IR 05000528/2019003

Integrated Inspection Report 05000528/2019003, 05000529/2019003, and 05000530/2019003 and Independent Spent Fuel Storage Installation (ISFSI) Inspection Report 07200044/2019002

ML19310G838
Person / Time
Site:	Palo Verde
Issue date:	11/05/2019
From:	John Dixon NRC/RGN-IV/DRP/RPB-D
To:	Bement R Arizona Public Service Co
References
IR 2019002, IR 2019003
Download: ML19310G838 (25)

Text

{{#Wiki_filter:ber 5, 2019

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - INTEGRATED INSPECTION REPORT 05000528/2019003, 05000529/2019003, AND 05000530/2019003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) INSPECTION REPORT 07200044/2019002

Dear Mr. Bement:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station, Units 1, 2, and 3. On October 11, 2019, the NRC inspectors discussed the results of this inspection with Ms. Maria Lacal and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, 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 Palo Verde.

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 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/ John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects Docket Nos. 05000528, 05000529 05000530, and 07200044 License Nos. NPF-41, NPF-51, and NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000528, 05000529, 05000530, and 07200044 License Numbers: NPF-41, NPF-51, and NPF-74 Report Numbers: 05000528/2019003, 05000529/2019003, 05000530/2019003, and 07200044/2019002 Enterprise Identifier: I-2019-003-0013 and 1-2019-002-0085 Licensee: Arizona Public Service Company Facility: Palo Verde Units 1, 2, and 3 Location: Phoenix, AZ 85072-2034 Inspection Dates: July 1, 2019 to September 30, 2019 Inspectors: C. Peabody, Senior Resident Inspector D. You, Resident Inspector R. Bywater, Resident Inspector D. Reinert, PhD, Reactor Inspector L. Brookhart, Senior ISFSI Inspector J. Braisted, Senior Project Engineer B. Correll, Reactor Inspector J. Nicholson, Senior Health Physicist J. Dykert, Health Physicist N. Fields, Health Physicist W. Smith, Health Physicist J. Reynoso, Resident Inspector, Diablo Canyon J. Tapp, Transportation & Storage Safety Inspector Approved By: John L. Dixon, JR, Chief Reactor Projects Branch D Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection and an independent spent fuel storage installation inspection 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.

List of Findings and Violations Failure to Incorporate Design Requirements to Inspect Manholes for the Diesel Generator Fuel Oil Storage Vaults into the Preventive Maintenance Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.01 Systems NCV 05000530/2019003-01 Evaluation Open/Closed The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate the design basis of the facility into procedures. Specifically, the licensee failed to implement a suitable testing program to inspect manholes installed in a plant modification intended to prevent water intrusion into the diesel generator fuel oil storage vaults.

Additional Tracking Items None.

PLANT STATUS

Unit 1 operated at or near full power for the inspection period.

Unit 2 entered the inspection period at full power. On August 16, 2019, the switchyard protective circuitry spuriously opened the Unit 2 output breakers causing a reactor trip. Unit 2 restarted on August 19, 2019, and returned to full power for the remainder of the inspection period.

Unit 3 operated at or near full power for the inspection period.

INSPECTION SCOPES

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

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems on August 13, 2019.

Impending Severe Weather Sample (IP Section 03.03) (2 Samples)

(1) The inspectors evaluated continued readiness during a period of heightened seismic activity on July 5, 2019.

(2) The inspectors evaluated readiness for impending adverse weather conditions for severe dust storm and thunderstorm warnings on September 25, 2019.

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated readiness to cope with external flooding on September 25, 2019.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Unit 2 essential chilled water B on July 18, 2019

(2) Unit 2 swing battery charger BD on July 24, 2019

(3) Unit 3 auxiliary feedwater B on September 30, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

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

(1) Unit 1, 2, and 3 corridor building 120 elevation on July 12, 2019

(2) Unit 3 main control room on July 19, 2019

(3) Unit 1 reactor trip switchgear and control element drive mechanism control room on September 10, 2019

(4) Unit 1 upper cable spreading room on September 11, 2019

==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated Unit 2 operator performance during plant startup following the short notice outage on August 19, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02)==

(1) The inspectors observed and evaluated a licensed operator continuing training simulator examination scenario and job performance measure examination on September 12, 2019. The inspectors assessed the performance of the operators and the control room simulator.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

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

(1) Emergency lighting return to 10 CFR 50.65(a)(2) following closeout of dual-lite charge card replacement on September 26, 2019

(2) Instrument air maintenance rule functional failure criteria change review on September 26, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

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

(1) Unit 2 engineered safety features actuation system B power supply replacement on August 5, 2019

(2) Unit 2 control element drive mechanism control system power switch assembly replacement on August 8 to 9, 2019

(3) Unit 2 diesel generator A outage concurrent with emergent switchyard maintenance on September 23 to 24, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 essential ventilation system battery room D functionality with leakage through backdraft damper 1MHJBM61 on July 22, 2019

