IR 05000528/2021002
| ML21217A331 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/09/2021 |
| From: | John Dixon NRC/RGN-IV/DRP |
| To: | Lacal M Arizona Public Service Co |
| References | |
| EA-21-083 IR 2021002 | |
| Download: ML21217A331 (25) | |
Text
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION - INTEGRATED INSPECTION REPORT 05000528/2021002, 05000529/2021002, AND 05000530/2021002 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mrs. Lacal:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station. On July 20, 2021, the NRC inspectors discussed the results of this inspection with Mr. T. Horton, Senior Vice President, Site Operations, 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.
A violation of 10 CFR 50.54(q)(2) was identified. Because the violation occurred as a result of the COVID-19 public health emergency described in Enforcement Guidance Memorandum 2020-002 (EGM-20-002), Dispositioning Violations of NRC Requirements during Coronavirus Disease 2019 (COVID-19), dated April 15, 2020, and because you met the conditions specified in this EGM, Attachment 3, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and is not issuing an enforcement action for this violation.
If you contest the violation or the significance 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.
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.
August 9, 2021 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:
Report Numbers:
05000528/2021002, 05000529/2021002 and 05000530/2021002
Enterprise Identifier:
I-2021-002-0110
Licensee:
Arizona Public Service Company
Facility:
Palo Verde Nuclear Generating Station
Location:
Tonopah, AZ
Inspection Dates:
April 1, 2021 to June 30, 2021
Inspectors:
L. Merker, Senior Resident Inspector
E. Lantz, Resident Inspector
N. Cuevas, Resident Inspector
J. Ellegood, Senior Resident Inspector
A. Sanchez, Senior Project Engineer
R. Azua, Senior Reactor Inspector
C. Peabody, Nuclear Engineer
R. Alexander, Senior Emergency Preparedness Inspector
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, 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 Develop an Adequate Testing Program for Fuel Transfer Tubes Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000528, 05000529,05000530/2021002-01 Open/Closed
[P.2] -
Evaluation 71111.08P The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
Criterion XI, Test Control. Specifically, the licensee failed to establish adequate testing requirements and acceptance limits to detect degradation of the fuel transfer tubes as required by 10 CFR Part 50, Appendix B, Criterion XI. Failure to detect degradation of the fuel transfer tube could result in the fuel transfer tube being rendered inoperable and unable to meet its safety-related functions.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-21-083 ERO Augmentation Response Timeline during the Public Health Emergency (EGM 20-002, Attachment 3)71114.04 Closed
PLANT STATUS
Unit 1 operated at or near full power for the duration of the inspection period.
Unit 2 entered the inspection period at full power. On May 19, 2021, the unit tripped on high pressurizer pressure due to an inadvertent actuation of a main steam isolation signal during engineered safety features actuation system testing. Unit 2 was restarted on May 21, 2021, and remained at or near full power for the remainder of the inspection period.
Unit 3 entered the inspection period at full power. On April 9, 2021, Unit 3 shut down for a planned refueling outage. Unit 3 was restarted on May 17, 2021, and operated at 12 percent power to perform main turbine control system troubleshooting until May 22, 2021, when the unit returned to full power. On May 25, 2021, the unit had a short-term, unplanned down power to 85 percent power to isolate a steam leak on the first-stage reheater drain tank level controller.
The unit returned to full power on May 26, 2021, and operated at or near full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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 standard 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 a portion 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of the seasonal high temperatures for the following systems on June 17, 2021:
Units 1, 2, and 3, emergency diesel generator system B
Units 1, 2, and 3, essential spray pond system B
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 3, containment spray system B in shutdown cooling, on April 15, 2021
- (2) Unit 3, spent fuel pool cooling systems A and B, on April 23, 2021
- (3) Unit 2, low pressure safety injection system A, on June 30, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 3 auxiliary feedwater system on June 16, 2021.
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 2, 100-foot elevation of turbine building, Fire Zone TB1, on April 23, 2021
- (2) Unit 1, main control room, Fire Zone 17, on June 21, 2021
- (3) Unit 3, essential chiller systems A and B rooms, Fire Zones 1 and 2, on June 22, 2021
- (4) Unit 3, 100-foot elevation of auxiliary building, Fire Zones 42A, 42B, 42C, 42D, on June 28, 2021
- (5) Unit 1, low pressure safety injection system A pump room, Fire Zone 32A, during pre-action sprinkler system maintenance, on June 30, 2021
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors verified, via remote inspection, that the Unit 3 reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities from April 12 to May 3, 2021.
03.01.a - Nondestructive Examination and Welding Activities
Radiographic examination (RT)a.
Low Pressure Safety Injection header drain and test Valve 3PSIEV064**VALVEX, Weld 572050-1 b.
Low Pressure Safety Injection header drain and test Valve 3PSIEV064**VALVEX, Weld 572050-2
Ultrasonic Examination (UT)a.
Steam Generator 1 feedwater downcomer, Weld 58-16 b.
Shutdown cooling loop 1, Weld 21-18 c.
