond pump A failure to start and spray pond pump breaker replacement, on November 2, 2018

(4) 36ST-9SB04, Unit 3 plant protection system test of the main steam isolation signal channel B following an erroneous half-leg trip, on December 11, 2018

71111.20Refueling and Other Outage Activities

The inspectors evaluated refueling outage 2R21 activities from October 6, 2018, to December 3, 2018.

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

(1) 73ST-9SI06, Unit 1 B train containment spray pump, on December 20, 2018

In-service (1 Sample)

(1) Unit 2 low pressure safety injection system A check valve 134 inservice test, on

October 9, 2018 Containment Isolation Valve (1 Sample)

(1) Unit 2 local leak rate testing of electrical and mechanical penetrations, on October 23, 2018

71114.04Emergency Action Level and Emergency Plan Changes

The inspector evaluated Palo Verde Nuclear Generating Station Emergency Plan, Revision 62, submitted on September 25, 2018; and Revision 63, submitted on December 6, 2018. Associated 10 CFR 50.54(q) emergency plan change process documentation was reviewed as well. The evaluation was performed in-office from December 3, 2018, to December 14, 2018. This evaluation does not constitute NRC approval.

OTHER ACTIVITIES - BASELINE

71152Problem Identification and Resolution Semiannual Trend Review

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

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Unit 2 containment liner punch marks

(2) Units 1 and 2 excore nuclear instruments missing O-rings at preamplifier-filter connections

71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000528/2018-001-00, automatic actuation of the reactor protection system resulting from a loss of reactor coolant pumps, on February 15, 2018

(2) Licensee Event Report 05000528/2018-003-00, condition prohibited by technical specification 3.7.4 due to inoperable atmospheric dump valve, on May 14, 2018

(3) Licensee Event Report 05000528/2018-004-00 and 05000528/2018-004-01, engineered safety feature pump room exhaust air cleanup system failure resulting in a condition prohibited by technical specifications, on May 17, 2018

(4) Licensee Event Report 05000529/2018-001-00, Unit 2 reactor trip due to dropped control element assembly, on May 23,

INSPECTION RESULTS

Observation 71152 Problem Identification and Resolution The inspectors reviewed the licensees response to a negative trend noted on their reactor vessel O-ring, specifically, the inner O-ring. The reactor vessel closure head interfaces with the reactor vessel by a raised face flanged design containing two metallic O-ring seals.

Between the inner and outer O-rings on the reactor vessel mating surface is a port that is piped to the reactor drain tank. This small pipe is also connected to a pressure instrument which is used to determine if a leak past the inner O-ring exists.

On November 5, 2017, Unit 1 had indication of rising pressure in the area between the inner and outer reactor vessel O-rings (CR 17-16139). On May 4, 2018, Unit 3 had a similar indication of rising pressure (CR 18-07701). Both of these cases indicate that there is leakage past the inner O-ring. However, there has yet to be indication of any leakage past the outer O-ring. It should be noted that in both cases, the leakage was observed shortly after coming out of a planned refueling outage.

Noting these two adverse trends, the licensee elected to perform an evaluation on the handling and installation of the metallic O-rings during the Unit 2 refueling outage which took place from October 6, 2018, to December 3, 2018. The licensee had the O-ring vendor Technetics onsite to perform the evaluation. Although the vendor did not observe any gross errors with the handling and installation, they did recommend the following actions:

• Placing the O-ring in a transportation crate from the warehouse to the head stand

• Use of tygon tubing for protecting the seals

• Maintain protective covering on the new O-ring seals until the old O-ring has been removed and the new O-ring is ready to install

• Consider repairing any defects greater than 0.0001 on the sealing surface

• A significant factor in sealing performance is percent of compression of the seal.

Currently, Palo Verde is seeing about 9 percent compression. The vendor is recommending 16 percent compression. This would entail using a thicker O-rings (from 0.5 cross section O-ring to 0.525)

The licensees engineering group is using the vendor report as an input to a final engineering evaluation of all the actions they plan on implementing to enhance their handling and installation of the reactor vessel O-rings. The licensee is aiming for these recommendations to be put into action prior to their next refueling outage (Unit 1, April 2019). These enhancement actions will be documented under CR 18-07701.

Observation 71111.18 Plant Modifications The inspector discussed with licensee staff discrepancies noted in the vendor quality assurance paperwork that the licensee accepted deviations of the as-delivered components from NUREG-0554, ASME NOG-1, and Palo Verde Nuclear Generating Station design specification 13-CN-0390, Technical Requirements for Upgrading the Containment Building Polar Crane to Single Failure Proof, that was provided to Konecranes. The inspector noted the following exceptions listed below:

Licensee Design Document: 13-CN-0390, Technical Requirements for Upgrading the Containment Building Polar Crane to Single Failure Proof Requirement Observation Section 7.5.1, stated in part, The girders, Not all weldments and castings that could end trucks, and trolleys shall be of basically collect moisture have drainage holes.

welded construction. All bolted connections shall be in accordance with American Institute of Steel Construction specifications for structural joints using American Society for Testing and Materials specifications A325 or A490 bolts. All castings and weldments that may collect moisture shall have drain holes 1/2-inch minimum. . .

Section 7.5.2.1, stated in part, All welding Some of the vendors used AWS and welding criteria shall be in accordance Specification D14.1, Specification for with the following codes and standards: All Welding of Industrial and Mill Cranes and structural steel welding shall be performed in other Material Handling Equipment versus accordance with American Welding Society AWS specification D1.1, Structural Welding (AWS) specification D1.1. . .

Code - Steel.

Section 7.9.1, required the crane to be able Konecranes NUREG 0612, Appendix C, to operate at a minimum temperature of 60ºF.

Compliance Matrix, stated in part, Impact testing was not performed on the bridge when initially built, so Palo Verde Nuclear Generating Station has elected to perform critical lifts only when Containment Building temperatures are >70ºF.

Section 7.11.3.4, stated in part, All threaded A number of fasteners used lock washers fasteners which have the potential to fall into while the majority of the fasteners inspected the fuel or equipment pools shall be installed had no lock washer, lock wire, staking, or utilizing thread locking fluid, lock wire, or apparent Locking fluid.

staking to prevent loosening during crane operation. Lock washers shall not be utilized. . .

