IR 05000528/2021010

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Biennial Problem Identification and Resolution Inspection Report 05000528/2021010 and 05000529/2021010 and 05000530/2021010
ML21117A295
Person / Time
Site: Palo Verde  
Issue date: 04/28/2021
From: Ami Agrawal
Division of Reactor Safety IV
To: Lacal M
Arizona Public Service Co
References
IR 2021010
Download: ML21117A295 (13)


Text

April 28, 2021

SUBJECT:

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

BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000528/2021010 AND 05000529/2021010 AND 05000530/2021010

Dear Ms. Lacal:

On March 26, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your 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.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection.

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, Ami N. Agrawal, Team Lead Inspection Programs & Assessment Team Division of Reactor Safety

Docket Nos. 05000528 and 05000529 and 05000530 License Nos. NPF-41 and 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:

05000528/2021010, 05000529/2021010 and 05000530/2021010

Enterprise Identifier: I-2021-010-0001

Licensee:

Arizona Public Service Company

Facility:

Palo Verde Nuclear Generating Station Units 1, 2 and 3

Location:

Tonopah, AZ

Inspection Dates:

March 01, 2021 to March 26, 2021

Inspectors:

R. Azua, Senior Reactor Inspector

D. Bollock, Senior Reactor Operations Engineer

B. Correll, Reactor Inspector

P. Vossmar, Senior Project Engineer

Approved By:

Ami N. Agrawal, Team Lead

Inspection Programs & Assessment Team

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
  • Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the licensee's ultimate heat sink/spray ponds.
  • Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
  • Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Palo Verde Nuclear Generating Station developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance.

  • As part of this inspection, the team selected the plants ultimate heat sink/spray ponds for a focused review within the corrective action program. For these systems, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of these systems. However, the team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the Palo Verde Nuclear Generating Station is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process. Audits were very detailed, thorough, and identified issues.

Assessment 71152B Safety-Conscious Work Environment: The team interviewed eighteen individuals. The purpose of these interviews was

(1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a Condition Report or by another method,
(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
(3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Instrumentation and Controls organization, and the Security organization. Due to the challenges brought on by the COVID-19 pandemic, and the Palo Verde Nuclear Generating Station's performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the Palo Verde Nuclear Generating Station has an adequate Safety Conscious Work Environment.

Willingness to Raise Nuclear Safety Issues: In the assessed focus groups, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.

Overall, the team concluded that the Palo Verde Nuclear Generating Station maintained a healthy SCWE.

Employee Concerns Program: The team looked at the Palo Verde Nuclear Generating Station 's Employee Concerns Program (ECP). The team interviewed the ECP manager and discussed her cases. The team reviewed the ECPs investigative packages. Overall, the team did not identify any concerns with the program.

EXIT MEETINGS AND DEBRIEFS

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

  • On March 26, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Maria Lacal and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Calculations

13-JC-SG-0205

Uncertainty Calculation for MSIV / FWIV Air Reservoir

Pressure Channels

Corrective Action

Documents

Evaluation 20-02912-008 "U2 Reactor Trip due to Loss of

Both Main Feedwater Pumps"

Condition Reports

16-08132, 16-08153, 17-16121, 17-16133, 18-00202, 18-

00361, 18-00362, 18-00906, 18-04090, 18-02591, 18-02604,

18-02625, 18-04013, 18-04386, 18-04528, 18-04757, 18-

05850, 18-06986, 18-07057, 18-07654, 18-07701, 18-08748,

18-08082, 18-08905, 18-09037, 18-09607, 18-09754, 18-

10332, 18-10362, 18-10569, 18-10611, 18-10686, 18-10939,

18-11093, 18-11413, 18-11600, 18-11605, 18-12188, 18-

2586, 18-12595, 18-12606, 18-12710, 18-12882, 18-13094,

18-13464, 18-13597, 18-13697, 18-14201, 18-14254, 18-

278, 18-14355, 18-14363, 18-14492, 18-14563, 18-14670,

18-14765, 18-14792, 18-14811, 18-14913, 18-15062, 18-

15114, 18-15136, 18-15173, 18-15271, 18-15705, 18-15988,

18-15990, 18-16124, 18-16256, 18-16438, 18-16467, 18-

16556, 18-16698, 18-16803, 18-17013, 18-17038, 18-17577,

18-17619, 18-17740, 18-17794, 18-17834, 18-18102, 18-

18730, 18-18935, 18-19036, 19-00797, 19-01919, 19-01992,

19-02554, 19-02846, 19-02987, 19-03055, 19-03935, 19-

04074, 19-04076, 19-04087, 19-04570, 19-04980, 19-05097,

19-05320, 19-05782, 19-05839, 19-06112, 19-06401, 19-

06472, 19-07158, 19-07346, 19-07419, 19-07977, 19-08022,

19-09064, 19-09306, 19-09307, 19-09323, 19-09352, 19-

09369, 19-09395, 19-10419, 19-10681, 19-10968, 19-11630,

19-11859, 19-11892, 19-12247, 19-12283, 19-12647, 19-

2699, 19-12700, 19-13273, 19-13292, 19-14793, 19-14968,

19-16095, 19-16375, 19-16711, 19-17214, 19-17504, 19-

17515, 19-18408, 19-18545, 19-18552, 19-18566, 19-18776,

20-01013, 20-01928, 20-02092, 20-02214, 20-02567, 20-

2912, 20-03247, 20-03639, 20-03915, 20-04177, 20-04286,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20-04287, 20-04681, 20-04780, 20-04787, 20-04958, 20-