Shutdown cooling loop 1, Weld 21-19 d.
Pressurizer, Weld 5-2 e.
Shutdown Cooling Heat Exchanger Room A, Weld 74-75
Dye Penetrant Examination (PT)a.
Low Pressure Safety Injection header drain and test Valve 3PSIEV064**VALVEX, Weld 572050-1 b.
Low Pressure Safety Injection header drain and test Valve 3PSIEV064**VALVEX, Weld 572050-2
Visual Examination (VT)a.
Reactor Vessel Head bolted connections b.
Steam Generator 1 manway bolted connections 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities The inspectors reviewed the following documents associated with boric acid leaks and evaluations
Condition Reports: 19-17526, 19-18644, 20-01806, 20-01864, 20-02472, 20-03083, 20-03339, 20-05337, 20-09869, 20-11001, 20-11785, 20-11809, 20-11828, 20-16767, 21-04165, 21-04166, 21-02088, 21-02935 03.01.d - Pressurized-Water Reactor Steam Generator Tub Examination Activities
The licensee performed:
a.
100 percent full length bobbin testing using a 0.610-inch diameter bobbin probe for all tubes b.
100 percent X-Probe inspection of all bobbin flaw-like signals at tube support structures that had bobbin indicated depth greater than 20 percent through wall c.
100 percent tube plug visual inspection from the primary side in all steam generators d.
Visual inspection of the channel head hot leg and cold leg primary side in all steam generators, including all visible clad surfaces
No in situ pressure testing was required Problem Identification and Resolution
The inspectors reviewed two condition reports associated with inservice and operating experience issues. As a result of this review, the inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. This finding is documented in this report.
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 licensed operator performance in the control room during Unit 3 dilution to estimated critical boron concentration and reactor startup, on May 16, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated operator requalification simulator training activities, on May 27, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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 1, switchyard maintenance during Unit 2 and Unit 3 outage, on May 21, 2021
- (2) Unit 3, emergent maintenance for a first stage reheater drain tank level controller steam leak that resulted in a down power, on May 26, 2021
- (3) Units 1 and 3, reactor protection system and engineered safety features actuation system surveillance testing, post Unit 2 trip, on June 7, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 3, electrical duct bank observed to be installed in direct contact with essential spray pond system A piping, on April 20, 2021
- (2) Unit 1, voltage transient on 120 Vac non-class 1E distribution panel NQN-D01 resulting in loss of the plant monitoring computer and core monitoring computer core operating limit supervisory system, on May 10, 2021
- (3) Unit 1, safety injection tank 1B vent valve A failure to close, on May 15, 2021
- (4) Unit 3, pressurizer vent valve RCA-HV-104 stroke time testing, on June 15, 2021
- (5) Unit 3, 10 Vac pushbutton failure during variable overpower trip adjustment, on May 28, 2021
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) Unit 3, polar crane temporary modification to bypass the high-pressure switches from the main and auxiliary hoist hydraulic energy-absorbing cylinders, on May 14, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 3, turbine-driven auxiliary feedwater pump testing following turbine disassembly and inspection, on May 3, 2021
- (2) Unit 3, testing of shutdown heat exchanger A outlet valve, 3JSIAHV0686, following disassembly and repack, on May 4,2021
- (3) Unit 2, engineered safety features actuation system matrix testing following Channel C relay hold matrix switch and test power supply replacement, on May 20, 2021
- (4) Unit 2, motor-driven auxiliary feedwater pump room essential air control unit inspection and testing, on May 26, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated the Unit 3 Refueling Outage 22 activities from April 9 to May 17, 2021.
- (2) The inspectors evaluated the Unit 2 forced outage activities following a reactor trip from May 19-21, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2, reactor trip switchgear Channel C circuit breaker time response testing, on April 6, 2021
- (2) Unit 3, steam generator 2 main steam safety valve testing, on April 10, 2021
- (3) Unit 2, main steam safety valve testing on valves that lifted during a reactor trip, on May 23, 2021
- (4) Unit 2, motor-driven auxiliary feedwater pump thermography and inservice testing, on May 26, 2021
- (5) Unit 1, plant protection system functional testing of reactor protection system and engineered safety features actuation system logic, on June 7, 2021
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 3, refuel access purge up-stream inlet containment isolation valve 2A inservice testing, on April 28, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Unit 3, containment isolation valve for chemical and volume control system charging line penetration 41, CHE-U41, testing, on May 1, 2021
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on March 9, 2021. The exercise scenario simulated on Unit 1 a letdown (liquid release)radiation monitor going into high alarm, a major electrical fault and fire in the train A safety-related electrical switchgear, an automatic reactor trip, failure of the fuel building crane resulting in dropping an empty dry fuel cask damaging the spent fuel pool wall, subsequent loss of spent fuel pool water level, and demonstration of extensive damage mitigation strategies consistent with 10 CFR 50.155(b)(2). The licensee completed its critique process for the exercise on April 1, 2021, and the inspectors subsequently evaluated the effectiveness of the critique process to identify performance weaknesses and deficiencies to ensure they were entered into the corrective action program for resolution. (This documents completion of this inspection sample which was documented as a partial sample in the 1st Quarter 2021 inspection report.)
