IR 05000528/2020003

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Integrated Inspection Report 05000528/2020003, 05000529/2020003, and 05000530/2020003
ML20303A347
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 10/30/2020
From: John Dixon
NRC/RGN-IV/DRP/RPB-D
To: Lacal M
Arizona Public Service Co
References
IR 2020003
Download: ML20303A347 (21)


Text

October 30, 2020

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2, AND 3 -

INTEGRATED INSPECTION REPORT 05000528/2020003, 05000529/2020003, AND 05000530/2020003

Dear Mrs. Lacal:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station Units 1, 2, and 3 and discussed the results of this inspection with you 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 the 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 Nuclear Generating Station Units 1, 2, and 3.

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 Units 1, 2, and 3. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects

Docket Nos. 05000528, 05000529, and 05000530 License Nos. NPF-41, NPF-51, and NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000528, 05000529 and 05000530

License Numbers:

NPF-41, NPF-51 and NPF-74

Report Numbers:

05000528/2020003, 05000529/2020003 and 05000530/2020003

Enterprise Identifier: I-2020-003-0001

Licensee:

Arizona Public Service Company

Facility:

Palo Verde Nuclear Generating Station, Units 1, 2, and 3

Location:

Tonopah, AZ

Inspection Dates:

July 1, 2020 to September 30, 2020

Inspectors:

C. Peabody, Senior Resident Inspector

R. Bywater, Resident Inspector

J. O'Donnell, Senior Health Physicist

D. Antonangeli, Health Physicist

Approved By:

John L. Dixon, Jr., Chief

Reactor Projects Branch D

Division of Reactor Projects

SUMMARY

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

Inadequate Procedure for Transport of the Containment Hydrogen Recombiners Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000529,05000530,05000528/2020003-01 Open/Closed

[H.6] - Design Margins 71111.04 The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the licensees failure to maintain an appropriate procedure for changing the mode of operation of the containment hydrogen recombiner system during a loss-of-coolant accident (LOCA) in Unit 2 or Unit 3. Specifically, hydrogen recombiner B, shared among the three units, was not physically capable of being moved out of its normal location in Unit 1, or installed in Unit 2 or Unit 3, without removing permanently-installed plant equipment obstructing the transport path of the recombiner, and necessary steps to remove the equipment were not addressed in the licensees procedure.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000530/2020-001-00 LER 2020-001-00 for Palo Verde, Condition Prohibited by Technical Specifications Due to Inoperable Spray Pond Pump 71153 Closed

PLANT STATUS

Units 1, 2, and 3 operated at or near rated thermal power for the entire 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated readiness for impending adverse weather conditions for monsoon thunderstorms on August 3, 2020.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 1 high-pressure safety injection system B during planned maintenance on high pressure safety injection system A on July 29, 2020
(2) Unit 1 containment hydrogen recombiner B on September 8, 2020
(3) Unit 1 diesel generator A during planned maintenance on diesel generator B on September 24, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 auxiliary feedwater system on September 10, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 3 engineered safety features A pump rooms, Fire Area 13, on July 20, 2020
(2) Unit 1 upper cable spreading room, Fire Area 60, on July 21, 2020
(3) Unit 1 lower cable spreading room, Fire Area 44, on July 21, 2020
(4) Unit 2 auxiliary building 120 elevation, Fire Zone 52D, on July 30, 2020
(5) Unit 2 lower cable spreading room, Fire Zones 12, 13, and 14, on August 31, 2020

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Diesel fuel oil vault B on September 22, 2020

