IR 05000528/2020003

Integrated Inspection Report 05000528/2020003, 05000529/2020003, and 05000530/2020003

ML20303A347
Person / Time
Site:	Palo Verde
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. Digitally signed by John L. Dixon Dixon Date: 2020.10.30 08:05:28 -05'00'

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 Enclosure

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 Report Aspect Section Barrier Integrity Green [H.6] - Design 71111.04 NCV 05000529,05000530, Margins05000528/2020003-01 Open/Closed 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 71153 Closed Verde, Condition Prohibited by Technical Specifications Due to Inoperable Spray Pond Pump

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.

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,

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 Report Aspect Section Barrier Integrity Green [H.6] - Design 71111.04 NCV 05000529,05000530, Margins05000528/2020003-01 Open/Closed 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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 40AO-9ZZ21 Acts of Nature 39

71111.04 Corrective Action Condition Reports 20-07585, 20-12271

Documents

Drawings 01-M-HPP-001 Containment Hydrogen Control 22

01-M-SIP-001 Safety Injection & Shutdown Cooling System 59

01-M-SIP-002 Safety Injection & Shutdown Cooling System 44

2DP-9OP01 Site Wide Status Control Program 4

40AC-0ZZ06 Locked Valve, Breaker, and Component Control 18

40DP-9OP02 Conduct of Operations 75

40DP-9OP02 Conduct of Operations 75

40DP-9OP09 System Status Control 55

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 8

Filtration Unit Removal and Installation

Work Orders 215025, 213239

71111.05 Corrective Action Condition Reports 20-09313, 20-09674, 20-09686, 20-10991, 20-11197

Documents

Miscellaneous PVGS Pre-Fire Strategies Manual 28

13-AN-0006 Specification for Field Installation of Presidential W Series 14

Steel Doors & Frames by Fenestra Corporation

UFSAR Sect 9B Fire Hazards Analysis 17

Procedures 14FT-9FP61 Semi-Annual Operational Test of Appendix R and Appendix 19

A Fire Door Closers

18FT-9FP39 Functional Test of Appendix A Fire/HELB Doors 0

71111.06 Drawings 01-E-DFB-001 Elementary Diagram Diesel Fuel Oil & Transfer System 8

Pump

01-E-DFF-001 Control Wiring Diagram Diesel Fuel Oil & Transfer System 3

Pump

Procedures 81DP-0CC27 Cable and Raceway Control and Tracking System 15

71111.11Q Miscellaneous Redacted LOCT Simulator Examination Scenario

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures 02DP-9RS01 Management of Critical Evolutions and Risk Informed 3