Section 7.11.4.1, did not permit aluminum The terminal blocks in the new cabinets components to be used inside containment, appear to be aluminum. Several of these unless contained within a sealed terminal box cabinets are open to the containment or waterproof housing.

atmosphere via cooling vents or conduits.

Vendor Document: CN390-A00359, Polar Crane Unit 2 Factory Acceptance Test Requirement Observation Step 7.46 a. auxiliary hoist micro speed test Recorded values of 2.6 ft/min raise and specification of 3 ft/min (+/- 10 percent) 2.4 ft/min lower, outside the required range of 2.7 to 3.3 ft/min Step 7.46 b. hoist micro speed specification Recorded values of 34.4 ft/min raise and of 1.5 ft/min (+/- 10 percent) 34.2 ft/min lower, outside the required range of 1.35 to 1.65 ft/min Step 7.46 c. auxiliary hoist electrical current No value recorded specification limit not to exceed 66 amps Step 8.48 calculated main hoist speed Recorded main hoist drum speed not specification of 4.0 ft/min (+/- 10 percent) converted to main hoist speed Step 8.50 calculated main hoist micro speed Recorded values of 23.6 raise and 22.9 lower specification of 3 in/min (+/-10 percent) with no units Step 8.50 b. main hoist electrical current No value recorded specification limit not to exceed 84 amps NUREG 0554, Single-Failure-Proof Cranes For Nuclear Power Plants Requirement Observation Section 2.3, Operating Environment, stated Vendor Document 13-CN-0390, Technical in part, The operating environment, including Requirements for Upgrading the Containment maximum and minimum pressure, maximum Building Polar Crane to Single Failure Proof, rate of pressure increase, temperature, does not provide values for minimum humidity, and emergency corrosive or pressure, maximum rate of pressure hazardous conditions, should be specified for increase, and emergency corrosive or the crane and lifting fixtures. . .

hazardous conditions. The licensee was unable to provide these values to the inspector.

Section 2.3, Operating Environment, stated There were a number of closed box sections in part, For cranes inside the containment of crane supports without the recommended structure, the closed box sections of the vent and/or drain valves.

crane structure should be vented to avoid collapse during containment pressurization.

Drainage should be provided to avoid standing water in the crane structure.

Section 2.8, Welding Procedures, stated in Some of the vendors used American Welding part, . . . Welds described in the Society (AWS) specification D14.1, recommendations of Section 2.6 should be Specification for Welding of Industrial and post-weld heat treated in accordance with Mill Cranes and Other Material Handling Subarticle 3.9 of AWS D1.1 . . .

Equipment, versus AWS specification D1.1.

ASME NOG1, 2004, Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)

Section 5427.1, specifically requires steel Konecranes August 23, 2017, letter stated, sheaves.

in part, . . . Since NOG-1-2004, Section 5427.1, specifically requires steel sheaves, we have taken an exception to NOG-1. Sections 5.3.5 of references 3 and 4 provide the technical justification on why the sheaves are acceptable.

Other Observations The proposed update to the updated final The proposed update was not accurate for all safety analysis report (UFSAR) stated, The of the as received polar crane components, containment polar cranes have been as described in the above table for upgraded to meet the guidelines for single- NUREG 0554.

failure-proof cranes contained in NUREG 0554.

Guidelines state that the crane meets Konecranes August 23, 2017, letter, states:

ASME NOG-1 requirements.

Since NOG-1-2004, Section 5427.1, specifically requires steel sheaves, we have taken an exception to NOG-1. Sections 5.3.5 of references 3 and 4 provide the technical justification on why the sheaves are acceptable.

The inspector identified additional discrepancies and verified that the licensee documented all discrepancies in Condition Report CR-18-17888.

Licensee-Identified Non-Cited Violation 71111.11 Licensed Operator Requalification Program This violation of very low safety-significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR Part 50.74 requires licensees to notify the NRC within 30 days of a change in medical condition of a licensed operator.

Contrary to the above, from May 18, 2018, to October 30, 2018, the licensee failed to notify the NRC of a change in medical condition of a licensed operator.

Significance/Severity Level: Severity Level IV. The performance deficiency was evaluated in accordance with the reactor oversight process and was determined to be minor because a licensing decision was not made due to the absence of this medical information, the individual was not on shift during the period of May 18, 2018, to December 12, 2018, and has used this therapeutic device and taken the medications as prescribed. The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to deter noncompliance. The inspectors determined the violation to be a Severity Level IV violation similar to Example 6.4.d.1(b) in the NRC Enforcement Policy and because it impacted the ability of the NRC to perform its regulatory oversight function. Specifically, by failing to inform the NRC of a change in an operators medical condition, the licensee prevented the NRC from performing the regulatory reviews associated with that process.

Corrective Action Reference: Condition Report 18-17047 Failure to Properly Preplan Corrective Maintenance Cornerstone Significance Cross-cutting Inspection Aspect Procedure Initiating Event Green [H.5] - 71111.13 NCV 05000529/2018004-001 Human Maintenance Closed Performance, Risk and Work Emergent Management Work Control The inspectors reviewed a Green, self-revealing, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, while planning replacement of an automatic control element drive mechanism (CEDM) timer module (ACTM) card, the licensee failed to provide instructions that would prevent unseating the adjacent ACTM card and losing electrical continuity or else plan the work for a plant mode that would not result in a plant transient. This caused a control element assembly to drop to the bottom of the core resulting in an automatic reactor trip.

Description:

On May 23, 2018, I&C technicians were performing planned maintenance on Unit 2. The activity was intended to replace control element drive mechanism control system (CEDMCS) logic power fuses and fuse holder caps in subgroups 15 and 16 with components of a newer design. With Unit 2 at 100 percent power, the licensee began the activity by placing subgroup 15 control element assemblies (CEAs) on the hold bus to allow the technicians to begin the fuse replacements without causing a loss of power to the subgroup 15 CEAs. As part of the maintenance activity, the technicians were to remove subgroup 15 ACTM cards one at a time. Once each set of fuses were replaced, the associated ACTM card would then be reseated. Three of the ACTM cards for subgroup 15 were reinstalled with no issues. However when attempting to reseat the ACTM card for CEA 62, the technicians encountered alignment issues. During their attempts to reseat the card, Unit 2 reactor tripped due to low departure from nucleate boiling ratio (DNBR) trip signals. There were no issues with the standard post trip actions.