(2) Unit 3 safety injection tank 1B with erratic narrow range level instrument on August 1, 2019

(3) Unit 1 recirculation line void analysis on August 29, 2019

(4) Unit 3 main steam line rad monitor 140 loss of communication on September 12, 2019

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) DMWO 4623203 Magnastor dry cask storage system - modification of fuel building components on August 13, 2019

(2) SP-1338 essential spray pond bypass line/margin recovery modification on September 16, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

[[IP sample::=

=IP 71111.18|count=6}}

The inspectors evaluated the following post-maintenance tests:

(1) 73ST-9CL03, Unit 2 containment airlock door seal leak test after replacement of the containment personnel airlock door seal on July 25, 2019

(2) 73ST-9XI53, Unit 1 high pressure safety injection header A to reactor coolant loop 2B valve SIA-UV-627 stroke time test following in-service test maintenance on August 27, 2019

(3) 73ST-9XI53, Unit 1 high pressure safety injection header A to reactor coolant loop 1B valve SIA-UV-647 stroke time test following in-service test maintenance on August 27, 2019

(4) 36ST-9SE13, Unit 2 excore startup channel system test after replacement of a 5 volt power supply, on September 3, 2019

(5) 36ST-9SB13, Unit 1 supplementary protection system D test after replacement of the test adjust voltage potentiometer R102 on September 4, 2019

(6) 73ST-9CH06 and 73ST-9CH02, Unit 1 charging pump test B after 12-month and 24-month preventative maintenance on September 9 to 12, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated a Unit 2 forced outage due to an electrical grid lockout on August 16 to 19, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1 recirculation actuation signal A line fill check on August 8, 2019

(2) Unit 1 supplementary protection system D functional test on September 4, 2019

(3) Unit 2 boron dilution alarm system functional test on September 5, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated:

(1) Emergency response organization drill on September 24,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 1 (April 1, 2018 through August 31, 2019)

(2) Unit 2 (April 1, 2018 through August 31, 2019)

(3) Unit 3 (April 1, 2018 through August 31, 2019)

MS07: High Pressure Injection Systems (IP Section 02.06) (3 Samples)

(1) Unit 1 (April 1, 2018 through August 31, 2019)

(2) Unit 2 (April 1, 2018 through August 31, 2019)

(3) Unit 3 (April 1, 2018 through August 31, 2019)

MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)

(1) Unit 1 (April 1, 2018 through August 31, 2019)

(2) Unit 2 (April 1, 2018 through August 31, 2019)

(3) Unit 3 (April 1, 2018 through August 31, 2019)

MS09: Residual Heat Removal Systems (IP Section 02.08) (3 Samples)

(1) Unit 1 (April 1, 2018 through August 31, 2019)

(2) Unit 2 (April 1, 2018 through August 31, 2019)

(3) Unit 3 (April 1, 2018 through August 31, 2019)

MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)

(1) Unit 1 (April 1, 2018 through August 31, 2019)

(2) Unit 2 (April 1, 2018 through August 31, 2019)

(3) Unit 3 (April 1, 2018 through August 31, 2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

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

(1) Determination of the extent of condition of discrepancies between times assumed in the probabilistic risk assessment and demonstrated simulator validation times within the time critical operator action program.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated the Unit 2 reactor trip and licensees response on August 16,

OTHER ACTIVITIES

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OTHER ACTIVITIES

60854 - Preoperational Testing of an ISFSI Preoperational Testing of an ISFSI

(1) An independent spent fuel storage installation (ISFSI) inspection was conducted at Palo Verde Nuclear Generating Station (Palo Verde) on August 13 to 16, 2019, and September 16 to 19, 2019, by a team of NRC inspectors from Region 1, Region 3, Region 4, and an individual from NRC Headquarters Division of Spent Fuel Management. The Palo Verde ISFSI is licensed as a general Part 72 licensee. The licensee had been utilizing the NAC Universal Multi-Purpose Canister System (UMS),approved under Certificate of Compliance (CoC) 72-1015, Amendment 5, and NAC UMS Final Safety Analysis Report (FSAR), Revision 11, to load and store spent fuel at their ISFSI. At the time of the on-site inspection, Palo Verde's ISFSI pad contained 152 NAC ventilated concrete casks (VCCs), each containing the steel transportable storage container (TSC) with a capacity for 24 pressurized water reactor (PWR) spent fuel assemblies.

Under the provisions of 10 CFR 72.210 and 10 CFR 72.212, Palo Verde elected to adopt and utilize a different storage system to store spent fuel casks at their ISFSI.

The licensee selected the NAC, Magnastor System under CoC 72-1031, Amendment 7, and FSAR Revision 10. The Magnastor TSC has the capacity to store 37 PWR spent fuel assemblies in each VCC.