Completion Times Programs

36ST-9SB13 Supplementary Protection System Functional Test 19

40DP-9OP02 Conduct of Operations 75

40DP-9OP09 System Status Control 55

71111.12 Corrective Action Condition Reports 19-17214, 18-00819, 16-02466, 20-01185, 16-01780,

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

Procedures 70DP-0MR01 Maintenance Rule 46

Work Orders 4502099, 4642515, 4289178, 4507039, 4595269, 4808601,

204492, 4642799, 4581614, 5212017, 5139646, 5225802

71111.13 Corrective Action Condition Reports 20-10092, 20-10098, 20-10670, 20-11454, 20-11518,

Documents 20-11528, 20-12342

Drawings 13-N001-13.04- Excore Safety Channel Interconnection Diagram 9

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 07/22/2020

Evaluation for

Palo Verde

Unit 3

Procedures 02DP-0RS01 Online Integrated Risk 9

2DP-9RS01 Management of Critical Evolutions and Risk Informed 3

Completion Times Programs

36ST-9SE01 Excore Safety Channel Log Calibration 99

40AL-9RK5A Panel B05A Alarm Responses 2a

40DP-9RS01 Operations Department Online Nuclear Risk Management 6

Mode 1 and 2

40OP-9PB01 4.16 kV Class 1E Power (PB) 33A

40OP-9SA02 De-Energization of BOP ESFAS 25

Inspection Type Designation Description or Title Revision or

Procedure Date

70DP-0RA05 Assessment and Management of Risk when Performing 23

Maintenance in Modes 1 and 2

73DP-9ZZ14 Surveillance Testing 27

Work Orders 5265280, 5061843, 5125779, 5126274, 5251558

71111.15 Corrective Action Condition Reports 19-10645, 20-09015, 20-09221, 20-10203, 20-09644,

Documents 20-09668, 20-11907

Drawings 01-M-SIP-002 Safety Injection and Shutdown Cooling System 44

2-M-AFP-001 Piping and Instrumentation Diagram: Auxiliary Feedwater 35

System

40DP-9OP09 Piping and Instrumentation Diagram: Diesel Generator 64

System

Miscellaneous 13-MC-HD-0053 Diesel Generator Room Heat Load and Temperature 6

Calculation during Essential Condition

4699043 Engineering Evaluation

CORA Plant Lube Oil Temperature and Pressure Data

Computer

CRDR 4452345 Unit 2 Main Feedwater Pump Turbine Fire Root Cause 2

Evaluation Report

DF/DG/PE DBM Diesel Generator, Class 1E Standby Generation, Fuel Oil 28

Storage and Transfer System

Procedures 02DP-9OP01 Site Wide Status Control Program 4

40AL-9RK2B Panel B02B Alarm Responses 59

40DP-9OP02 Conduct of Operations 75

40DP-9OP09 System Status Control 55

40DP-9OP26 Operations Condition Reporting Process and Operability 46

Determination/Functional Assessment

73ST-9SI03 Leak Test of SI/RCS Pressure Isolation Valves 55

Work Orders 5259529, 5265859

71111.18 Corrective Action Condition Reports 19-09102

Documents

Procedures 40AL-9RK1C Panel B01C Alarm Responses 7

81EP-0EE10 Design Change Process 49

IP-ENG-001 Standard Design Process 1

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.19 Corrective Action Condition Reports 20-09705, 20-10092, 20-12189

Documents

Drawings NN640-A00008 Pulsation Dampener Precharge Adapter 3

Procedures 30DP-9WP04 Post-Maintenance Testing Development 20

2MT-9PE01 Cleaning, Inspection, and Testing of Class 1E Emergency 45

Diesel Generator

37DP-9ZZ02 Major Machine Post-Maintenance Monitoring 3

40OP-9CH13 Charging Pump Suction Stabilizer and Discharge Pulsation 31

Dampener Operation

40OP-9SA01 BOP ESFAS Modules Operation 32

73DP-9ZZ12 Motor Operated Valve (MOV) Program 19

73DP-9ZZ26 Motor Operated Valve Testing Using QuikLook 6

73ST-9CH06 Charging Pumps - Inservice Test 38

73ST-9DG08 Class 1E Diesel Generator Load Rejection, 24 Hour Rated 14

Load and Hot Start Test Train B

73ST-9SI10 HPSI Pumps Miniflow - Inservice Test 53

2MT-9ZZ82 Time Delay Relay Testing 23

Work Orders 4885966, 5262915, 5265280, 5143791, 5143800, 5145409,

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

5145421

71111.22 Corrective Action Condition Reports 20-09579, 20-09581, 20-09677, 19-03338, 20-11518,

Documents 20-11454

Miscellaneous Plant Review STRIDE PRB Approval Meeting for Excore Linear Power 09/21/2020

Board Calibration Presentation

PVN-E-0030 STRIDE to Extend Frequency for Excore Linear Power 0

Calibration

Procedures 01DP-0RS02 Surveillance Test Risk Informed Documented Evaluation 2

(STRIDE) Process

36ST-9SE02 Excore Linear Monthly Calibration 90

73DP-9ZZ14 Surveillance Testing 27

73ST-9AF02 Auxiliary Feedwater A - Inservice Test 60

73ST-9EC02 Essential Chilled Water Pumps - Comprehensive Pump Test 10

71114.06 Miscellaneous Radiological Assessment Coordinator Quals 08/25/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