The licensees post trip investigation determined that the automatic trip was the result of CEA 64 dropping to the bottom of the core causing the core protection calculators to generate a low DNBR and a high local power density trip signal. The technicians also determined that the ACTM card for CEA 64, located next to the CEA 62 card the technicians were trying to reseat and powered from a different subgroup, had become unseated and lost power. The licensee entered the event into their corrective action program as CR 18-08748 and performed a root cause evaluation.

The root cause evaluation revealed the following items:

• The alignment issue when trying to reseat an ACTM card caused the lower logic card, located behind and at right angles to the ACTM cards, to flex away from the row of ACTM cards causing adjacent ACTM cards to slowly unseat.

• The card alignment issue was a known equipment deficiency in Unit 2. Specifically, CR 17-09075, written on June 20, 2017, identified the issue that when manipulating a card, an adjacent card could be unseated.

• The card alignment issue was discussed in work planning meetings for this activity, but action to prevent the possibility affecting adjacent cards (especially in another subgroup) was not considered.

As a result the licensee did not establish any additional controls to mitigate the possibility that the known card alignment deficiency could cause unseating of adjacent cards. Alternatively, the inspectors noted that the licensee could have considered performing the fuse replacement activity during a plant mode when the card alignment deficiency would not have caused a plant transient, such as during a refueling outage.

Corrective Action: Unit 2 corrected the alignment issues during refueling outage 2R21. An extent of condition found that the alignment issue was only present in Unit 2.

Corrective Action Reference: CR 18-08748

Performance Assessment:

Performance Deficiency: The station failed to properly preplan maintenance such that the manipulation of one ACTM card would not affect the seating of another ACTM card due to the misalignment of the cards during work planning meetings. The misalignment was a known deficiency that was documented in their corrective action program.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the procedure quality attribute of the Initiating Events Cornerstone and affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the station failed to consider the adverse consequences due to the ACTM card misalignments when generating work instructions to manipulate those cards. This ultimately caused a control rod to drop to the bottom of the core resulting in an automatic reactor trip.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012. The inspectors determined that the finding had a very low safety significance (Green) because the finding resulted in a reactor trip, but did not involve a loss of mitigating equipment relied upon to transition the plant to a stable shutdown condition.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with the work management component because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, the work was not effectively planned and executed by incorporating risk insights and controlling job site conditions, and the work process did not incorporate contingency plans, compensatory actions, or abort criteria as needed to prevent potential adverse consequences of known alignment problems with ACTM cards. [H.5]

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures listed in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a, states, in part, that maintenance that can affect the performance of safety-related equipment should be properly planned and performed in accordance with written procedures appropriate to the circumstances.

Contrary to the above, on May 23, 2018, the licensee performed maintenance that can affect the performance of safety-related equipment which was not properly planned and performed in accordance with written work instructions that were appropriate to the circumstances.

Specifically, work instructions in Work Order 5006012 were not appropriate because they failed to address how to prevent unseating an ACTM card while seating another card, causing a loss of electrical continuity to an unaffected control element assembly.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy because of its very low safety significance (Green)and was entered in to the licensees corrective action program as CR 18-08748.

Failure to Establish an Adequate Procedure for Control of Potential Tornado Borne Missiles Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green [H.3] - 71111.20 Systems NCV 05000529/2018004-002 Human Refueling Closed Performance, and Other Change Outage Management Activities 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 prescribe instructions appropriate to the circumstances for the control and monitoring of transient missile hazards that have the potential to affect the operability of the essential spray ponds.

Description:

On September 28, 2018, the inspectors performed a walkdown of the yard area around Unit 2 and identified a large number of unsecured potential tornado borne missile (PTBM) hazards within 400 feet of the Unit 2 essential spray ponds. A PTBM is defined as an object that could become airborne during a tornado and be transported to the essential spray ponds. In addition, the object could damage the spray pond nozzles when it impacts the exposed spray nozzles or nozzle piping. The unsecured PTBMs included piping spool pieces, rubber hoses, large toolboxes, wire material storage baskets, wooden pallets, piping storage racks, and metal stanchions. The materials had been staged in preparation for draining a portion of the essential spray pond system to facilitate piping inspections during the October 2018 refueling outage. The inspectors noted that many of the PTBMs were not labelled with PTBM permit tags as required. The inspectors notified the Unit 2 shift manager of the potentially nonconforming condition.

On October 12, 2018, the inspectors were performing walkdowns near the Unit 2 essential spray ponds and noted several hundred scaffolding poles, wooden boards, and miscellaneous scaffolding components staged near the essential spray pond pump house.

The inspectors observed that many of the scaffolding materials were bound together with a lightweight nylon rope that would be insufficient to restrain the materials from becoming airborne during a design basis tornado event. The inspectors informed the licensees outage control center of this potentially nonconforming 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, Section 3.5.1.4. The key input into this analysis is the maximum missile density near each of the stations essential spray ponds. Higher missile densities lead to an increase in the probability that the essential spray pond will not be able to perform its function to provide cooling following a tornado. The probabilistic analysis concluded that a tornado event will not cause the loss of the heat removal function of the essential spray ponds so long as the licensee manages the storage of loose materials within the transient missile density limit. If the PTBM density limit is exceeded, however, the presumption of essential spray pond operability following a tornado event is lost.

The licensee uses Procedure 01DP-0XX01, Control and Monitoring of Potential Tornado Borne Missiles, Revision 4, to maintain the license basis density limits for PTBM hazards.

This procedure contains guidance for licensee personnel to be able to identify and control PTBM hazards. Transient items that meet the definition of a PTBM must be identified and tagged with a permit and entered into the licensees database for tracking PTBMs to ensure the operability limits are not exceeded.