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following emergency plan changes:
Changes to [Emergency Response Organization] Staff Augmentation During a
[COVID-19] Public Health Emergency, dated July 16, 2020, and December 21, 2020
Revision 69 to the site emergency plan, submitted to the NRC on April 9, 2021
Palo Verde Nuclear Generating Station Units 1, 2, and 3, Docket Nos. 50-528/529/530, Proposed Revision to the Emergency Plan, dated November 16, 1993 These evaluations do not constitute NRC approval.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the emergency preparedness drill (Emergency Response Organization Green Team) on June 8,
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue. The inspectors performed an in-depth review of the licensees ability to identify issues regarding Magne-Blast circuit breakers, evaluate each occurrence, and implement corrective actions.
From January 1 through June 30, 2021, the licensee wrote 10 condition reports documenting issues regarding Magne-Blast circuit breakers. The inspectors assessed the licensees problem identification threshold, evaluations, and corrective actions related to these condition reports. In each instance, the licensee adequately followed site procedures to identify, evaluate, and correct the issue.
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) Unit 3, reactor coolant pump 2B seal injection water leakage following Refueling Outage 22, on May 9, 2021
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)
- (1) The inspectors evaluated the Unit 2 automatic reactor trip and the licensees response, on May 19,
INSPECTION RESULTS
Failure to Develop an Adequate Testing Program for Fuel Transfer Tubes Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000528, 05000529,05000530/2021002-01 Open/Closed
[P.2] -
Evaluation 71111.08P The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. Specifically, the licensee failed to establish adequate testing requirements and acceptance limits to detect degradation of the fuel transfer tubes as required by 10 CFR Part 50, Appendix B, Criterion XI. Failure to detect degradation of the fuel transfer tube could result in the fuel transfer tube being rendered inoperable and unable to meet its safety-related functions.
Description:
During an inspection of the Palo Verde Nuclear Generating Station Unit 3 Inservice Inspection Program, the inspectors reviewed the licensees surveillance test (RT-201580/WSL-5202549) for the fuel transfer tube PCE-M01, which is located between the spent fuel pool fuel transfer canal and the refueling cavity. The tube is also surrounded by a secondary tube structure, the fuel transfer tube housing PCE-M01C. Specifically, this test was developed as a corrective action for NCV 05000528, 05000529,05000530/2019002-01 (ADAMS Accession No. ML19220B489), and was designed to verify that the fuel transfer tube leakage rate did not exceed a 3 inch drop in spent fuel pool level during a 45 minute test (145 gallons per minute). The basis for the acceptance criteria for this test was the licensees ability to make up this rate of flow should such a leak exist. Based on the review of the surveillance test, two items were noted:
- (1) The engineering evaluation that the licensee used to identify the largest leak rate that the transfer tube could experience did not evaluate the potential impact that a flaw of that magnitude would have on the pipes capability to withstand a design basis earthquake; and
- (2) The test failed to consider the secondary tube structure surrounding the fuel transfer tube (fuel transfer tube housing) and the impact that it would have on the results of the test. Specifically, the volume of the anulus between the two tube structures was approximately 1000 gallons. As a result, the test would probably not yield a leak rate greater than 22 gallons per minute during the 45-minute test, regardless of the size of the leak.
Based upon a review of the Combustion Engineering Standard Safety Analysis Report and the Update Final Safety Analysis Report, the fuel transfer tube assembly has four safety related, quality-related (Q) functions, including decay heat removal for the spent fuel pool and the reactor during the fuel transition mode of refueling operations under a scenario where a loss of off-site power is assumed in conjunction with a single mechanical failure. During this mode of operation when the core is being off loaded or re-loaded, the spent fuel pool cooling system may be augmented by one train of shutdown cooling (using either the low pressure spray injection or containment spray pump) and associated auxiliaries. The shutdown cooling train in service is aligned such that it would provide cooling to both the reactor core and the spent fuel pool. Flow through the fuel transfer tube PCE-M01 is credited for heat removal purposes in this case. This function was part of DMWO 00793132, Fuel Transfer Tube Assembly Subcomponent Reclassification, which was implemented in 1997.
In 2019 the fuel transfer tube and associated equipment were removed from the inservice inspection program; however they continue to be quality Class Q components.
Corrective Actions: The Licensee has entered the issue into their corrective action program and walked down and inspected the fuel transfer tube prior to plant startup. No signs of tube deterioration were noted.
Corrective Action References: Condition Report CR 21-05449
Performance Assessment:
Performance Deficiency: Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, the licensee failed to develop an adequate testing program for the fuel transfer tube to ensure it remained capable of performing its safety functions under design conditions.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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 licensee failed to have an adequate testing procedure to perform examinations/testing required to provide reasonable assurance that the fuel transfer tube could perform its intended function during design basis events, and therefore, maintain the ability to provide cooling to the irradiated fuel assemblies.