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 control room activities during supplementary protection system functional testing on August 6, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated annual simulator examinations on September 4, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Radioactive drains level switch failures due to ground water intrusion events trend review on July 9, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2 planned maintenance of high-pressure safety injection pump B with steam generator FLEX makeup pump contingency on July 9, 2020
(2) Unit 3 high-pressure safety injection, low pressure safety injection, and containment spray (train B equipment) planned maintenance on July 22, 2020
(3) Unit 2 emergent work controls balance of plant engineered safety features actuation system A power supply replacement on August 12, 2020
(4) Unit 1 emergent work controls related to plant protection system half-leg trips for recirculation actuation signal on September 11, 2020, and main steam isolation signal on September 12, 2020
(5) Unit 3 main turbine electro-hydraulic control system troubleshooting on September 30, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1 operability of emergency generator B with oil leakage on July 16, 2020
(2) Unit 3 operability of core protection calculator D with loss of indication and intermittent spiking on July 29, 2020
(3) Unit 1 operability of reactor coolant system pressure isolation valve SIB-V532 after failure of leakage monitoring pressure transmitter SIN-PIT-391 on August 12, 2020
(4) Unit 1 operability of diesel generator B with lube oil heat exchanger inlet partially blocked with duct tape on September 23, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary modification 19-09102-004 to remove sub-synchronous resonance generator protection trips

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1)73ST-9SI10, Unit 2 high pressure safety injection pump A test following planned maintenance on July 9, 2020 (2)73ST-9CH06, Unit 1 charging pump A test following corrective maintenance on August 5, 2020 (3)40OP-9SA01, Unit 2 balance of plant engineered safety features actuation system A autotest following corrective maintenance on August 28, 2020 (4)73DP-9ZZ25, Unit 3 motor-operated valve testing of low pressure safety injection SI-615 following periodic valve operator and breaker inspections on September 18, 2020 (5)32MT-9ZZ82, Unit 1 essential chiller B Agastat relay testing following planned maintenance on September 21, 2020 (6)32MT-9PE01, Unit 1 diesel generator B governor overspeed test following planned governor replacement on September 29, 2020 (7)73ST-9DG08, Unit 1 diesel generator B single largest load rejection test following planned maintenance on September 29, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 2 essential chilled water pump B comprehensive test on September 10, 2020
(2) Units 1, 2, and 3 ex-core linear (power) calibration surveillance test risk-informed documented evaluation (STRIDE) to extend frequency from monthly to quarterly under the surveillance frequency control program on September 21, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 3 auxiliary feedwater pump A inservice test on July 27, 2020

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

(1) The inspectors evaluated an emergency preparedness drill and training evolution on August 25, 2020.
(2) The inspectors evaluated an emergency preparedness training evolution as part of the licensed operator continuing training simulator examinations on September 4,

RADIATION SAFETY

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (3 Samples)

The inspectors evaluated the integration of as low as is reasonably achievable planning into the following work activities:

(1) Valve, flange, pump maintenance and inspections under RWP #2-3502
(2) Primary side steam generator maintenance under RWP #1-3306
(3) Reactor destack and restack under RWP #3-3002

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)

The inspectors evaluated dose estimates and exposure tracking.

(1) Valve, flange, pump maintenance and inspections under RWP #2-3502
(2) Primary side steam generator maintenance under RWP #1-3306
(3) Reactor destack and restack under RWP #3-3002

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) A radiation workers potential airborne exposure evaluation dated April 25, 2020, Evaluation No. 20-05801-001
(2) A radiation worker alarmed the personnel contamination monitor exiting the radiologically controlled area on April 30, 2020, Evaluation No. 20-06101-001

Special Dosimetric Situations (IP Section 03.04) (1 Sample)

The inspectors evaluated the following special dosimetric situations:

(1) Dose assessment for three declared pregnant workers

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

(1) Unit 1 (July 1, 2019 through June 30, 2020)
(2) Unit 2 (July 1, 2019 through June 30, 2020)
(3) Unit 3 (July 1, 2019 through June 30, 2020)

BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)

(1) Unit 1 (July 1, 2019 through June 30, 2020)
(2) Unit 2 (July 1, 2019 through June 30, 2020)
(3) Unit 3 (July 1, 2019 through June 30, 2020)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Shift technical advisors assigned dual-role as emergency notification system communicators contrary to emergency plan requirements on September 8, 2020

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000530/2020-001-00, Condition Prohibited by Technical Specifications due to Inoperable Spray Pond Pump (ADAMS Accession No. ML20120A607). An inspection finding pertaining to this event was previously dispositioned in Palo Verde Inspection Report 2020-001 (ADAMS Accession No. ML20133K115) as NCV 05000528, 05000529,05000530/2020001-01 Failure to Incorporate Vendor Recommendations into GE Magne-Blast Medium Voltage Circuit Breaker Maintenance and Overhaul Procedures. This LER is closed with no further performance deficiencies identified.