For the piping spool pieces and other components identified on September 28, 2018, licensee maintenance personnel had not accurately accounted for all PTBMs. PTBM permit tags were found on only a few of the items. The number of items that had been entered into the licensees tracking database was 12. However, after questioning from the inspectors, the licensee evaluated the staged material and identified that at least 64 items met the definition of a PTBM. The operability limit defined in Procedure 01DP-0XX01 is 30 PTBMs within any 10,000 square foot area. The licensee determined that maintenance personnel had been unclear of how to identify PTBMs and establish accurate quantities when creating a PTBM permit and had obtained permits for groups of material rather than individual items that could become separate missile hazards.

For the scaffolding materials identified on October 12, 2018, a PTBM permit had been generated for the materials, but included only seven racks and five equipment bins. The many scaffolding poles, boards, and other equipment were not recognized as separate PTBMs and were not included in quantity of materials entered into the PTBM database.

Thus, for both examples identified by the inspectors, the licensee had unknowingly exceeded the analyzed PTBM density limits for which the essential spray ponds could be presumed to remain operable following a tornado event.

Operations personnel use the PTBM database to monitor the margin to the PTBM density limits and ensure the essential spray ponds remain operable. Without an accurate number of PTBM items entered into the database, the licensee had not questioned the operability of the essential spray ponds until challenged by the inspectors.

The licensee evaluated these conditions under Condition Reports 18-14363, 18-15171, and 18-16311. The licensee concluded that Procedure 01DP-0XX01, Control and Monitoring of PTBMs, is poorly written and confusing to follow. The procedure was first issued as an engineering procedure in 2010 and the procedure formatting and structure has remained technical in nature rather than providing explicit instructions for how to implement a defined process. The licensee also concluded that despite its title of Control and Monitoring of PTBMs, the procedure is not structured to facilitate control or monitoring. The procedure did not contain directions for controlling PTBMs to minimize high density clusters and did not facilitate monitoring localized densities within the PTBM tracking database. The inspectors verified that the licensee generated action item 18-14363-015 to revise Procedure 01DP-0XX01 to address these deficiencies.

Corrective Action: The licensee took immediate corrective action by removing the transient PTBMs from the vicinity of the Unit 2 essential spray ponds.

Corrective Action References: Condition Reports 18-14363, 18-15171, and 18-16311

Performance Assessment:

Performance Deficiency: The licensees failure to establish an adequate procedure for the control and monitoring of potential tornado borne missiles 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, as a result of unclear instructions, the licensee failed to control the storage of loose material that constituted potential tornado borne missile hazards in the vicinity of the Unit 2 spray ponds, and as a result exceeded 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. 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, to 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 six days 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 2.1E-9 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, the 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 emergency diesel generators.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with the change management component because licensee leaders failed to use a systematic process for implementing change so that nuclear safety remains the overriding priority. Specifically, when Procedure 01DP-0XX01 was initially issued in 2010, it was accompanied by several other program elements designed to raise awareness of the potential tornado borne missile program. These other program elements included issuance of a communications plan, site-wide news releases, periodic mandatory employee training, designated area owners, and operations department PTBM performance indicators. Since 2010, the licensee has terminated most of these other elements of the PTBM program. The licensee failed to re-evaluate and reinforce Procedure 01DP-0XX01 to compensate for removing the other program elements that were designed to ensure the PTBM program standards were met. [H.3]

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings. Updated Final Safety Analysis Report, Section 3.5.1.4, Missiles Generated by Natural Phenomena (Tornados), provided probabilistic criteria to ensure essential spray pond operability.

Study 13-NS-A106, Probabilistic Risk Assessment of Potential Tornado Missile Damage to the Station Ultimate Heat Sink, Revision 0, provided the missile density requirements to ensure the probabilistic criteria in the UFSAR, Section 3.5.1.4, are met.

Procedure 01DP-0XX01, Control and Monitoring of Potential Tornado Borne Missiles, Revision 4, implemented the control of transient missile hazards, an activity affecting quality, to ensure the missile density requirements of Calculation 13-NS-A106 and, therefore, the operability requirements for spray pond nozzles are met.

Contrary to the above, since 2010, Procedure 01DP-0XX01, intended to implement the control and monitoring of transient missiles that could have an effect on the operability of the essential spray ponds, an activity affecting quality, was not appropriate to the circumstances.

Specifically, licensee personnel failed to establish instructions to ensure that potential tornado missile density criteria are understood and controlled within limits.

Enforcement Action: This violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy because of its very low safety significance (Green)and was entered in to the licensees corrective action program as CR 18-14363.

EXIT MEETINGS AND DEBRIEFS

On October 19, 2018, the inspectors presented the inservice inspection activities inspection results to Mr. B. Rash, Vice President, Engineering, and other members of the licensee staff.

The inspector confirmed that proprietary information was controlled to protect from public disclosure.

On November 5, 2018, the inspector presented the Unit 2 Polar Crane inspection results to Mr. M. McLaughlin, Vice President, Operations Support, and other members of the licensee staff. The inspector verified no proprietary information was retained or documented in this report.

On November 9, 2018, the inspectors presented the triennial heat sink performance inspection results to Ms. M. Lacal, Senior Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On December 14, 2018, the inspector communicated the emergency action level and emergency plan changes inspection results telephonically to Ms. C. Shields, Manager, Emergency Preparedness, and other members of the licensee staff. Unless otherwise noted, no proprietary information was retained by the inspector or documented in this report.

On December 27, 2018, the inspector presented the licensed operator requalification inspection results to Mr. D. Elkinton, Section Leader Compliance, and other members of the licensee staff.

The inspectors verified no proprietary information was retained or documented in this report.

On January 2, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. B. Rash, Vice President, Engineering, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

THIRD PARTY REVIEWS The inspectors reviewed a World Association of Nuclear Operator reports that was issued during the inspection period.