Significance: Using NRC Inspection Manual Chapter 0609, Appendix G, Attachment 1, Exhibit 3, Mitigating Systems, the inspectors determined the finding is of very low safety significance (Green) because the finding was related to the qualification of the component and the component remained operable or functional.
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.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that systems, structures, and components will perform satisfactorily in service is identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, prior to May 3, 2021, the licensee failed to establish a test program to assure that all testing, required to demonstrate that the fuel transfer tubes will perform satisfactorily in service, was identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, the licensee did not establish adequate examinations and testing required by 10 CFR Part 50, Appendix B, Criterion XI, Test Control, to detect degradation of the fuel transfer tube. As indicated, this violation is documented in the licensees corrective action program as CR 21-05449.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement Discretion Enforcement Action EA-21-083: ERO Augmentation Response Timeline during the Public Health Emergency (EGM 20-002, 3)71114.04
Description:
The Palo Verde Nuclear Generating Station (PVNGS) Emergency Plan, Section 4.2 and Table 1 delineate the number of staff required on-shift to support emergency response activities. This same section and table also describe the number of staff required to augment and staff the emergency response facilities after an Alert or higher declaration within two timeframes: 60-minute augmentation during normal hours, and 120-minute augmentation during off-hours.
Upon the start of the COVID-19 Public Health Emergency (PHE) in March 2020, the licensee reduced normal site staffing and plant work activities to a minimum to reduce the risk of infection to plant staff from the COVID-19 virus. Concurrent with the reduction of onsite staffing and moving of most site personnel to work-at-home activities, the licensees emergency preparedness (EP) staff developed an evaluation to shift the emergency response organization (ERO) response timelines to align continuously with the off-hours activation requirement of 120 minutes, rather than the variable requirement to activate the facilities within 60 minutes of an Alert or higher declaration during normal work hours, and within 120 minutes during off-hours. While the PVNGS Emergency Plan does not define normal hours and off-hours, a licensee Administrative Procedure 16DP-0EP34-01, generally defines normal hours to include the hours of 7:00 a.m. through 5:30 p.m. Tuesday through Friday, and off-hours to include all other periods. (Most licensee personnel work four, 10-hour workdays per week, if not assigned on-shift work activities.)
In the evaluation, the licensee stated that because on-shift staffing was designed to support an ERO augmentation period of 120 minutes during the off-hours (worst case) conditions, shifting the ERO augmentation period continuously during the COVID-19 PHE to the 120-minute timeframe did not reduce the effectiveness of the PVNGS Emergency Plan and emergency response readiness would be effectively maintained. The evaluation provided additional evidence to support this conclusion including the licensees use of the all call ERO augmentation method where the entire ERO is called out to staff the emergency response facilities (vice only a duty on-call team), thereby increasing the likelihood that the response facilities would be staffed well before the 120-minute maximum requirement.
The inspectors independently reviewed the licensees on-shift staffing analyses and augmentation methodology, in part to assess the assumptions and statements in the licensees evaluation. Further, the inspectors reviewed the licensees evaluation against the criteria in Enforcement Guidance Memorandum (EGM) 2020-002, Attachment 3, and concluded that the licensee had demonstrated the four EGM criteria were satisfied by the licensees evaluation.
Corrective Actions: The licensee documented its evaluation of the shift in ERO augmentation timelines to the off-hours 120-minute timeframe in an initial document dated July 16, 2020, after initial communications with the Region IV EP inspection staff earlier in the spring 2020.
As the PHE continued, and the licensee extended the work-at-home activities for most PVNGS staff until at least early 2021, the licensees EP staff reviewed and updated the original evaluation in December 2020.
Corrective Action References: CR 2020-06418
Enforcement:
Significance/Severity: The inspectors determined that the failure to maintain the requirement of the PVNGS Emergency Plan, Section 4.2 and Table 1, relative ERO augmentation staffing within 60 minutes during normal hours, would have been characterized as having a very low safety significance (Green) using the Manual Chapter 0609, Appendix B, Emergency Preparedness SDP. Specifically, the 10 CFR 50.47(b)(2) planning standard function of a process for timely augmentation of on shift staff is established and maintained would be best characterized as a degraded function (i.e., Green). However, in that the circumstances which resulted in this change (i.e., the COVID-19 PHE) were not within the licensees ability to foresee or correct, no performance deficiency was identified for this issue.
Violation: Title 10 CFR 50.54(q)(2) requires that licensees shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to Part 50 and the planning standards of § 50.47(b). Title 10 CFR 50.47(b)(2) requires, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined and timely augmentation of response capabilities is available. The PVNGS Emergency Plan, Section 4.2 and Table 1 define the licensees on-shift and emergency response augmentation requirements, including augmentation staffing of emergency response facilities within 60 minutes of an emergency declaration during normal hours, and within 120 minutes during off-normal hours. Contrary to the above, from April 2020 to May 17, 2021, the licensee failed to maintain the augmentation staffing of emergency response facilities within 60 minutes of an emergency declaration during normal hours. Specifically, due to the ongoing COVID-19 PHE, the licensee shifted ERO augmentation to the 120 minute goal for all times (normal and off-hours), following documenting an evaluation that concluded the temporary change/compensatory measure did not reduce the effectiveness of the Emergency Plan and emergency response readiness would be effectively maintained.