INSPECTION RESULTS

Inadequate Procedure for Transport of the Containment Hydrogen Recombiners Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity

Green NCV 05000529,05000530,05000528/2020003-01 Open/Closed

[H.6] - Design Margins 71111.04 The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to maintain an appropriate procedure for changing the mode of operation of the containment hydrogen recombiner system during a loss-of-coolant accident (LOCA) in Unit 2 or Unit 3. Specifically, hydrogen recombiner B, shared among the three units, was not physically capable of being moved out of its normal location in Unit 1, or installed in Unit 2 or Unit 3, without removing permanently-installed plant equipment obstructing the transport path of the recombiner, and necessary steps to remove the equipment were not addressed in the licensees procedure.

Description:

The containment hydrogen control system includes two 100 percent capacity redundant safety-related trains of hydrogen recombiners and a single-train nonsafety-related hydrogen purge system that is a backup system to the recombiners. The design requirement is to maintain containment hydrogen concentration less than 4.0 volume percent following a LOCA. The hydrogen recombiners and the hydrogen purge system are shared among the three units. The equipment is installed in the Unit 1 auxiliary building and each component is intended to be transportable to Units 2 or 3 if there was a LOCA in one of those units. The hydrogen recombiner skids are each approximately 5.5 feet wide, 10.5 feet long, and weigh 11,000 pounds. The cylindrical recombiner body on the skid is approximately 5.3 feet in diameter and 8.5 feet tall. By design the recombiners are required to be installed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initiation of a LOCA, warm-up for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and then placed in service within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of the initiation of a LOCA.

On June 3, 2020, while hydrogen recombiner A was nonfunctional due to a corrective maintenance item, the inspectors performed a walkdown of the hydrogen control system and identified a potential lack of clearance for transport of the hydrogen recombiner B skid out of the Unit 1 auxiliary building. The path of travel for the B skid was blocked by emergency lighting battery bank 1QDN-N08. The inspector reviewed Procedure 31MT-9HP01, Hydrogen Recombiner/Hydrogen Purge Exhaust Air Filtration Unit Removal and Installation, Revision 8. This procedure provided instructions for the transport of the hydrogen recombiners following a LOCA. The procedure did not identify the obstruction or provide steps to remove it. The licensee confirmed the inspectors observation and initiated Condition Report 20-07585. The licensee concluded the hydrogen recombiner B remained functional because removal of battery bank 1QDN-N08 was estimated to only require 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of time, leaving ample time available to move and install the skid in Unit 2 or Unit 3.

On June 8, 2020, the inspectors performed a walkdown of the hydrogen recombiner B transport path in Units 2 and 3. The inspector identified other potential obstructions that would prevent the hydrogen recombiner skid from being moved to its required location. These permanently installed components included fire panel 2EFPNJ22J in Unit 2 and fire panel 3EFPNJ32J in Unit 3. These interferences were also not addressed by Procedure 31MT-9HP01. The licensee confirmed these observations and added them to Condition Report 20-07585 for evaluation. The licensee completed additional walkdowns and concluded these fire panels and some other miscellaneous light fixtures and minor obstructions would require removal to allow transport and installation of the hydrogen recombiner B skid. The licensee updated its functionality assessment with information that 12-18 hours would be required to remove the additional obstructions and this work could be performed in parallel with the removal of the hydrogen recombiner B skid from the Unit 1 auxiliary building. The licensee concluded there was still sufficient time available to install the recombiner within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and, therefore, the hydrogen recombiner B remained functional. The licensee initiated a procedure change request to revise Procedure 31MT-9HP01 to include the required plant modifications to support removal and installation of the hydrogen recombiner B skid.