DOCUMENTS REVIEWED

71111.04Equipment Alignment

Procedures

Number Title Revision

40OP-9SI01 Shutdown Cooling Initiation 56

40ST-9SI12 Shutdown Cooling Flow Verification 8

40ST-9SI07 High Pressure Safety Injection System Alignment 21

Verification

Drawings

Number Title Revision

01-M-SIP-001 P&I Diagram Safety Injection and Shutdown Cooling 43

System

01-M-SIP-001 P&I Diagram Safety Injection & Shutdown Cooling 57

System

01-E-PHA-001 Single Line Diagram 480V Class 1E Power System 21

Motor Control Center M31

01-E-PHA-003 Single Line Diagram 480V Class 1E Power System 30

Motor Control Center M33

01-E-PHA-005 Single Line Diagram 480V Class 1E Power System 15

Motor Control Center M35

71111.05AQFire Protection Annual/Quarterly

Work Orders

24637 5033525 4850349

Miscellaneous

Documents

Number Title Revision

PVNGS Pre-Fire Strategies Manual 26

71111.07Heat Sink Performance

Condition Reports

16-03487 16-02624 17-04346 16-18445 16-02413

Condition Reports Generated During the Inspection

18-18022 18-18023 18-18087 18-18088 18-18142

Work Orders

4752012 4264546 4414212 4210815 4210816 4403647 4396131

Procedures

Number Title Revision

73DP-9ZZ11 Heat Exchanger Program 15

Operations Condition Reporting Process and Operability

40DP-0OP26 45

Determination/Functional Assessment

74DP-9CY04 Systems Chemistry Specifications 96

40OP-9AF01 Essential Auxiliary Feedwater System 66

40OP-9PC01 Fuel Pool Cooling 16

Drawings

Number Title Revision

M021-00207 Oil Cooler Whitlock Type 1-R-4 F

13-C-SPS-375 Nuclear Service Spray Ponds Plan 14

Miscellaneous

Documents Revision

Number Title or Date

1PCB Heat Exchanger Thermal Performance Analysis October 29,

for 1R16 2011

1PCB Heat Exchanger Thermal Performance Analysis April 13, 2010

for 1R15

1PCB Heat Exchanger Thermal Performance Analysis October 16,

for 1R14 2008

1PCB Heat Exchanger Thermal Performance Analysis June 8, 2007

for 1R13

VTD-S445-0002 Installation, Operation & Maintenance For Struthers 0

Wells Corp. Fuel Pool Heat Exchangers

VTD-S445-0006 Specifications, Spare Parts, Special Tools, and Torque 0

Requirements for Struthers Wells Corp. Fuel Pool Heat

Exchangers

VTD-S445-0007 Specifications, Spare Parts, Special Tools, and 0

Torque Requirements for Struthers Sells Corp. Essential

Cooling Water Heat Exchangers

Miscellaneous

Documents Revision

Number Title or Date

VTD-C150-00014 Carrier Application Data for the Condenser and 2

Economizer (Essential Chiller)