Basis for Discretion: Because the violation occurred as a result of the COVID-19 PHE described in Enforcement Guidance Memorandum 2020-002 and because the licensee met the conditions specified in this EGM, Attachment 3, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and is not issuing an enforcement action for this violation.
Very Low Safety Significance Issue Resolution Process: Change to Emergency Plan in 1994 Relative to Emergency Response Organization (ERO)
Augmentation Timelines 71114.04 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.
Description:
In reviewing the documentation and bases related to the licensees ERO augmentation changes during the COVID-19 Public Health Emergency (see writeup for EGM 2020-02 implementation), the inspectors identified that the licensee submitted a request to NRC Headquarters in November 1993, per 10 CFR 50.54(q) for a review and approval of a change to the stations emergency plan related to the ERO augmentation timeline requirements; moving from 30 and 60 minute response requirements, to 60 and 120 minute requirements (ADAMS Accession No. ML17310A818). However, in further reviewing the NRC correspondence sent back to Palo Verde Nuclear Generating Station (PVNGS) in February 1994 regarding the request (ADAMS Accession No. ML17310B081), the inspectors found that the letter approving the change was addressed from NRC Region V (Walnut Creek, CA office), and did not include a formal Safety Evaluation Report (SER) documenting the bases for the approval.
As documented in Regulatory Issue Summary (RIS) 2007-01, Clarification of NRC Guidance for Maintaining a Standard Emergency Action Level Scheme, (ADAMS Accession No. ML062760472), and other NRC decisions from the early 2000s, requests from power reactor licensees for review and approval of emergency plan changes sent to NRC Regions and any letters from the Regions in response to the licensee requests for review and approval were not legally binding approvals in that the Commission had only delegated the authority to review and approve changes to power reactor licenses (of which emergency plan changes are a subset) down to the Office of Nuclear Reactor Regulation (NRR). As such, on the surface, the inspectors questioned whether the 1994 letter from NRC Region V to PVNGS was a valid NRC approval of the change to the licensees emergency plan, and whether the licensee had made a change to its emergency plan contrary to 10 CFR 50.54(q).
In 1993, 10 CFR 50.54(q) required in part that the licensee shall retain the emergency plan and each change that decreases the effectiveness of the plan as a record until the Commission terminates the license for the nuclear power reactor.Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in § 50.4, a report of each proposed change for approval. As such, if the 1994 letter from NRC Region V did not convey valid NRC approval, the licensee may have violated this requirement by implementing emergency plan changes that decreased the effectiveness of the plan, without prior NRC approval.
The inspectors found that the PVNGS request in November 1993 was directly addressed to NRC Headquarters as required by 10 CFR 50.54(q) and § 50.4. The inspectors also found in NRC records, an internal memorandum to file written by Region V staff, dated February 25, 1994 (ADAMS Accession No. ML17310B094, Not Publicly Available), which documents the receipt of the PVNGS request in November 1993, a review of the proposed changes by a Region V EP Analyst, and coordination and conversations in mid-February 1994 between staff in Region V and the Emergency Preparedness Branch in NRR (NRR/PEPB) regarding the request. The same memo documented Region Vs intention to approve the changes to the PVNGS ERO augmentation timeline scheme based on the NRR/PEPBs approval of similar changes at other power reactor licensees, and that the NRR/PEPBs staff member concurred with Region Vs position.
Subsequently, on February 25, 1994, Region V issued the aforementioned letter to PVNGS which stated in part based on our review of the proposed changes and your justification for the changes - on-shift staffing levels and the remoteness of the PVNGS - we approve the proposed changes to the PVNGS Emergency Plan. The inspectors also found that this letter to PVNGS had received concurrence on its content by the Branch Chief of NRR/PEPB.
Therefore, the inspectors determined that while the 1994 approval letter was issued by NRC Region V, the licensee submitted their change request to the appropriate NRC headquarters address, and that the NRC Office responsible for approving emergency plan changes (NRR)reviewed and concurred on PVNGSs 1993 submittal.
Licensing Basis: As described in subsequent license amendment requests from PVNGS which requested changes related to the stations on-shift and/or augmenting ERO staff, and were subsequently approved by NRR (e.g., February 5, 1999 (ADAMS Accession No. ML17313A777), and July 31, 2020 (ADAMS Accession No. ML20163A037)), the licensee clearly noted that they understood/believed that the NRC had approved the 1993 change to the 60/120 ERO augmentation timelines in its emergency plan. Additionally, the inspectors identified that in the 1999 license amendment and SER approved by NRR, the NRC staff clearly indicate an understanding that the prior 1994 review and approval was completed in an acceptable manner. That subsequent SER states:
On November 16, 1993, APS [Arizona Public Service, the licensee] submitted proposed Revision 13 to the PVNGS Emergency Plan, requesting NRC approval in accordance with 10 CFR 50.54(q). Revision 13 moved the 30-minute responders on-shift and reduced the number of off-site monitoring teams from two to one. APS committed to place 10 radiological responders on-shift. The staff approved Revision 13 on February 25, 1994, after concluding that the on-shift staffing levels exceeded the staffing guidance in Table B-1 of NUREG-0654/FEMA-REP-1.