Due to differences in equipment layout in the auxiliary buildings, the inspectors did not have a concern with transportability of the hydrogen recombiner A skid out of Unit 1 and into Unit 2 or Unit 3.

Corrective Actions: The licensee completed walkdowns in all three units to identify obstructions requiring removal to support transport of the hydrogen recombiner and documented a functionality assessment of the hydrogen recombiner. The licensee also initiated a corrective action item to revise Procedure 31MT-9HP01.

Corrective Action References: Condition Reports 20-07585, 20-12271

Performance Assessment:

Performance Deficiency: The licensees failure to maintain an adequate procedure for the removal of the hydrogen recombiner B skid from Unit 1 and installation in Unit 2 or Unit 3 following a LOCA was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the design control and procedure quality attributes of the Barrier Integrity Cornerstone and impacted the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Procedure 31MT-9HP01 only provided instructions for removal and installation of one hydrogen recombiner. Absent guidance to move both hydrogen recombiner skids following a LOCA, and absent an unobstructed travel path for hydrogen recombiner B, the inspectors concluded the time available to place a hydrogen recombiner in service was significantly challenged if there were a failure of hydrogen recombiner A.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. 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 December 13, 2019. The inspectors determined that the finding had very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment (valves, airlocks, etc.), failure of containment isolation system (logic and instrumentation), failure of containment pressure control equipment (including structures, systems or components credited for compliance with Order EA-13-109), failure of containment heat removal components; and, the facility does not have a containment design that uses hydrogen igniters (Exhibit 3, Section C).

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. The finding has a cross-cutting aspect in the area of human performance associated with the design margins component because the licensee failed to carefully guard and maintain design margin through a systematic and rigorous process. Specifically, emergency lighting battery banks were permanently installed in September 2018, June 2019, and July 2019 (for Units 1, 3, and 2 respectively) that obstructed the travel path of hydrogen recombiner B. This was not recognized, assessed, and included in the licensees procedure for removal, transport, and installation of a hydrogen recombiner during a LOCA. Ultimately, this resulted in loss of design margin for placing the hydrogen removal system in service. [H.6]

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, 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 3.v, states, in part, that instructions for startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the hydrogen recombiner system.

Contrary to the above, prior to June 8, 2020, the licensee did not maintain an appropriate procedure for startup, shutdown, and changing the mode of operation of the hydrogen recombiner system during a loss-of-coolant accident in Unit 2 or Unit 3. Specifically, station Procedure 31MT-9HP01, Hydrogen Recombiner/Hydrogen Purge Exhaust Air Filtration Unit Removal and Installation, Revision 8, did not have appropriate instructions for transporting hydrogen recombiner B, shared among the three units, from its normal location in Unit 1, to Unit 2 or Unit 3 during a LOCA in one of those units. Previously unidentified, permanently-installed plant equipment created obstructions to the transport of the hydrogen recombiner B from Unit 1 to Unit 2 or Unit 3 following a LOCA, and removal of this equipment was not addressed in Procedure 31MT-9HP01.

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 August 7, 2020, the inspectors presented the occupational radiation protection inspection results to Mr. B. Rash, Vice President, Nuclear Engineering and Regulatory, and other members of the licensee staff.
  • On October 7, 2020, the inspectors presented the integrated inspection results to Mrs. M. Lacal, Executive Vice President/Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Procedures