Revised Response to NRC Generic Letter (GL) 89-13 October 1, 1993

Recommended Actions

Annual 10 CFR 50.59, 10 CFR 72.48 and Commitment December 22,

Change Report (January - December 2005) 2006

1MPCAE01 Eddy Current Inspection Summary - Fuel Pool Cooler February 2016

PCAE01

1MPCBE01 Eddy Current Inspection Summary - Fuel Pool Cooler February 2016

PCBE01

2MPCAE01 Eddy Current Inspection Summary - Fuel Pool Cooler February 2015

PCAE01

2MPCBE01 Eddy Current Inspection Summary - Fuel Pool Cooler February 2015

PCBE01

3MPCAE01 Eddy Current Inspection Summary - Fuel Pool Cooler January 2015

PCAE01

3MPCBE01 Eddy Current Inspection Summary - Fuel Pool Cooler February 2015

PCBE01

Essential Cooling Water Heat Exchanger Thermal October 31,

Performance Test Report 2012

Essential Cooling Water Heat Exchanger Thermal April 23, 2014

Performance Test Report

Essential Cooling Water Heat Exchanger Thermal May 1, 2017

Performance Test Report

FAI 13-0471 Evaluation of Acceptance Criteria Based on 0

Waterhammer Phenomena in the AF Piping for APS

Nuclear Generating Station, Units 1, 2 and 3

FAI 14-0364 Evaluation of Acceptance Criteria Based on 0

Waterhammer Phenomena in the PC Piping for APS

Nuclear Generating Station, Units 1, 2 and 3

13-MM-0021 Material Requisition for Auxiliary Feedwater Pumps 13

DMWO 4011490 Engineering Disposition for Spray Pond Wall 1

Refurbishment

13-CN-0365 Specification for Forming, Placing, Finishing, and Curing 11

of Grout and Concrete

Calculations

Number Title Revision

RE-01-C19-2014 U1R18 As-Left Spent Fuel Pool Decay Heat Projections 0

13-NC-PC-0203 Loss of Spent Fuel Pool Cooling Evaluations 3

13-MC-PC-0217 Spent Fuel Cooling System - Shutdown Cooling and 5

Pool Cooling Heat Transfer Evaluation

13-MC-SP-0306 MINET Hydraulic Analysis of SP System 5

13-MC-SP-0307 SP/EW System Thermal Performance Design Bases 9

Analysis

SDOC 02-MN950- EW Heat Exchanger Replacement - B&W Essential 0

A00003 Cooling Water Heat Exchanger Thermal-Hydraulic

Performance & Flow-Induced Vibration Report

71111.08Inservice Inspection Activities

Condition Reports

17-04807 17-06872 17-07462 17-08423 17-08521

17-08756 17-09718 17-1114 17-12329 17-13114

17-15464 18-00733 18-00942 18-02177 18-02487

Work Orders

4704651 4791185 4595676 4718617 5024637

Procedures

Number Title Revision

73DP-9WP04 Welding and Brazing Control 20

73DP-9WP05 Weld Filler Material Control 10

73TI-0ZZ13 Radiographic Examination 20

73TI-9ZZ05 Dry Magnetic Particle Examination 19

73TI-9ZZ07 Liquid Penetrant Examination 18

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

73WP-0ZZ04 Welding of Carbon and Low Alloy Steels to Stainless 19

and Nickel Alloys

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

73WP-0ZZ20 Visual Inspection of Code Welds 9

75RP-9RP30 Radiation Protection Oversight of Radiography 2

Procedures

Number Title Revision

70TI-9ZC01 Boric Acid Walkdown Leak Detection 21

73DP-9ZC01 Boric Acid Corrosion Control Program 8

EPRI-PIPE-MPA-1 Procedure for Manual Phased Array Examination of 2

Austenitic and Ferritic Pipe Welds

PDI-UT-5 PDI Generic Procedure for the Straight Beam Ultrasonic 2

Examination of Bolts and Studs,

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

Weld Overlaid Similar and Dissimilar Metal Welds

PDI-UT-11 PDI Generic Procedure for the Ultrasonic Examination of 1

Reactor Pressure Vessel Nozzle-to-Shell Welds and the

Nozzle Inner Corner Radius

PDI-UT-10 PDI Generic Procedure for the Ultrasonic Examination of 2

Dissimilar Metal Welds

PDI-UT-1 PDI Generic Procedure for the Ultrasonic Examination of 2

Ferritic Pipe Welds

PDI-UT-2 PDI Generic Procedure for the Ultrasonic Examination of 3

Austenitic Pipe Welds

PDI-UT-3 PDI Generic Procedure for the Ultrasonic Through-Wall 1

Sizing of Planar Flaws in Similar Metal Piping Welds

Miscellaneous

Documents

Number Title Date

Audit 2017-003 Engineering Programs December 6, 2017

2-07657- Palo Verde Nuclear Generating Station Units 1, 2, and March 2, 2018

MLL/TNW 3, Docket Nos. STN 50-528/529/530

Supplement to Relief Request 56 - Unit 2, Third

10-Year Inservice Inspection (ISI) Interval Extension

SWMS No. Formal Self-Assessment of the Inservice Inspection August 16, 2013

4362861 Program

SWIMS No.17- Welding Program Self-Assessment June 30, 2017

09564

71111.11 Licensed Operator Requalification Program and Licensed Operator Performance

Condition Reports

18-19310 18-19315 18-05351 18-06620 18-17047

17-01597 17-00651 17-02134 16-20182 16-19366

Condition Reports

17-00284 17-06366 17-03722 17-02671 17-08110

17-10495 17-10434 17-00092 17-00521 17-01060

17-01076 17-01439 17-01470 17-02201 17-02378

17-02541 18-00450 18-02315 18-02693 18-04454

Work Orders

28401

Procedures

Number Title Revision

73TI-9MB05 Main Turbine Operations to Support Validation Testing 0

of the EX2100E Main Generator Excitation System Post

Generator Stator Rewind

40ST-9RC01 RCS and Pressurizer Heat-up and Cooldown Rates 19

15DP-0OT02 LOCT Annual and Biennial Operating Exam Sample 5

Plan Development

15DP-0OT03 LOCT Biennial Written Exam Development and Sample 5

Plan

15DP-0OT04 LOCT Annual and Biennial Exam Administration 6

15DP-0OT05 NRC Examination Security 8

15DP-0OT06 LOCT Scenario and JPM Development 4

LOCT Training Program Description 70

15DP-0CC01 Simulator Operator Feedback 2

5DP-0CC02 Simulator Design Control 2

15DP-0CC03 Simulator Loadout Control 3

15DP-0CC04 Simulator Performance Testing 3

15DP-0TR70 Simulator Configuration 4

PV-1281 Exam Security Briefing Checklist 5

PV-1282 Pre-Exam Activities Security Checklist 2

PV-1283 Simulator Pre-Exam Activities Security Checklist 9

PV-1286 Initial License Exam Security Checklist for Admin JPMs 5

PV-1822 Initial License Exam Security Checklist for Written 1

Examinations

PV-1824 Initial License Exam Security for Simulator Scenarios 2

Procedures

Number Title Revision

01DP-0EM13 Licensed Operator Medical Examinations 11

40DP-0OP09 Operator Licensing and Requalification Process 1

Miscellaneous

Documents Revision

Number Title or Date

2018 LOCT Operations Test Sample Plan 0

Operations Training Critical Task List 12

Written Exam Remediation December 2017

Written Exam Remediation #1 December 2018

Written Exam Remediation #2 December 2018

71111.12Maintenance Effectiveness

Condition Reports

18-01796 VC-MMH1-18-001

Quality Records

214832 54214833 54214834 54214835 54214837 54214840 54214864

214865 54215151 54215457 54215458 54215467 54215477 54215481

215489 54215490 54215713 54215715 54215716 54215717 54215718

215720 54216789 54216795 54216801 54216803 54216804 54216837

216849 54216850 54216855 54216856 54217047 54217048 54217049

217050 54217051 54217052 54217251 54217256 54217777 54217820

217821 54217845 54217849 54217850 54217898 54218089 54218220

218226 54218227 54218228 54218229 54218230 54218232 54218234

218236 54218237 54218238 54218240 54218242 54218243 54218244

218245 54218246 54218541 54218548 54218551 54218552 54218553

218560 54218565 54218566 54218567 54218568 54219237 54219250

219506 54219568 54219603 54220093 54220096 54220099 54220128

220180 54220221 54220340 54220963 54221321 54221403 54222066

222273 54222274 54227399 54232514 54232515 54238523 54238524

241230 54241706 54241707 54273380 54300927 54357112 52596991

2596992 52596993 52596989 52596994 52596996 52410653

Work Orders

4151870-24

71111.13Maintenance Risk Assessments and Emergent Work Control

Condition Reports

18-15424 18-05353 16-12956 10-00150 15-08614

18-08748 17-09075 15-11063 18-05303 18-06515

Work Orders

22983 5006012

Procedures

Number Title Revision

40DP-9AP21 Protected Equipment 7

2DP-0RS01 Online Integrated Risk 7

30DP-9MP01 Conduct of Maintenance 78

Miscellaneous

Documents

Number Title Date

Unit 2 Shutdown Safety Function Assessment October 12, 2018

Schedulers Evaluation for PV Units 1, 2, and 3 October 4, 2018

71111.15Operability Determinations and Functionality Assessments

Condition Reports

16-15545 14-00406 17-003961 18-15424 18-18407

17-16139 18-07701 17-16139 18-18549 18-15398

18-18548 18-18551

Work Orders

49005003 4911770

Procedures

Number Title Revision

40OP-9CH12 Refueling Water Tank (RWT) Operations 41

Procedures

Number Title Revision

73ST-9SI10 HPSI Pumps Miniflow - Inservice Test 52

40DP-9OP19 Locked Valve, Breaker, and Component Tracking 139

Drawings

Number Title Revision

01-M-SIP-001 P & I Diagram Safety Injection & Shutdown Cooling 57

System

71111.18Plant Modifications

Condition Reports

17-14312 18-08540 18-17888

Procedures

Number Title Revision

CN390-A00193 APS 225/35 Ton Single Failure Proof Trolley and 1

Controls Upgrade Installation Procedure (Vendor)