Further, while the November 1993 request from PVNGS does not specifically state that the licensee determined that the proposed change constituted a decrease in effectiveness to the emergency plan, the letter specifically requests review and approval of the change, which at least implies that the licensee had determined that the change could have constituted a decrease in effectiveness. The contemporary inspectors requested to review the 10 CFR 50.54(q) evaluation from 1993 which may have documented the licensees determination of a potential decrease in effectiveness. However, no such document has been retained by the licensee, nor would necessarily have been required to be retained, in that the licensee submitted the request for review and approval of the change to the NRC, and that submission included an analysis and bases for the requested changes. Based on the totality of data available to the licensee and NRC, the inspectors determined that from January 1994 to present the licensee had interpreted the receipt of the Region V letter as the formal NRC review and approval of the change to its emergency plan relative to the ERO augmentation timelines, and retained the documentation of the request and approval as required by 10 CFR 50.54(q).
However, different from examples described in RIS 2007-01, the inspectors concluded that PVNGS appropriately submitted the change request for review and approval to NRC Headquarters (vice to a Region), and there is documented communication, coordination, and evaluation between NRR and Region V regarding the proposed change. While there is no apparent NRC documentation of an SER for the change and the letter issuing the statement of approval did not come from the delegated authority (NRR) [as was, and is, the normal NRC practice for documenting such change approvals] the licensee had little reason to believe at the time that the letter from Region V was an invalid approval from the NRC. Yet, there were opportunities for the licensee to identify this issue existed after issuance of the RIS, albeit 13 years later. Further, as noted in the subsequent, related 1999 SER, the NRC clearly expressed an understanding that the 1993 request for review and approval was conducted by the NRC staff (NRR) staff and constituted a legally valid licensing action.
Significance: The inspectors initially assessed the potential significance of this issue using the guidance in IMC 0612, Appendices B and G. Specifically, as noted in IMC 0612, Appendix G, Emergency Planning Cornerstone-Specific Supplemental Guidance for Appendix B Screening Figures 1 and 2, in evaluating the issue for applicability to Traditional Enforcement (IMC 0612, Appendix B, Block TE), a licensees failure to obtain NRC approval for an Emergency Plan change when required by 10 CFR 50.54(q) is a violation that impacted the ability of the NRC to perform its regulatory oversight and would be processed under traditional enforcement, only if certain criteria are satisfied. The inspectors assessed the Traditional Enforcement path did not apply in this case in that the ERO augmentation timelines in the PVNGS Emergency Plan were changed to 60- and 120-minute timeframes in January 1994; however, the licensee did analyze the change impact on the effectiveness of the emergency plan (as described in the 1993 request), there was no clear deficiency in the analysis (based on the Region V February 1994 internal memo, and the contemporary inspectors review of the 1993 request), and the licensee submitted the application to the NRC for prior approval as required.
In following the ROP path in IMC 0612, Appendix B, the inspectors would next assess if the VLSSIR process applies but considered if there was a performance deficiency first to inform the significance assessment. In this case, the inspectors assessed the issue of concern may be the result of the licensee failing to meet the requirements of 10 CFR 50.54(q), but as previously noted, the inspectors determined that this issue of concern was not reasonably within the licensees ability to foresee and correct such that the issue could have been prevented. Specifically, the licensee completed the request for the change to the emergency plan, appropriately submitted to NRC Headquarters for prior review and approval, and only after receiving a response from the NRC (in this case Region V) did they affect the change to the emergency plan. As such, this assessment concludes there is not a performance deficiency, yet as previously assessed, the Traditional Enforcement path also does not apply for the assessment.
Finally, the inspectors assessed if the issue would have been more than minor assuming a performance deficiency had occurred. Specifically, the inspectors assessed if the emergency preparedness cornerstone objective would have been adversely affected by assessing PVNGSs current On-Shift Staffing Analyses. The analyses were reviewed to determine whether the licensees on-shift staff would be capable of responding to a range of emergency events without the need for early augmented ERO staffing. The inspectors concluded that the licensee demonstrates that the on-shift staffing is sufficient to combat the most significant events for the first 120 minutes without any augmenting ERO staff. As such, an assumed performance deficiency would not have adversely impacted the emergency preparedness cornerstone objective, and thus would be of minor safety significance because the on-shift staff would be capable of responding to the most significant emergency situations for at least 120 minutes without additional support from the ERO. The inspectors also determined that Minor Example 4.h in IMC 0612, Appendix E, was similar to these circumstances.