On September 16 to 19, 2019, the purpose of the inspection was to observe and evaluate the licensees pre-operational testing and training exercises required to be performed by a general licensee prior to use of the system to load spent fuel assemblies. The NAC Magnastor CoC 72-1031, Appendix A, Technical Specification (TS) 5.8 contained a list of loading, closure, handling, unloading, and transfer operational dry runs that are required to be performed prior to the first loading of a Magnastor cask. Specifically, during the September inspection dates, the NRC inspectors observed Palo Verde perform the following demonstrations to meet TS 5.8:

• TSC unloading operations, which included reflooding the canister in the cask loading pit (CLP), (TS 5.8.n)
• Hydrostatic pressure testing of the TSC in the CLP (TS 5.8.g)
• Moving a VCC into the fuel handling building (FHB) on the rail car (TS 5.8.a)
• Vacuum drying and helium backfilling of the TSC in the CLP (TS 5.8.g)
• Passive Magnastor Transfer Cask (PMTC) movement though the designated load path from the CLP to installation on the VCC with installed Transfer Adapter (TS 5.8.f, 5.8.h, and 5.8.i)
• Transfer of the TSC from the PMTC to the VCC such that the shield doors were closed (TS 5.8.j)
• Transfer of the TSC from the VCC to the PMTC to demonstrate unloading operations (TS 5.8.m)
• PMTC movement though the designated load path into CLP (TS 5.8.b)
• VCC lid assembly installation (TS 5.8.k)
• Transport of the VCC via rail car from the FHB to the VCC transfer pad (TS 5.8.l)
• Transport of the VCC via vertical cask transporter (VCT) from the VCC transfer pad to the ISFSI (TS 5.8.l)

Palo Verde successfully completed the above listed pre-operational activities and fully demonstrated that the procedures, programs, and training related to those dry cask storage operations had been successfully integrated into its site operations. The inspectors did not identify any issues of concern requiring documentation. The licensee previously performed demonstrations to meet parts of TS 5.8.g (welding, sealing, and non-destructive examination) as documented in a prior NRC inspection report 05000528/2019001, 05000529/2019001, 05000530/2019001, and

===07200044/2019001 (ADAMS Accession No. ML19122A295). The licensee still has a number of demonstrations that are required to be completed before utilization of the Magnastor system. Those demonstrations are projected to be performed in late 2019.

60856 - Review of 10 CFR 72.212(b) Evaluations Review of 10 CFR 72.212(b) Evaluations ===

(1) From August 13 to 16, 2019, the NRC ISFSI inspection team performed a review to evaluate the licensee's program implementation for inclusion of the use of the Magnastor system into the site's existing 10 CFR Part 50 and Part 72 programs. The inspection scope included a review of the licensee's programs for heavy loads, emergency planning, fire protection, quality assurance, radiation protection, and record retention.

Specifically, the inspection team evaluated the following:

• The licensees structural and seismic calculations for Magnastor storage operations which included: over-head spent fuel building crane with the loaded transfer cask, loaded transfer cask in the spent fuel pools loading area, loaded transfer cask in the stack-up configuration to support downloading of a canister into the concrete over-pack, and the structural and soil liquefaction calculations for use of the Magnastor system at the ISFSI pad
• Spent fuel selection procedure to verify the spent fuel assemblies met the approved content requirements from the Appendix B Technical Specifications
• Licensees implementation of Palo Verde's heavy load program to encompass the Magnastor storage system
• Analyses to determine maximum weights placed on the cask handling crane during loading operations and procedures for manual operation of the hoisting system and the bridge and trolley transfer mechanisms in emergent conditions
• Evaluations that verify the new canister hoist system met the single-failure proof criteria as described in NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants
• Load testing documentation for the new canister hoist system for compliance with ASME B30.2 Overhead and Gantry Cranes
• Cask handling crane daily, periodic, and annual inspection procedures for compliance with ASME B30.2 criteria
• Design specifications and load testing documentation for all special lifting devices, including the new hoist crane system, canister lift block, and transfer cask lift trunnions for compliance with ANSI N14.6 Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds or More
• Licensees implementation of Magnastors 10 CFR Part 72 emergency planning requirements into the existing 10 CFR Part 50 Emergency Plan
• Licensees fire and explosion hazards analysis for the ISFSI and conducted a walk-down of the heavy haul path and ISFSI to ensure all hazards had been identified and evaluated
• Radiological dose calculations to verify annual levels from ISFSI would be less than the limits specified in 10 CFR 72.104
• Licensees ISFSI maintenance and surveillance procedures to verify compliance with requirements from the FSAR and license Technical Specifications
• Palo Verdes quality assurance program, corrective action program, and implementing procedures for incorporation of ISFSI related activities
• Palo Verdes radiation protection program for implementation of ISFSI activities, which included ALARA planning, neutron dosimetry, radiation work plans, and calibration of radiological instrumentation
• Verified the licensee had established procedures to ensure record retention requirements of 10 CFR 72.212
• Licensees corrective action programs condition reports of issues identified for resolution since the last NRC ISFSI inspection performed in February 2019 The inspectors did not identify any issues of concern requiring documentation.