40AO-9ZZ21

Acts of Nature

71111.04

Corrective Action

Documents

Condition Reports 20-07585, 20-12271

Drawings

01-M-HPP-001

Containment Hydrogen Control

01-M-SIP-001

Safety Injection & Shutdown Cooling System

01-M-SIP-002

Safety Injection & Shutdown Cooling System

2DP-9OP01

Site Wide Status Control Program

40AC-0ZZ06

Locked Valve, Breaker, and Component Control

40DP-9OP02

Conduct of Operations

40DP-9OP02

Conduct of Operations

40DP-9OP09

System Status Control

40DP-9OP19

Locked Valve, Breaker, and Component Tracking

140

Miscellaneous

Updated Final Safety Analysis Report

20A

Procedures

31MT-9HP01

Hydrogen Recombiner/Hydrogen Purge Exhaust Air

Filtration Unit Removal and Installation

Work Orders

215025, 213239

71111.05

Corrective Action

Documents

Condition Reports 20-09313, 20-09674, 20-09686, 20-10991, 20-11197

Miscellaneous

PVGS Pre-Fire Strategies Manual

13-AN-0006

Specification for Field Installation of Presidential W Series

Steel Doors & Frames by Fenestra Corporation

UFSAR Sect 9B

Fire Hazards Analysis

Procedures

14FT-9FP61

Semi-Annual Operational Test of Appendix R and Appendix

A Fire Door Closers

18FT-9FP39

Functional Test of Appendix A Fire/HELB Doors

71111.06

Drawings

01-E-DFB-001

Elementary Diagram Diesel Fuel Oil & Transfer System

Pump

01-E-DFF-001

Control Wiring Diagram Diesel Fuel Oil & Transfer System

Pump

Procedures

81DP-0CC27

Cable and Raceway Control and Tracking System

71111.11Q Miscellaneous

Redacted

LOCT Simulator Examination Scenario

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

2DP-9RS01

Management of Critical Evolutions and Risk Informed

Completion Times Programs

36ST-9SB13

Supplementary Protection System Functional Test

40DP-9OP02

Conduct of Operations

40DP-9OP09

System Status Control

71111.12

Corrective Action

Documents

Condition Reports 19-17214, 18-00819, 16-02466, 20-01185, 16-01780,

17-11615, 19-13541, 20-02505, 20-04319

Procedures

70DP-0MR01

Maintenance Rule

Work Orders

4502099, 4642515, 4289178, 4507039, 4595269, 4808601,

204492, 4642799, 4581614, 5212017, 5139646, 5225802

71111.13

Corrective Action

Documents

Condition Reports 20-10092, 20-10098, 20-10670, 20-11454, 20-11518,

20-11528, 20-12342

Drawings

13-N001-13.04-

Excore Safety Channel Interconnection Diagram

Miscellaneous

Schedulers Evaluation for PV Unit 1

09/11/2020

Schedulers Evaluation for PV Unit 1

09/12/2020

Unit 3 Operator Control Room Logs

07/22/2020

Schedulers Evaluation for PV Unit 3

09/30/2020

Schedulers Evaluation for PV Unit 2

07/09/2020

Schedulers Evaluation for PV Unit 2

08/28/2020

Schedulers

Evaluation for

Palo Verde

Unit 3

07/22/2020

Procedures

2DP-0RS01

Online Integrated Risk

2DP-9RS01

Management of Critical Evolutions and Risk Informed

Completion Times Programs

36ST-9SE01

Excore Safety Channel Log Calibration

40AL-9RK5A

Panel B05A Alarm Responses

2a

40DP-9RS01

Operations Department Online Nuclear Risk Management

Mode 1 and 2

40OP-9PB01

4.16 kV Class 1E Power (PB)