31MT-9RC30 Reactor Vessel Head Removal and Installation 58

Drawings Revision

Number Title or Date

219237 Main Hoist Gearcase - Structural Welds 0

217521 Main Hoist Equalizer - Structural Welds 0

215467 Main Hoist Bottom Block - Structural Welds 0

220963 Main Hoist Drum - Structural Welds 0

219237 Main/Auxiliary Hoist Brake Base - Structural Welds 0

214833 Trolley Truck Right - Structural Welds 0

241707 Trolley Seismic Restraints - Structural Welds 0

222274 Auxiliary Hoist Drum - Structural Welds 0

216795 Auxiliary Hoist Upper Block - Structural Welds 0

CN390-A00055 SRI-Trolley Frame, Trolley Frame Weldment 0

Miscellaneous

Documents

Number Title Revision

13-CN-390 Technical Requirements for Upgrading the Containment 1

Building Polar Crane to Single Failure Proof

Engineering Disposition for ENG-DMWO 3282819 1

(ZC-1311) Polar Crane Upgrade Modification

Miscellaneous

Documents

Number Title Revision

484-09275-MM/ac APS Palo Verde Nuclear Generating Station Acceptance 0

of the use of Nylatron for Sheaves on the Replacement

Trolley Assemblies

Various NDE Records for Crane System Critical Welds

S-16-0014 10 CFR 50.59 Screening / Evaluation 3

17-F026 Final LDCR for DMWO 3282819

Vendor

Documents

Number Title Revision

KNES 36676-80 Tripod Bail Load Test Procedure 2

CN-36676-21 NUREG 0612, Appendix C, Compliance Matrix for 1

Konecranes/Konecranes Supersafe' Single Failure

Proof Trolley

CN-3667622 Konecranes Nuclear Equipment and Services 2

Supersafe' Single Failure Proof Upgrade for Palo

Verde Nuclear Generating Station Polar Crane

3667623 Palo Verde Nuclear Generating Station Polar Crane 0

Compliance Matrix

13-CN390-A00183 Safety Analysis Report for Konecranes Supersafe' 0

Single Failure Proof Trolley Palo Verde Nuclear

Generating Station Polar Crane

2018-00899 Polar Crane QA Document folder 0

CN390-A00359 Polar Crane Unit 2 Factory Acceptance Test 0

13-CN-0390 Technical Requirements for Upgrading the Containment 0

Building Polar Crane to Single Failure Proof (Vendor

document with same document number and title as

licensee document above)

Modification

Number Title Revision

DMWO 3282819 Polar Crane Upgrade Modification 0

(ZC-1311)

Vendor

Calculation

Number Title Revision

CN390-A00181 Palo Verde Nuclear Generating Station - APS Main 0

Vendor

Calculation

Number Title Revision

Hoist Reeving Calculation

71111.19Post-Maintenance Testing

Condition Reports

18-17331 3157405 18-17372 18-17577 18-17740

Work Orders

22458 4909877 4911663 5065857 5079029 4922458

Procedures

Number Title Revision

73DP-0XI03 Check Valve Predictive Maintenance and Monitoring 27

Program

73ST-9ZZ25 Check Valve Disassembly, Inspection, and Manual 13

Exercise

73ST-9XI33 HPSI Pump and Check Valve Full Flow Test 63

40ST-9DG01 Diesel Generator A Test 49

36ST-9SB04 PPS Function Test - RPS/ESFAS Logic 26

Miscellaneous

Documents

Number Title Date

Last Measurement Deviation Report October 30, 2018

71111.20Refueling and Other Outage Activities

Condition Reports

18-18582 18-18066 18-16233 18-16164 18-14363

18-15171 18-16311

Procedures

Number Title Revision

31MT-9ZC07 Miscellaneous Containment Building Heavy Loads 40

40MT-9ZZ01 Operations Maintenance Activities 6

78OP-9FX02 Fuel Transfer Machine 26A

40OP-9ZZ23 Outage GOP 79

01DP-0XX01 Control and Monitoring of PTBMs 4

Drawings

Number Title Revision

241707 SRI-Bracket, Seismic Restraint Weldment 1

Miscellaneous

Documents

Number Title Revision

282819 Engineering Disposition for Polar Crane Upgrade 0

Modification

18-18582-009 Engineering Evaluation

53702 Event Notification Worksheet: Personnel Medical 0

Condition

13-NS-A106 Missiles Generated by Natural Phenomena (Tornados) 0

Engineering

Reports Number Title Revision

2016-00631 Engineering Document Change 2

71111.22Surveillance Testing

Work Orders

4909840 4928971 4932057

Procedures

Number Title Revision

73ST-9ZZ26 Check Valve Non-intrusive Testing or Examination - 6

Inservice Test

73ST-9SI06 Containment Spray Pumps and Check Valves - 44

Inservice Test

73ST-9CL01 Containment Leakage Type B and C Testing 46

71114.04Emergency Action Level and Emergency Plan Changes

Procedures

Number Title Revision

EP-900 Emergency Response Organization (ERO) Position 17

Checklists

Miscellaneous

Documents

Number Title Date

2-7799-CS/WP Palo Verde Nuclear Generating Station (PVNGS), Units September 25,

1, 2, and 3 and Independent Spent Fuel Storage 2018

Installation; Docket Nos. 50-528, 50-529, 50-530, and

2-44; License Nos. NPF-41, NPF-51, and NPF-74;