60857 - Review of 10 CFR 72.48 Evaluations Review of 10 CFR 72.48 Evaluations

(1) The inspectors reviewed a list of 10 CFR 72.48 screenings performed by the licensee for use of the new Magnastor system. The inspectors evaluated the following:

• Selected licensee 10 CFR 72.48 screenings and associated changes, tests, or experiments
• The process by which the licensee evaluates 10 CFR 72.48 screenings and evaluations performed by the Certificate of Compliance (CoC) holder

INSPECTION RESULTS

Failure to Incorporate Design Requirements to Inspect Manholes for the Diesel Generator Fuel Oil Storage Vaults into the Preventive Maintenance Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.01 Systems NCV 05000530/2019003-01 Evaluation Open/Closed The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate the design basis of the facility into procedures. Specifically, the licensee failed to implement a suitable testing program to inspect manholes installed in a plant modification intended to prevent water intrusion into the diesel generator fuel oil storage vaults.

Description:

On February 20, 2019, in preparation for quarterly inservice testing of the Unit 3 diesel generator fuel oil transfer pump B, the licensee removed the diesel generator fuel oil storage vault plug to access the vault. Upon removal of the plug, the licensee discovered and removed about 2,000 gallons of water that had accumulated inside to vault to a depth of about 19 inches. Then, when the licensee attempted to perform the diesel generator fuel oil transfer pump test, the pump power supply breaker immediately tripped when operators attempted to start the pump. With an inoperable fuel oil transfer pump, diesel generator B was declared inoperable and was documented in Condition Report 19-02640. During the licensees investigation, water condensation droplets were found on vault surfaces and inside the interior of the non-watertight electrical junction boxes in the vault. Inside one of the junction boxes, the terminal board for the fuel oil transfer pump power supply cables was found corroded and saturated with water. The degraded condition resulted in a short circuit and trip of the power supply breaker.

On February 21, 2019, following a rainfall event, the licensee identified that water was entering the vault through a conduit for the diesel generator fuel oil transfer pump power supply cable. This issue was documented in condition report 19-02727.

After removing the rainwater from the vault, drying electrical components, replacing the degraded terminal board, and successfully testing the fuel oil transfer pump, diesel generator B was declared operable on February 22, 2019.

Another rainfall event occurred on February 22, 2019, and the licensee identified and removed approximately 800 gallons of water from the vault. The licensee also discovered that a nearby manhole was filled with water and when the manhole was dewatered, the leakage into the vault stopped. This issue was documented in condition report 19-02790.

The licensee initiated a Level 1 root cause evaluation for this event and identified that the manhole was installed as part of a modification intended to prevent water intrusion events into the diesel generator fuel oil storage vaults that had resulted in previous fuel oil transfer pump failures (Unit 2 fuel oil transfer pump B in April 2009 and Unit 2 fuel oil transfer pump A in September 2010).

Modification DF-1555 (DMWO 3560653) installed new duct banks with water impervious cables that sloped away from the diesel generator building and the diesel generator fuel oil storage vaults. In between these duct banks, a new manhole was installed to collect water that may have entered the conduits in the duct banks through leaking joints. Water collected in the manhole was designed to be held at an elevation below the cable conduits to prevent it from draining into the diesel generator fuel oil storage vault and impacting the transfer pump.

The modification was completed for Unit 3 in June 2017. Following installation of the modification, water was found in the Unit 3 fuel oil storage vault B on three out of four quarterly vault inspections. Condition reports were initiated for each of these occurrences and some assessment was performed to identify the leak path into the vault. However, the possibility that the DF-1555 manhole was the source of the water was not considered until the February 20, 2019, event.

The licensees investigation concluded that the Unit 3 diesel generator fuel oil storage tank manhole B was more susceptible to water ingress due to its location with respect to rainwater drainage paths from nearby buildings.

The licensees investigation further identified that the manholes installed by DMWO 3560653 were not entered into the preventive maintenance program for inspection and dewatering of manholes. Licensee staff who would be responsible for this task were not aware of the existence of the manholes.

Corrective Actions: The licensees corrective actions included issuing a night order requiring several items:

• Weekly inspections of the Unit 3 fuel oil storage vault B for water intrusion
• Daily inspections of the Unit 3 fuel oil storage vault B for water intrusion on days there is rainfall and for two days following rain activity
• Inspect all nine of the modification DF-1555 manholes for all three units during and for two days following rainstorms
• Document any identified water intrusion into the manholes or the Unit 3 fuel oil storage vault B in a condition report The inspectors have verified implementation of the required inspections on and following days with rainfall.

The licensee replaced the Unit 3 fuel oil transfer pump B motor cable terminal board in the fuel oil storage vault with waterproof spliced cable connections.