As such, it was determined that the VLSSIR process best applies in this situation, and that the NRC intends to discontinue any further inspection effort on this issue in that:
- (1) The licensee believed, and continues to believe, that they received appropriate NRC approval for the 60- and 120-minute augmentation staffing change based on the January 1994 letter received from NRC Region V which stated the change was approved. Yet the 60/120 -minute augmentation staffing change may not be within the PVNGS licensing basis since the validity of the 1994 approval is in question.
- (2) The inspectors found evidence in NRC records that there was coordination, evaluation, and communication between NRR and NRC Region V in 1993-1994 regarding the change requested by PVNGS. But no additional evidence has been uncovered to clarify why a formal license amendment and SER were not issued by NRR approving the change, rather than the letter issued by Region V. As such the lack of evidence precludes the inspectors from concluding that the 60- and 120-minute augmentation change is formally within the PVNGS licensing basis.
- (3) The inspectors reviewed and concluded that the licensees current On-Shift Staffing Analyses demonstrate that the on-shift staffing is sufficient to combat the most significant emergency events for the first 120 minutes without any augmenting ERO staff. As such, if this issue were assumed to be an ROP performance deficiency, the issue would have minimal safety significance (i.e., minor).
- (4) Finally, the Chief for the Region IV Response Coordination Branch concurs that spending additional resources researching the current licensing basis is not likely to benefit public health and safety relative to other inspection activities.
Technical Assistance Request: No Technical Assistance Request was processed in support of this issue. However, Region IV staff informally discussed the issue identified with staff from the Office of Nuclear Security and Incident Response (NSIR), since that office now provides the policy and inspection support for emergency preparedness topics.
Corrective Action Reference: CR 2021-06384
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 3, 2021, the inspectors presented the Unit 3 inservice inspection results to Mrs.
M. Lacal, Executive Vice President / Chief Nuclear Officer, and other members of the licensee staff.
On May 21, 2021, the inspectors presented the emergency preparedness exercise and emergency plan change review inspection results to Mrs. M. Lacal, Executive Vice President / Chief Nuclear Officer, and other members of the licensee staff.
On July 20, 2021, the inspectors presented the integrated inspection results to Mr. T. Horton, Senior Vice President, Site Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
20-14199, 20-11736, 20-10952, 20-10239, 20-09201,
20-09199, 20-09138
Procedures
Procedures
Essential Spray Pond (SP) Train A
Procedures
Essential Spray Pond (SP) B
Procedures
Hot Weather Protection
Work Orders
WO 26356, 5226297
Corrective Action
Documents
Condition Reports
21-00971
Drawings
2-M-SIP-001
P&I Diagram Safety Injection and Shutdown Cooling System
Drawings
2-M-SIP-002
P&I Diagram Safety Injection and Shutdown Cooling System
Drawings
03-M-AFP-001
P&I Diagram Auxiliary-Feedwater System
Drawings
03-M-CTP-001
P&I Diagram Condensate Storage and Transfer System
Procedures
Essential Auxiliary Feedwater System
Procedures
Auxiliary Feedwater Pump AFN-P01 Monthly Valve
Alignment
Procedures
Auxiliary Feedwater Pump AFA-P01 Monthly Valve
Alignment
Procedures
Auxiliary Feedwater Pump AFB-P01 Monthly Valve
Alignment
Corrective Action
Documents
Condition Reports
21-07293, 21-07242, 5353217
Miscellaneous
PVGS Pre-Fire Strategies Manual
Miscellaneous
Control of Doors, Hatches and Plugs
Miscellaneous
USAR Section 9B
Fire Hazards Analysis
Corrective Action
Documents
Condition Reports
19-05981, 19-06854
Miscellaneous
4th Inspection Interval, Inservice Inspection Program,
Summary Manual, PVNGS Unit 3
Procedures
Welding and Brazing Control
Procedures
Weld Filler Material Control
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Procedures
Ultrasonic Examination of Welds in Ferritic Components
Procedures
Visual Examination of Welds, Bolting, and Components
Procedures
Visual Examination of Component Supports
Procedures
Visual Examination for Leakage
Procedures
PDI-UT-1
PDI Generic Procedure for the Ultrasonic Examination of
Ferritic Pipe Welds
09/12/2017
Procedures
PDI-UT-2
PDI Generic Procedure for the Ultrasonic Examination of
Austenitic Pipe Welds
03/11/2020
Work Orders
WO 5172050, 5201703, 5207594, 5216108, 5216109, 5216114
Corrective Action
Documents
Condition Reports
21-06711, 21-02209
Miscellaneous
S-16-0086
50.59SCREEN for Start-up and Main Transformer Lead