PVNGS Emergency Plan, Revision 62

Evaluation Tracking Effectiveness Evaluation Form, Revision 62, Palo August 29,

Number 2018-002E Verde Nuclear Generating Station Emergency Plan 2018

2-07839-CS/MA Palo Verde Nuclear Generating Station (PVNGS), Units December 6,

1, 2, and 3 and Independent Spent Fuel Storage 2018

Installation; Docket Nos. 50-528, 50-529, 50-530, and

2-44; License Nos. NPF-41, NPF-51, and NPF-74;

PVNGS Emergency Plan, Revision 63

71152Problem Identification and Resolution

Condition Reports

18-18408 18-16091 18-07701 17-16139 18-18420

18-02569 18-16928 18-12217

Work Orders

2891465 3326510 3490456 3250774 3374818 3374819

Procedures

Number Title Revision

31MT-9RC31 Reactor Vessel O-Ring Replacement 13

40DP-9OP26 Operations Condition Reporting Process and Operability 45

Determination/Functional Assessment

Miscellaneous

Documents Revision

Number Title or Date

ODMI: Unit 1 Reactor Vessel Flange Indication of 1

Leakage from Inner O-ring

ODMI: Unit 3 Reactor Vessel Flange Indication of May 22, 2018

Leakage from Inner O-ring

17-16139-004 Engineering Evaluation November 17,

2017

Vendor

Documents

Number Title Date

Technetics: Customer Contact Report November 20,

Vendor

Documents

Number Title Date

2018

71153Follow-up of Events and Notices of Enforcement Discretion

Condition Reports

18-02605 18-08466 18-00202

Miscellaneous

Documents Revision

Number Title or Date

18-02605-009 Unit 1 Main Turbine Excitation Trip Root Cause 0

Evaluation

18-00202-027 Engineering Evaluation July 3, 2018

CRDR 4531542 Inability of ADV 2JSGAHV0184 to Stroke Open from the July 31, 2014

Control Room and Remote Shutdown Panel

Information Request August 21, 2018

Notification of Inspection and Request for Information

Palo Verde Nuclear Generating Station, Unit 2

NRC Inspection Report 05000529/2018004

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: October 11 - 18, 2018

Inspector: Wayne Sifre, Senior Reactor Inspector

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 Wayne Sifre, by October 3, 2018, to facilitate

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

inspector 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.

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.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this

letter and its enclosure will be available electronically for public inspection in the NRC

Public Document Room or from the Publicly Available Records (PARS) component of

NRCs document system (ADAMS). ADAMS is accessible from the NRC web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

On October 11, 2018, a reactor inspector from the Nuclear Regulatory Commissions

Region IV office will perform the baseline inservice inspection at Palo Verde Nuclear

Generating Station, Unit 2, using NRC Inspection Procedure 71111.08, "Inservice

Inspection Activities. Experience has shown that this inspection is a resource intensive

inspection both for the NRC inspectors 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) identifies 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 Mr. Del Elkinton of your licensing organization. The tentative inspection

schedule is as follows:

Preparation week: October 3 - 10, 2018

Onsite weeks: October 11 - 18, 2018

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 Wayne Sifre at 817-200-1193.

(mail to: Wayne.Sifre@nrc.gov ).

A.1 ISI/Welding Programs and Schedule Information

a) A detailed schedule (including preliminary dates) of:

i. Nondestructive examinations planned for ASME Code Class Components

including containment, performed as part of your ASME Section XI, risk informed

(if applicable), and augmented inservice inspection programs during the

upcoming outage.

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

the Section XI scope (if applicable).

iii. Examinations planned as part of your boric acid corrosion control program

(mode 3 walk downs, bolted connection walk downs, etc.)

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

outage (ASME Class 1, 2, or 3 structures, systems, or components). Include the

weld identification number, description of weld, category, class, type of exam and

procedure number, and date of examination.

b) A copy of ASME Section XI, Code Relief Requests and associated NRC safety

evaluations applicable to the examinations identified above. A list of ASME Code

Cases currently being used to include the system and/or component the Code Case

is being applied to.

c) 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.

d) 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.

e) 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

applicable procedures that will be used to conduct these examinations.

f) 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.

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

h) Please provide copies of the most recent self-assessments for the inservice

inspection, welding, and Alloy 600 programs.

i) Copy of the procedures for NDE and welding techniques that will be used during the

outage.

A.2 Boric Acid Corrosion Control Program

a) 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.

b) 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 walk down inspections performed as part of the boric

acid corrosion control program.

A.3 Additional Information Related to all Inservice Inspection Activities

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

program (e.g., condition reports) 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.

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

required for the activities described in A.1 through A.4.

c) Please provide names and phone numbers for the following program leads:

• Inservice inspection (examination, planning)

• Containment examinations

• Snubbers and supports

• Site welding engineer

• Boric acid corrosion control program

B. Information to be Provided Onsite to the Inspector at the Entrance Meeting

(October 11, 2018):

B.1 Inservice Inspection / Welding Programs and Schedule Information

a) Updated schedules for inservice inspection/nondestructive examination activities,

including steam generator tube inspections, planned welding activities, and schedule

showing contingency repair plans, if available.

b) 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:

i. Weld data sheet (traveler).

ii. Weld configuration and system location.

iii. Applicable Code Edition and Addenda for weldment.

iv. Applicable Code Edition and Addenda for welding procedures.

v. Applicable welding procedures used to fabricate the welds.

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

from B.1.b.v.

vii. Copies of welders performance qualification records (WPQ).

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

ix. Radiographs of the selected welds and access to equipment to allow viewing

radiographs (if radiographic testing was performed).

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

xi. Readily accessible copies of nondestructive examination personnel qualifications

records for reviewing.

c) For the inservice inspection related corrective action issues selected by the inspectors

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

documentation.

d) For the nondestructive examination reports with relevant conditions on ASME Code

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

the examination records, examiner qualification records, and associated corrective

action documents.

e) A copy of (or ready access to) most current revision of the inservice inspection program

manual and plan for the current interval.

f) For the nondestructive examinations selected by the inspectors 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

a) 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.

b) 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 Codes and Standards

a) 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.

b) 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.).

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

ML19031B145

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

By: JDixon Yes No Publicly Available Sensitive

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