The licensee added the manholes to the preventive maintenance program. Preventive Maintenance Basis document 5136008, Electrical Manholes, has been revised to include the manholes in the preventive maintenance program for periodic inspection and for inspections for water intrusion following heavy rainfall.

The licensee is going to raise the elevation of the Unit 3 diesel generator fuel oil storage tank B manhole to prevent surface water intrusion.

Corrective Action References: Condition Reports 19-02688, 19-02640, 19-02727, 19-02790

Performance Assessment:

Performance Deficiency: The failure to provide a suitable testing program to inspect the manholes installed by DMWO 3560653 following rainfall was a performance deficiency. Specifically, Action Item 4310776 was initiated during the modification impact review process to review and update testing program items that inspected hatches onsite for leaks and water accumulator. Action Item 4310779 was closed with no changes made to any existing items or creation of any new actions that would add the manholes to the preventive maintenance program.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to add the manholes to the site preventive maintenance task to inspect them periodically and after rainfall contributed to water intrusion into the Unit 3 diesel generator fuel oil transfer pump B motor cable junction box in the diesel generator fuel oil storage vault, failure of the fuel oil transfer pump during operation, and inoperability of the Unit 3 diesel generator B.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because the finding:

(1) was not a design deficiency;

(2) did not represent a loss of system and/or function;

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and

(4) did not result in the loss of a high safety-significant, nontechnical specification train. Specifically, the Unit 3 diesel generator B was inoperable for an exposure time of less than eight days, which is less than the 10-day outage time for an inoperable diesel generator allowed by Technical Specification 3.8.1, Condition B.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. The licensee failed to evaluate the cause and potential consequences of water intrusion identified during three previous inspections of the Unit 3 B diesel generator fuel oil vault after installation of modification DF-1555.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Additionally, design control measures shall provide for verifying or checking the adequacy of design such as by the performance of design reviews.

Contrary to the above, from June 2014 through February 2019, manholes installed by modification DF-1555 were not included in the preventive maintenance program for inspection and removal of accumulated water. The design review process for verifying and checking the adequacy of modification DF-1555 failed to assure this design basis was correctly translated into specifications, drawings, procedures, or instructions.