04960, 20-05251, 20-05314, 20-05452, 20-05517, 20-05802,

20-05938, 20-06557, 20-06850, 20-07241, 20-07481, 20-

07547, 20-07670, 20-07739, 20-08110, 20-08198, 20-08199,

20-08265, 20-09028, 20-09364, 20-09585, 20-09725, 20-

09924, 20-10484, 20-10494, 20-10515, 20-10641, 20-10816,

20-11174, 20-11182, 20-11409, 20-11431, 20-11551, 20-

11560, 20-11568, 20-11593, 20-11696, 20-11699, 20-11850,

20-11978, 20-12024, 20-12081, 20-12429, 20-12624, 20-

13190, 20-13770, 20-14083, 20-14169, 20-14289, 20-14754,

20-15396, 20-15470, 20-16013, 20-16123, 20-16333, 21-

00183, 21-00892, 21-01086, 21-01121, 21-02448, 21-02452,

Corrective Action

Documents

Resulting from

Inspection

NCV 2019002-01

closure

LEVEL 2 EVALUATION CR 19-06854 in response to NRC

NCV 2019002-01

NCV 2019003-01

closure

Evaluation 19-02688-007 Revision 2 "Unit 3B Diesel Fuel Oil

Transfer Pump Trip"

Rev 2

NRC FIN

2018003-01

LEVEL 3 EVALUATION REPORT 18-15727-001 and

LEVEL 2 EVALUATION CR 18-10686 in response to NRC

FIN 2018003-01

Engineering

Changes

DMWO 3560653 Diesel Fuel Oil Storage Tank Cable

Replacement (DF-1555)

EC 18-14201-010 "New knob design / installation method for

910 and 911 Series hand-switches."

18-03753-003

Raise the Setpoint for the MSIV/FWIV Control Air Reservoir

Low Pressure Alarm

Engineering

Evaluations

18-12188-007

Lack of O2 Analyzer Cells for GR System Becoming an

Issue

03/15/2020

18-18935-002

Unit 2 Polar Crane Modification Issues

20-06850-003

Contractor Injury While Moving Portable A/C Unit

Miscellaneous

Radiation Protection Event logs (2018-2020)

01/27/2021

SI Shut Down Cooling Performance Criteria Formulation

Bases

06/30/2008

SI Tanks SITs Performance Criteria Formulation Bases

06/30/2008

Spray Pond Maintenance Rule Performance Criteria Basis

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Worksheet

Station Blackout Generators Performance Criteria

Formulation Bases

03/16/2011

Spray Pond System Health Reports

01/01/2016-

01/01/2021

Main Steam Maintenance Rule Performance Criteria Basis

Worksheet

SI Containment Spray Performance Criteria Formulation

Bases

06/30/2008

SI High Pressure SI Performance Criteria Formulation Bases

06/30/2008

Instrument Air Maintenance Rule Performance Criteria Basis

Worksheet

19-02987

Maintenance Rule a(1) Issue Tracking Form - MSIVs

0, 1

February 2021

Station Quality

Issue (SQI):

Maintenance

Material Storage

Station Quality Issue (SQI): Maintenance Material Storage

February

21

NGT90C000136

Technical Conscience Principles

09/13/2019

SI Low Pressure

SI Performance

Criteria

Formulation

Bases

06/30/2008

SR-19-0037

Document review of U3R21 refueling outage work order

instructions (SG blowdown valve replacement).

10/19/2019

SR-19-0039

Observation of work associated with PB 1655 modification

for replacement of existing Class 1E 727 relays.

10/22/2019

SR-20-0032

Walkdown of Electrical Maintenance Shop (EMS) Level B

storage area

10/19/2020

Operability

Evaluations

19-03935

19-04277

19-16834

20-06195

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21-00373

Procedures

01DP-0AP50

Project Management

01DP-0XX01

Control and Monitoring of Potential Tornado Borne Missiles

Revision 6

31MT-9RC23

Reactor Coolant Pump Sulzer Bingham Seal Replacement

40DP-9ZZ04

Time Critical Action (TCA) Program

40OP-9FT01

Feedwater Pump Turbine A

40OP-9FT02

Feedwater Pump Turbine B

60DP-0QQ23

Nuclear Assurance Stop Work and Escalation Processes

70DP-0MR01

Maintenance Rule

70DP-0RA03

Probabilistic Risk Assessment Model Control

81DP-0CC28

Classification of Structures, Systems, and Components

Revision 16

81DP-0EE10

Design Change Process

AP50-55

Complexity Evaluation

EDG 01

Engineering Human Performance Tools

IP-ENG-001

Standard Design Process

Self-Assessments

Audit Plan and Report - Audit 2018-004 Training and

Qualification

Audit Plan and Report 2018-007 Radiation Safety

Audit Plan and Report 2018-007 Radiation Safety

Audit Report Audit 2020-003 Nuclear Training

18-10703

3R20 Modifications Site Self Assessment

19-0029

Design and Configuration Control Audit

19-021

Design and Configuration Control Audit

20-00078

Trending Engineering Projects Team Clock Reset Data

20-04619

Boric Acid Corrosion Control Program Simple Self

Assessment

20-04628

MRV Flow Accelerated Corrosion Self Assessment

2018-005

Maintenance and Modifications

2019-003

Engineering Programs Audit

2019-004

Fire Protection

2019-007

Design Control and Configuration Management Audit

20-004

Nuclear Fuels Audit

20-005

Maintenance and Modifications

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Work Orders

5092504

Align ACTM card cages in CEDMCS cabinets

28646

Replace 3A SP Breaker

28728

Replace 1B SP Breaker

28750

Replace 2A SP Breaker

0