33A

40OP-9SA02

De-Energization of BOP ESFAS

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

70DP-0RA05

Assessment and Management of Risk when Performing

Maintenance in Modes 1 and 2

73DP-9ZZ14

Surveillance Testing

Work Orders

265280, 5061843, 5125779, 5126274, 5251558

71111.15

Corrective Action

Documents

Condition Reports 19-10645, 20-09015, 20-09221, 20-10203, 20-09644,

20-09668, 20-11907

Drawings

01-M-SIP-002

Safety Injection and Shutdown Cooling System

2-M-AFP-001

Piping and Instrumentation Diagram: Auxiliary Feedwater

System

40DP-9OP09

Piping and Instrumentation Diagram: Diesel Generator

System

Miscellaneous

13-MC-HD-0053

Diesel Generator Room Heat Load and Temperature

Calculation during Essential Condition

4699043

Engineering Evaluation

CORA Plant

Computer

Lube Oil Temperature and Pressure Data

CRDR 4452345

Unit 2 Main Feedwater Pump Turbine Fire Root Cause

Evaluation Report

DF/DG/PE DBM

Diesel Generator, Class 1E Standby Generation, Fuel Oil

Storage and Transfer System

Procedures

2DP-9OP01

Site Wide Status Control Program

40AL-9RK2B

Panel B02B Alarm Responses

40DP-9OP02

Conduct of Operations

40DP-9OP09

System Status Control

40DP-9OP26

Operations Condition Reporting Process and Operability

Determination/Functional Assessment

73ST-9SI03

Leak Test of SI/RCS Pressure Isolation Valves

Work Orders

259529, 5265859

71111.18

Corrective Action

Documents

Condition Reports 19-09102

Procedures

40AL-9RK1C

Panel B01C Alarm Responses

81EP-0EE10

Design Change Process

IP-ENG-001

Standard Design Process

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.19

Corrective Action

Documents

Condition Reports 20-09705, 20-10092, 20-12189

Drawings

NN640-A00008

Pulsation Dampener Precharge Adapter

Procedures

30DP-9WP04

Post-Maintenance Testing Development

2MT-9PE01

Cleaning, Inspection, and Testing of Class 1E Emergency

Diesel Generator

37DP-9ZZ02

Major Machine Post-Maintenance Monitoring

40OP-9CH13

Charging Pump Suction Stabilizer and Discharge Pulsation

Dampener Operation

40OP-9SA01

BOP ESFAS Modules Operation

73DP-9ZZ12

Motor Operated Valve (MOV) Program

73DP-9ZZ26

Motor Operated Valve Testing Using QuikLook

73ST-9CH06

Charging Pumps - Inservice Test

73ST-9DG08

Class 1E Diesel Generator Load Rejection, 24 Hour Rated

Load and Hot Start Test Train B

73ST-9SI10

HPSI Pumps Miniflow - Inservice Test

2MT-9ZZ82

Time Delay Relay Testing

Work Orders

4885966, 5262915, 5265280, 5143791, 5143800, 5145409,

29524, 4906601, 4906652, 5145344, 5145345, 5145354,

5145421

71111.22

Corrective Action

Documents

Condition Reports 20-09579, 20-09581, 20-09677, 19-03338, 20-11518,

20-11454

Miscellaneous

Plant Review

Board

STRIDE PRB Approval Meeting for Excore Linear Power

Calibration Presentation

09/21/2020

PVN-E-0030

STRIDE to Extend Frequency for Excore Linear Power

Calibration

Procedures

01DP-0RS02

Surveillance Test Risk Informed Documented Evaluation

(STRIDE) Process

36ST-9SE02

Excore Linear Monthly Calibration

73DP-9ZZ14

Surveillance Testing

73ST-9AF02

Auxiliary Feedwater A - Inservice Test

73ST-9EC02

Essential Chilled Water Pumps - Comprehensive Pump Test 10

71114.06

Miscellaneous

Radiological Assessment Coordinator Quals

08/25/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

PVNGS Emergency Plan

EP-0803 F

Protective Action Recommendation Flow Chart

EP-801 H

Emergency Action Level Classification Matrix - Hot

Conditions

Redacted

LOCT Simulator Examination Scenario

Procedures

EP-0900

Emergency Response Organization Position Checklists

71124.02

Corrective Action

Documents

Condition Reports 19-05697, 19-13194, 19-14038, 20-05124

Miscellaneous

1R21 Radiological Safety Summary

3R21 Radiological Safety Summary

2R22 Radiological Safety Summary

Procedures

75DP-0RP03

ALARA Program Overview

75DP-0RP08

Managing Radiological Risk

75DP-9RP01

Radiation Exposure and Access Control

75RP-9RP02

Radiation Work Permits

75RP-9RP12

ALARA Reports

75TD-9RP02

ALARA Work Planning

Radiation Work

Permits (RWPs)