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

EXIT MEETINGS AND DEBRIEFS

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

• On October 9, 2019, the inspectors presented the ISFSI inspection results to Ms. Maria Lacal, Senior Vice President Regulatory and Oversight, and other members of the licensee staff.
• On October 11, 2019, the inspectors presented the integrated inspection results to Ms. Maria Lacal and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Corrective Action Condition Reports 19-13946, 19-13946, 19-13825, 19-13817, 19-13806, 19- Documents 13804, 19-13804, 19-11126, 19-11030, 19-09947, 19-05762, 19-04426, 19-02790, 19-02727, 19-02688, 19-02658, 19- 2640 Miscellaneous Unit 3 Night Order 03/06/2019 PVNGS Updated FSAR 19 2013-00044 Engineering Document Change 08/01/2017 2590671 Preventive Maintenance Basis Electrical Manholes 3EZY09BKKM01 Component Data Sheet 4310776 Action Item 06/25/2014 5136008 Preventive Maintenance Basis Electrical Manholes DMWO 3560653 DFOST Vault Cable Replacement 0 DF-1555 DMWO 3560653 DFOST Vault Cable Replacement 1 DF-1555 Procedures 40AO-9ZZ21 Acts of Nature 38 40DP-9OP34 Switchyard Administrative Control 21 40DP-9OPA9 Outside Area Operator Logs 18 40ST-9ZZ37 Inoperable Power Sources Action Statement 3 73DP-0EE05 Engineering Preventive Maintenance Program 4 73DP-0EE05 Engineering Preventive Maintenance Program 16 81DP-0CC26 Impact Process 13 86DP-0EE01 Reliability Centered Maintenance (RCM) Based System 10 Reviews 87DP-0CC17 Control of Engineering Data in SWMS 19 91DP-0EN31-01 Management of Sumps and Manholes Administrative 5 Guideline 71111.04Q Corrective Action Condition Reports 19-10655, 19-10003 Documents Drawings 03-M-AFP-001 P & I Diagram Auxiliary-Feedwater System 31 2-M-ECP-001 P & I Diagram Essential Chilled Water System 31 Inspection Type Designation Description or Title Revision or Procedure Date Procedures 40OP-9PK01 125 VDC Class 1E Electrical System 36 40ST-9AF08 Auxiliary Feedwater Pump AFB-P01 Monthly Valve 6 Alignment Work Orders 4976774 71111.05Q Corrective Action Condition Reports 19-11432, 19-11431, 19-10993 Documents Drawings 13-A-ZYD-005 Door Details Sheet 1 of 2 20 13-A076-10 Missile Resistant Doors Manually Operated 5 13-A076-11 Missile Resistant Doors Manually Operated 8 13-A076-3 Missile Resistant Doors Manually Operated 10 13-A076-7 Missile Resistant Doors Manually Operated 6 Miscellaneous PVNGS Pre-Fire Strategies Manual 26 PVNGS Updated FSAR 19 13-VTD-R095- Ray Proof Instructions for Serial No J-318-D7 Missile 2 2 Resistant, Double Leaf Swing, Manually Operated Door 13-VTD-R095- Ray Proof Instructions for Serial No J-212-D3 Missile 4 003 Resistant, Double Leaf Swing, Manually Operated Door 13-VTD-R095- Ray Proof Instructions for Serial No J-208-D5 Missile 4 008 Resistant, Single Leaf Swing, Manually Operated Door 13-VTD-R095- Ray Proof Instructions for Serial No J-408-D8 Missile 4 009 Resistant, Double Leaf Swing, Manually Operated Door DEC-00305 Install Zero International Model #322 UL Listed/Fire-Rated 0 Weatherstripping At Meeting Stiles of Missile Resistant Doors J408, J318, and A-212 Procedures 14DP-0FP33 Control of Transient Combustibles 30 38FT-9QK19 Fire Detection/Protection System Functional and Supervised 11 Circuits Test - Protectowire Models ACR 1615 and 1618 38FT-9QK27 Fire Detection/Protection System Functional and Supervised 7 Circuits Test - Honeywell One Detector Type Panels 40DP-9ZZ17 Control of Doors, Hatches, and Floor Plugs 63 Work Orders 3318811 71111.11Q Miscellaneous Licensed Operator Continuing Training Simulator Evaluation 09/12/2019 Scenario Licensed Operator Continuing Training Job Performance 09/12/2019 Inspection Type Designation Description or Title Revision or Procedure Date Measure Procedures 40OP-9ZZ04 Plant Startup Mode 2 To Mode 1 77 71111.12 Corrective Action Condition Reports 19-13610, 19-02987, 17-18024, 16-03279, 15-03256, 16- Documents 02999, 16-02703, 16-02550, 16-02475, 16-01661, 15-12126, 15-09594, 15-07003, 15-06072, 15-03216 Miscellaneous Issue 01383 Dual-Lite fixtures- Performance Criteria Unacceptable 5 Issue 02069 Update Performance Criteria Basis Document for IA 0 Procedures 32FT-9QD20 Annual Battery Discharge Testing 5 70DP-0MR01 Maintenance Rule Program 45 Work Orders 4831868, 4831862, 4831861, 4831859, 4831858, 4831856, 4785820, 4662164, 4659507, 4654142, 4634672, 4633817 71111.13 Corrective Action Condition Reports 19-13825, 19-13806, 19-11297, 19-11266, 17-14046 Documents Drawings 13-E-MAA-001 Main Single Line Diagram 31 Miscellaneous Schedulers Evaluation of Risk for PV Unit 2 09/22-28/ 2019 Palo Verde EGHV Switchyard Status 09/23/19-09/29/19 09/22-28/ 2019 Procedures 40AO-9ZZ21 Acts of Nature 38 40OP-9DG01 Emergency Diesel Generator A 80 40OP-9SF01 Control Element Drive Mechanism Control System CEDMCS) 30 Operation Work Orders 5158802, 5152633 71111.15 Corrective Action Condition Reports 19-13216, 19-12547, 19-11588, 19-11496, 19-11215, 19- Documents 11154, 19-10851, 19-10645, 19-01676 Drawings 01-M-HJP-002 Control Building HVAC P&I Diagram 18 03-M-SIP-002 Safety Injection and Shutdown Cooling System 38 Miscellaneous Technical Specifications 118 Technical Specifications Bases 0 Updated Final Safety Analysis Report 20 Control Building HVAC System Design Basis Manual 19 13-EC-HJ-PK-204 Hydrogen Generation Calculation for Class 1E Station 2 Batteries - GNB Model NCN-33 Inspection Type Designation Description or Title Revision or Procedure Date 13-JC-SI-200 Safety Injection Tank Level Narrow Range Setpoint and 5 Uncertainty Calculation 13-MC-HJ-003 Control Building HVAC System (HJ) Heat Load Equipment 10 Adequacy Calculation 13-MC-HJ-264 Analysis of the Isolation Capabilities for the Control Building 0 Isolation Dampers 13-MS-B086 Development of ECCS Suction Side Piping Arc Lengths 3 Associated with Calculated Max Void Volumes VTD-R411-010 Ruskin Manufacturing Company Operation-Maintenance 2 Instructions and Spare Parts List for Dampers Procedures 16DP-0EP31 Emergency Preparedness Equipment Out of Service 11 40ST-9SI04 RAS Line Fill Check 26 40ST-9ZZM1 Operations Mode 1 Surveillance Logs 73 Work Orders 5156164 71111.18 Corrective Action Condition Reports 19-13273, 19-11483, 19-11472, 19-09926, 19-09299, 19- Documents 09298 Drawings 01-M-SPP-002 Essential Spray Pond System 22 2-M-SPP-002 Essential Spray Pond System 18 2-M-SPP-002 Essential Spray Pond System 19 03-M-SPP-001 Essential Spray Pond System 66 Miscellaneous PVNGS Units 1, 2, & 3 EQ Program Manual 26 13-MC-HF-901 Fuel Building Transient Analysis 6 13-MC-HF-901 Fuel Building Transient Analysis 7 13-MS-A152 Study for the Design Temperature Validation of Components 1 in the Fuel Building 13-NS-B081 At-Power PRA System Study for the Essential Spray Pond 1 System 2011-221 Evaluate changes made to the Spray Pond piping by DCR 01/11/ 2019 SP-1338 (DMWO 3304346) 2016-00852 Engineering Document Change for 13-MC-HF-0901 12/12/2016 2019-0480 Engineering Document Change for 13-MS-A152 07/24/2019 SP-1338 Bypass Line/Margin Recovery 0 Procedures 40AC-0ZZ06 Locked Valve, Breaker, and Component Control 18 Inspection Type Designation Description or Title Revision or Procedure Date 40DP-9OP19 Locked Valve, Breaker, and Component Tracking 138 40DP-9OP19 Locked Valve, Breaker, and Component Tracking 139 40DP-9OP19 Locked Valve, Breaker, and Component Tracking 139B 40EP-9EO03 Loss of Coolant Accident 44 Work Orders 4623203 71111.19 Corrective Action Condition Reports 18-19377, 19-03362, 19-12322 Documents Miscellaneous 73DP-9CL02 Containment Leakage Rate Testing Program 34 Procedures 36ST-9SB13 Supplementary Protection System Functional Test 19 36ST-9SE13 Excore Startup Channel and Boron Dilution Alarm System 37 Calibration 73ST-9CH02 Charging Pumps - Comprehensive Test 13 73ST-9CH06 Charging Pumps - Inservice Test 35 73ST-9CL03 Containment Airlock Door Seal Leak Test 28 73ST-9XI53 Train A HPSI Injection and Miscellaneous SI Valves - Cycle 13