Differential Protection Upgrade
Miscellaneous
Unit 1, 2, 3 Night
Orders
Interim Action for 36ST-9SB04 PPS Functional test
PPS/ESFAS
05/26/2021
Procedures
Online Integrated Risk
Procedures
PPS Functional Test - RPS/ESFAS Logic
Procedures
PPS Functional Test - RPS/ESFAS Logic
Procedures
Switchyard Administrative Control
Work Orders
WO 21750, 5225975, 5319663, 4728616
Corrective Action
Documents
Condition Reports
21-04795, 21-05929, 21-06191, 21-04795, 21-05730
Miscellaneous
Updated Final Safety Analysis Report
20C
Miscellaneous
Technical Specification Bases
Miscellaneous
Unit 1 Operator Logs
05/09/2021
Miscellaneous
21-04795-002
Engineering Evaluation
Procedures
PPS Variable Over Power Setpoint Adjustment for Power
Ascension After Refueling
Procedures
PPS Variable Over Power Setpoint Adjustment for Power
Ascension After Refueling
Procedures
CEA Position Data Log
Procedures
PIDL Alarm Circuit Operability Surveillance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
DNB/LHR/AZTILT/ASI with COLSS Out of Service
Procedures
COLSS Functional Verification
Work Orders
WO 5342867, 5344685, 5344685
Calculations
EE 21-04198-010
Load Drop Analysis
Corrective Action
Documents
Condition Reports
21-04198, 21-04574
Procedures
Reactor Vessel Head Removal and Installation
Corrective Action
Documents
Condition Reports
21-05595, 21-06347, 21-05730
Procedures
Auxiliary Feedwater Pump Turbine Disassembly and
Assembly
Procedures
PPS Functional Test - RPS/ESFAS Logic
Procedures
Essential Auxiliary Feedwater System
Work Orders
WO 24968, 5207384, 5219241, 5343801
Procedures
Standard Post trip Actions
Procedures
Outage GOP
Procedures
Calculation of Estimated Critical Condition
Procedures
Determination of Anticipated Critical Condition
Procedures
Reload Power Ascension Test
Procedures
Low Power Physics Testing Using STAR
Corrective Action
Documents
Condition Reports
21-06337, 21-06377, 21-06531, 21-06550, 21-06600, 21-
06823, 21-06984
Procedures
PPS Functional Test - RPS/ESFAS Logic
Procedures
Motor Operated Valve (MOV) Testing with Quicklook
Procedures
Auxiliary Feedwater B - Inservice Test
Procedures
Containment Leakage Type B and C Testing
Procedures
CP, EW, IA, and NC Valves - Inservice Test
Procedures
Main Steam and Pressurizer Safety Valve Set Pressure
Verification
RPS Matrix Relays to Reactor Trip Response Time Test
Work Orders
WO 204611, 5206614, 5207118, 5219021, 5343901, 5343904,
21750, 5206495
Corrective Action
Condition Reports
21-02727, 21-02732, 21-02818, 21-02769, 21-02905,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
21-03107, 21-03108, 21-03109, 21-03451, 21-03736,
21-03742
Miscellaneous
Palo Verde Executive Management Debrief: NRC Evaluated
Full Scale Exercise (March 9, 2021)
04/01/2021
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
21-06384
Miscellaneous
Updated Palo Verde On-Shift Emergency Response
Organization Staffing and Capabilities Analysis (validated for
Emergency Plan License Amendment)
09/10/2019
Miscellaneous
090-05063
Palo Verde On-Shift Emergency Response Organization
Staffing and Capabilities Analysis
2/06/2012
Miscellaneous
2-08254 - CS/h
Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2,
and 3 and Independent Spent Fuel Storage Installation;
Docket Nos. 50-528, 50-529, 50-530 and 72-44; License
Nos. NPF-41, NPF-51 and NPF-74; PVNGS Emergency
Plan, Revision 69
04/09/2021
Miscellaneous
CR 2020-06418
Evaluation: Staff Augmentation During a Public Health
Emergency
07/16/2020
Miscellaneous
CR 2020-06418
Evaluation: Staff Augmentation During a Public Health
Emergency (Revision 1)
2/21/2020
Miscellaneous
Evaluation
Tracking Number:
21-001E
Revision 69 of Palo Verde Emergency Plan
03/25/2021
Miscellaneous
NCAQ Level 4
Evaluation 21-
00528-001
ORO Notification Enhancements for Follow-up Notifications
2/12/2021
Miscellaneous
Screening
Tracking Number:
21-006S
Revision 69 of Palo Verde Emergency Plan
03/04/2021
Corrective Action
Documents
Condition Reports
21-07077, 21-07089, 21-07106, 21-07152
Miscellaneous
2016 ERO Drill Report
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Emergency Preparedness Drill and Exercise Program
Management
Procedures
Steam Generator Tube Rupture
Procedures
Functional Recovery
Procedures
Notifications
Procedures
Accident Assessment
Procedures
ERO/ERF Activation and Operation
Procedures
Protective Actions
Corrective Action
Documents
Condition Reports
21-05923, 21-00656, 21-04697, 21-00225, 21-07124, 21-
05531, 21-04869, 21-03635, 21-00254, 21-00289, 21-07318,
21-03717, 19-10419, 19-18776
Procedures
Condition Reporting Process
Procedures
Operations Maintenance Activities
Procedures
Boric Acid Walkdown Leak Detection
Work Orders
WO 5341217, 5341405, 5334190, 5308579, 5339112, 5188894,
206771, 5132706, 5308579