PVNGS Emergency Plan 67

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 20

71124.02 Corrective Action Condition Reports 19-05697, 19-13194, 19-14038, 20-05124

Documents

Miscellaneous 1R21 Radiological Safety Summary

3R21 Radiological Safety Summary

2R22 Radiological Safety Summary

Procedures 75DP-0RP03 ALARA Program Overview 6

75DP-0RP08 Managing Radiological Risk 3

75DP-9RP01 Radiation Exposure and Access Control 23

75RP-9RP02 Radiation Work Permits 32

75RP-9RP12 ALARA Reports 6

75TD-9RP02 ALARA Work Planning 13

Radiation Work 2019-3002 Reactor DeStack and Restack 3

Permits (RWPs) 2019-3306 Primary Side Steam Generator Maintenance 1

2019-3502 Valve, Flange, Pump Maintenance and Inspections 1

20-3306 Primary Side Steam Generator Maintenance 2

20-3502 Valve, Flange, Pump Maintenance and Inspections 2

Self-Assessments 2019 Annual ALARA/Management Evaluation Report

RP IPA 1S19 Radiation Protection Integrated Performance Assessment 08/24/2019

Report, First Half of 2019

RP IPA 2S19 Radiation Protection Integrated Performance Assessment 03/12/2020

Report, Second Half of 2019

71124.04 Corrective Action Condition Reports 18-01948, 18-07163, 18-13538, 18-16488, 18-17921,

Documents 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 Type Designation Description or Title Revision or

Procedure Date

100536 Personnel Dosimetry Performance Testing 05/15/2020

115-02421-MWL Minor Change to the EPD Geometry Factor Utilized at 09/17/2002

PVNGS

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 02/14/2014

U1 DAW Database Summary for Waste Type for Unit 1 Dry Active 10/05/2019

Waste (DAW) Sea Land

U2 DAW Database Summary for Waste Type for Unit 2 Dry Active 05/12/2020

Waste (DAW) Sea Land

U3 DAW Database Summary for Waste Type for Unit 3 Dry Active 12/26/2019

Waste (DAW) Sea Land

Procedures 75DP-0RP01 RP Program Overview 12

75DP-9RP01 Radiation Exposure and Access Control 23

75RP-9ME23 Exposure Evaluation for Lost, Damaged, or Abnormally 14

Indicating Dosimetry

75RP-9ME27 Issue and Use of IPAM-TX External Alarming Device 8

75RP-9RP03 Bioassay Analysis 10

75RP-9RP04 Personnel Contamination Monitoring 9

75RP-9RP05 Contamination Dose Evaluation 8

75RP-9RP06 DAC-Hr Tracking 6

75RP-9RP08 Radiological Air Sampling 1

75RP-9RP16 Special Dosimetry 26

Radiation 0-M-20200504-2 Annual Survey of TLD Storage in Security Building 05/04/2020

Surveys 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 12/14/2018

Radiation Safety

2-03784 September 2018 Offsite Safety Review Committee Meeting 09/21/2018

18- 002, Operations, Chemistry and Radiation Protection

Subcommittee Report

2-03811 January 2019 Offsite Safety Review Committee (OSRC) 01/31/2019

Meeting 19-001, Operations, Chemistry and Radiation

Protection Subcommittee Report

Inspection Type Designation Description or Title Revision or

Procedure Date

2-03854 June 2020 Offsite Safety Review Committee Meeting 20- 06/05/2020

001, Operations, Chemistry and Radiation Protection

Subcommittee Report

71151 Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

Procedures 40DP-9LC01 Performance Indicator - Barrier Integrity Cornerstone: RCS 4

Leak Rate

40ST-9RC02 ERFDADS (Preferred) Calculation for RCS Water Inventory 54

74DP-0LC01 RCS Activity Performance Indicator 6

74ST-9RC02 Reactor Coolant System Specific Activity Surveillance Test 16

71152 Corrective Action Condition Reports 20-08597, 16-11134, 20-12272

Documents

Miscellaneous PVNGS Emergency Plan 67

Operations News Flash 07/01/2020

Procedures 40DP-9OP02 Conduct of Operations 74

71153 Miscellaneous 530-2020-001 Licensee Event Report: Spray Pond Pump Inoperable 04/24/2020

Greater than TS Allowed Outage Time

18