                                              - Inservice Test

Work Orders 5077465, 5143298, 5163952, 4998952 71111.22 Corrective Action Condition Reports 19-11496, 19-12322 Documents Drawings 01-M-SIP-001 Safety Injection and Shutdown Cooling System 58 Procedures 36ST-9SB13 Supplementary Protection System Functional Test 19 36ST-9SE05 BDAS Functional Test 26 40ST-9SI04 RAS Line Fill Check 26 Work Orders 5163952, 5017203, 5012290 71114.06 Corrective Action Condition Reports 19-09256, 19-07906 Documents Miscellaneous EP-0803 F Protective Action Recommendation Flow Chart EP-0804 E Release Evaluation Flow Chart EP-801 H Emergency Action Level Classification Matrix - Hot Conditions EP-802 H Emergency Action Level Classification Matrix - Cold Conditions EP-930 B Emergency Action Level Classification Matrix - All Conditions Inspection Type Designation Description or Title Revision or Procedure Date 71151 13-NS-C075 MSPI Basis Document 9 Procedures 70DP-0PI01 Performance Index Data Mitigating Systems Cornerstone 8 71152 Corrective Action Condition Reports 13-00981, 19-00054, 19-04087, 19-05839 Documents Miscellaneous 13-NS-B062 At-Power PRA Study for Human Reliability Analysis 14 Procedures 40DP-9ZZ04 Time Critical Action (TCA) Program 13 71153 Corrective Action Condition Reports 19-11892 Documents Procedures 40EP-9EO01 Standard Post Trip Actions 23 40EP-9EO02 Reactor Trip 14 40EP-9EO07 Loss of Offsite Power / Loss of Forced Circ 31 60854 Corrective Action Condition Reports 19-12550, 19-13535, 19-13452, 19-13436 Documents Corrective Action Condition Reports 19-13446, 19-13513, 19-13542 Documents Resulting from Inspection Miscellaneous PV Unit 3 Archived Operator Log 9/19/2019 09/27/2019 TRM 3.9.104 Fuel Building Essential Ventilation System (FBEVS) 65 Procedures 40DP-9ZZ17 Control of Doors, Hatches and Floor Plugs 63 78OP-9ZZ04 MAGNASTOR Cask Loading Operations Draft X - 09/13/19 78OP-9ZZ05 MAGNASTOR Cask Unloading Operations Draft D - 09/13/19 Radiation Work 9-1306 Dry Cask Storage of Spent Fuel Assemblies Using Modular 0 Permits (RWPs) Advanced Generation Nuclear All-Purpose Storage

                                              (MAGNASTOR)