2019-3002

Reactor DeStack and Restack

2019-3306

Primary Side Steam Generator Maintenance

2019-3502

Valve, Flange, Pump Maintenance and Inspections

20-3306

Primary Side Steam Generator Maintenance

20-3502

Valve, Flange, Pump Maintenance and Inspections

Self-Assessments

2019 Annual ALARA/Management Evaluation Report

RP IPA 1S19

Radiation Protection Integrated Performance Assessment

Report, First Half of 2019

08/24/2019

RP IPA 2S19

Radiation Protection Integrated Performance Assessment

Report, Second Half of 2019

03/12/2020

71124.04

Corrective Action

Documents

Condition Reports 18-01948, 18-07163, 18-13538, 18-16488, 18-17921,

18-18545, 18-18839, 19-06703, 19-08035, 19-13560,

19-15101, 20-04823, 20-05406, 20-05801, 20-05964,

20-06101, 20-07383, 20-07625, 20-08081

Miscellaneous

PVNGS Neutron Study

2009

Dosimetry Program Quality Manual

08/16/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

100536

Personnel Dosimetry Performance Testing

05/15/2020

115-02421-MWL

Minor Change to the EPD Geometry Factor Utilized at

PVNGS

09/17/2002

18-01948-001

Personnel Contamination Event 2-18-00001

03/18/2018

2-20-008

Personnel Contamination Event

04/28/2020

CRDR 4441719

ANI 11-02 Response

2/14/2014

U1 DAW

Database Summary for Waste Type for Unit 1 Dry Active

Waste (DAW) Sea Land

10/05/2019

U2 DAW

Database Summary for Waste Type for Unit 2 Dry Active

Waste (DAW) Sea Land

05/12/2020

U3 DAW

Database Summary for Waste Type for Unit 3 Dry Active

Waste (DAW) Sea Land

2/26/2019

Procedures

75DP-0RP01

RP Program Overview

75DP-9RP01

Radiation Exposure and Access Control

75RP-9ME23

Exposure Evaluation for Lost, Damaged, or Abnormally

Indicating Dosimetry

75RP-9ME27

Issue and Use of IPAM-TX External Alarming Device

75RP-9RP03

Bioassay Analysis

75RP-9RP04

Personnel Contamination Monitoring

75RP-9RP05

Contamination Dose Evaluation

75RP-9RP06

DAC-Hr Tracking

75RP-9RP08

Radiological Air Sampling

75RP-9RP16

Special Dosimetry

Radiation

Surveys

0-M-20200504-2

Annual Survey of TLD Storage in Security Building

05/04/2020

0-M-20200505-4

Annual Survey of TLD Storage in Building F

05/05/2020

Self-Assessments 2018-007

Nuclear Assurance Department Audit Plan and Report for

Radiation Safety

2/14/2018

2-03784

September 2018 Offsite Safety Review Committee Meeting

18- 002, Operations, Chemistry and Radiation Protection

Subcommittee Report

09/21/2018

2-03811

January 2019 Offsite Safety Review Committee (OSRC)

Meeting 19-001, Operations, Chemistry and Radiation

Protection Subcommittee Report

01/31/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2-03854

June 2020 Offsite Safety Review Committee Meeting 20-

001, Operations, Chemistry and Radiation Protection

Subcommittee Report

06/05/2020

71151

Miscellaneous

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Procedures

40DP-9LC01

Performance Indicator - Barrier Integrity Cornerstone: RCS

Leak Rate

40ST-9RC02

ERFDADS (Preferred) Calculation for RCS Water Inventory

74DP-0LC01

RCS Activity Performance Indicator

74ST-9RC02

Reactor Coolant System Specific Activity Surveillance Test

71152

Corrective Action

Documents

Condition Reports 20-08597, 16-11134, 20-12272

Miscellaneous

PVNGS Emergency Plan

Operations News Flash

07/01/2020

Procedures

40DP-9OP02

Conduct of Operations

71153

Miscellaneous

530-2020-001

Licensee Event Report: Spray Pond Pump Inoperable

Greater than TS Allowed Outage Time

04/24/2020