60856 ALARA Plans RWP#: 1306_00 Dry Cask Storage of Spent Fuel Assemblies Using 07/09/2019 MAGNASTOR Calculations US52-00239-02 NUREG-0554 Compliance Matrix for APS Canister Hoist 2 13-NC-FH-0004 Occupational Dose Rates for NAC-Magnastor Dry Storage 0 Cask Operations 13-NC-ZD-0001 ISFSI Dose Calculation Spreadsheet 5 13-NC-ZD-0001: ISFSI Dose Calculation Spreadsheet 05/17/2019, Inspection Type Designation Description or Title Revision or Procedure Date EDC-2019-00076 09/06/2019 13-NC-ZY-0288 Cloud Inhalation/Immersion Doses for ISFSI 1 13-NC-ZY-0289 ISFSI Dry Cask MCNP Direct and Skyshine Plant Yard and 3 Offsite Doses 13-NC-ZY-0289: Doses from a Single Cask within ISFSI 05/17/2019 EDC 2019-00076 13-NC-ZY-0290 Ground Contamination Levels for ISFSI 2 30032-2001 APS Magnastor Weight & C.G. Calculation 3 71160-2006 Concrete Cask Structural Evaluation 8 A0-CC-ZD-0002 ISFSI - Cask Storage Pad Design 2 RE-03-C21-2019- U3C21 Spent Fuel Selection for Dry Casks 153-157 Storage 0 (Draft) 007 Calibration Magnastor M&TE Log Records Corrective Action Condition Reports 19-01555-008, 19-04069, 19-04510, 19-05088, 19-11163, Documents 19-11452, 19-11714, 19-11826, 19-11827, 19-11831, 19- 11842, 19-11869 Corrective Action Condition Reports 19-11776, 19-11776-001, 19-11871, 19-11895, 19-11934, Documents 19-12080, 19-12082, 19-12128, 19-12132, 19-12133, 19- Resulting from 12134, 19-12350, 19-12554, 19-13025 Inspection Engineering 2017-00745 Alignment Leveling Stand (ALS) Design for NAC-Magnastor 1 Changes Dry Cask Storage System 2019-00076 Fuel Building Laydown Load Evaluation for the Dry Cask A Storage Project DMWO 4623203 Magnastor Cask Implementation 2 Engineering 13-CN383- 150 Ton Spent Fuel Pool Cask Handling Crane Safety 2 Evaluations A00002-2 Analysis US52-00239-03 APS Canister Hoist N14.6 Compliance Matrix 1 Fire Plans 14DP-0FP35 Pre-Fire Strategies Manual 26 A0-MS-B022 Independent Spent Fuel Storage Installation Fire Hazards 4 Analysis PR-0904 Fire Protection 2 Inspection Type Designation Description or Title Revision or Procedure Date Miscellaneous PVNGS Emergency Plan 64 2-01598-MWL PVNGS Neutron Dosimetry Summary 11/18/1994 ANPM-00096- Neutron Dose Rate Calibration Change 10/05/1986 MWL-96.65 Event Reporting Event Reporting Manual 46 Manual 30DP-0MP13 PVNGS Rigging Control 15 30DP-0WM07 Controls for Use of Measuring and Test Equipment (M&TE) 14 30DP-0WM17 Crane Operator Qualifications 6 30DP-9MP11 Field Use of Rigging 42A 30DP-9MP12 Overhead Cranes 39 31MT-9ZC07 Miscellaneous Containment Building Heavy Loads 40 40AO-9ZZ21 Acts of Nature 38 2DP-9NF02 Fuel Assembly Selection for Dry Cask Storage 15 75DC-9SF02 Radiation Protection Requirements for Magnastor Dry Cask 0a (Draft) Storage and Basis 75RP-9RP16 Special Dosimetry 25 78DP-0ZD01 Dry Cask Storage Documentation Tracking Requirements 7 78OP-9FX05 Operation of the Echo-330 Ultrasonic Test Equipment 8 78OP-9ZZ02 NAC-UMS Cask Loading Operations 40 78ST-1ZD01 Daily ISFSI Temperature Monitoring System 11 81DP-0ZZ01 Civil System, Structure, and Component Monitoring Program 24 84DP-0RM30 Record Management Control 32 US52-00239-08 APS 55 Ton Canister Lift Factory Acceptance Test Procedure 2 US52-00239-22 N14.6 Load Test Procedure Components of Canister Hoist 3 Work Orders 04822962/0, Calibrate Radiation Monitors per 74ST9SQ22 /74ST9SQ32 2018/2019 04842928/0, for Units 1, 2, and 3 04941025/0, 04857107/0, 04874581/0, 04944111 Work Orders 5006357/0 Perform Ultrasonic Inspections 10/23/2018 60857 Engineering 50.59 and 72.48 50.59 S-19-004, 72.48 S-19-002, NAC-19-MAG-04, NAC-19- 08/13/2019 Inspection Type Designation Description or Title Revision or Procedure Date Evaluations Screenings MAG-05, NAC-19-MAG-13, NAC-19-MAG-14, NAC-19-MAG- 15, NAC-19-MAG-16 Procedures 87DP-0CC08 Control of Vendor Engineering Documents 28 93DP-0LC03 Licensing Document Maintenance 28 2| ]]