IR 05000528/2023001
| ML23124A062 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/08/2023 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Heflin A Arizona Public Service Co |
| References | |
| EA-20-054 IR 2023001 | |
| Download: ML23124A062 (36) | |
Text
May 08, 2023
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INTEGRATED INSPECTION REPORT 05000528/2023001 AND 05000529/2023001 AND 05000530/2023001 AND 07200044/2023001
Dear Adam Heflin:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station. On April 18, 2023, the NRC inspectors discussed the results of this inspection with Todd Horton, Senior Vice President, Site Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. None of these findings involved a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, John L. Dixon, Jr., Chief Projects Branch D Division of Operating Reactor Safety Docket Nos. 05000528, 05000529 05000530, 07200044 License Nos. NPF-41, NPF-51, NPF-74
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000528, 05000529, 05000530, and 07200044
License Numbers:
Report Numbers:
05000528/2023001, 05000529/2023001, 05000530/2023001, and
07200044/2023001
Enterprise Identifier:
I-2023-001-0008 and I-2023-001-0076
Licensee:
Arizona Public Service Company
Facility:
Palo Verde Nuclear Generating Station
Location:
Tonopah, AZ
Inspection Dates:
January 1 to March 31, 2023
Inspectors:
L. Merker, Senior Resident Inspector
E. Lantz, Resident Inspector
N. Cuevas, Resident Inspector
S. Hedger, Senior Emergency Preparedness Inspector
L. Brookhart, Senior Spent Fuel Storage Inspector
J. Freeman, Spent Fuel Storage Inspector
C. Rosales-Cooper, Strategic Advisor for Global Engagement and
Outreach
H. Strittmatter, Emergency Preparedness Inspector
N. Brown, Resident Inspector
Approved By:
John L. Dixon, Jr., Chief
Projects Branch D
Division of Operating Reactor Safety
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 Perform Preventive Maintenance Results in Partial Loss of Offsite Power in Units 1 and 3 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000528,05000530/2023001-01 Open/Closed
[H.1] -
Resources 71153 The inspectors reviewed a self-revealed, Green, finding for the failure to perform inspections and maintenance on the Unit 2, 13.8 kV intermediate bus switchgear enclosure, 2E-NAN-S05.
Specifically, the licensees failure to perform inspections and maintenance resulted in water intrusion and a fault in the 2E-NAN-S05A cubicle causing a partial loss of offsite power to Units 1 and 3. The partial loss of offsite power to Units 1 and 3 resulted in the valid actuation and loading of the Unit 1 emergency diesel generator B and Unit 3 emergency diesel generator A.
Failure to Follow the Design Change Process Results in Partial Loss of Offsite Power in Units and 3 Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000529,05000530/2023001-02 Open/Closed None (NPP)71153 The inspectors reviewed a self-revealed, Green, finding for the failure to follow the design change process. Specifically, the licensees failure to follow procedures during the design change process resulted in an unintended second ground being installed in the current transformer circuit of the AE-NAN-X01 startup transformer causing a partial loss of offsite power to Units 2 and 3 during a fault on an unrelated non-class load center. The partial loss of offsite power to Units 2 and 3 resulted in the valid actuation and loading of the Unit 2 emergency diesel generator A and Unit 3 emergency diesel generator B.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000528,05000530/20 22-001-00 LER 2022-001-00 for Palo Verde Nuclear Generating Station (PVNGS), Units 1 and 3, Emergency Diesel Generator Actuation on Loss of Offsite Power to Class 4.16 kV Buses 71153 Closed LER 05000529,05000530/20 22-001-00 LER 2022-001-00 for Palo Verde Nuclear Generating Station (PVNGS), Units 2 and 3, Emergency Diesel Generator Actuation on Loss of Offsite Power to Class 4.16 kV Buses 71153 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 February 28, 2023, the licensee lowered power to 72 percent power to repair leaking tubes in the low-pressure feedwater heater 3C. On March 5, 2023, the licensee began power ascension and returned to full power on March 6, 2023. On March 27, 2023, the unit began a coastdown for refueling outage 2R24 and ended the inspection period at approximately 94 percent power.
Unit 3 operated at or near full power for the duration 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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 3, essential spray pond train A following surveillance testing, on January 13, 2022
- (2) Unit 2, essential chilled water train B following maintenance, on January 26, 2023
- (3) Unit 3, emergency diesel generator train A following maintenance, on March 20, 2023
- (4) Unit 1, auxiliary feedwater train A, on March 23, 2023
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, electrical penetration room train B (channel B), fire zone 42B, on January 3, 2023
- (2) Unit 3, class 1E 125 VDC channel A, B, C, and D battery rooms, fire zones 8A, 8B, 9A, and 9B, on February 10, 2023
- (3) Unit 2, control building basement A and B train sides, fire zones 1 and 2, on February 13, 2023
- (4) Unit 2, remote shutdown rooms A and B, fire zones 10A and 10B, on February 16, 2023
- (5) Unit 3, fuel building 140-foot level, fire zone 29A, on March 28, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire department training and performance during unannounced fire drills on January 20 and 30, 2023, and March 10, 2023.
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 the Unit 2 downpower to 72 percent power in support of low-pressure feedwater heater work, on February 28, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator continued training simulator exam activities, on January 31, 2023.
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) Unit 3, emergency diesel generator train A, on March 23, 2023
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, high risk for emergent troubleshooting and repair of the emergency bearing oil pump starter cabinet after a failed pump run, on January 19, 2023
- (2) Unit 1, high risk for emergent work on main turbine control oil pump A during planned startup transformer AE-NAN-X03 outage, on February 2, 2023
- (3) Unit 3, high risk for supplementary protection system channel D response time testing, on February 2, 2023
- (4) Unit 3, high risk for emergent maintenance to replace stator cooling water pump B and motor following a sheared pump shaft, on February 24, 2023
- (5) Unit 3, high risk for planned maintenance to replace main turbine control oil pump B filter, on March 7, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, turbine-driven auxiliary feedwater pump operability determination due to failure of actuator for trip throttle valve AFA-HV-54, on January 18, 2023
- (2) Unit 3, atmospheric dump valve SGB-HV-0185 operability determination after the closed indication remained illuminated when stroking the valve open, on March 9, 2023
- (3) Units 1 and 2, emergency diesel generator engine-driven jacket water pump check valves DGB-V-714 (Unit 1) and DGB-V-417 (Unit 2) operability determinations for bolts not fully engaged, on March 22, 2023
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, permanent modification to upgrade the motor generator sets with new equipment to address component obsolescence, minimize maintenance, reduce system induced noise and harmonics, and improve overall system reliability, on March 1, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (2 Samples)
- (1) Unit 1, charging pump A post-maintenance testing following plunger and valve replacement, on February 15, 2023
- (2) Unit 3, emergency diesel generator train A post-maintenance testing following maintenance outage, on March 23, 2023
Surveillance Testing (IP Section 03.01) (5 Samples)
- (1) Unit 2, diesel fuel oil transfer pump train A testing, on January 12, 2023
- (2) Unit 2, low-pressure safety injection train B, containment spray train B, and recirculation actuation signal line alignment verification and ultrasonic testing, on January 19, 2023
- (3) Unit 2, balance of plant emergency safety features actuation system functional testing of the fuel building emergency ventilation actuation system, control room emergency filtration actuation system, and control room ventilation isolation actuation system modules, on January 25, 2023
- (4) Unit 3, emergency diesel generator train B testing, on March 14, 2023
- (5) Unit 2, containment 100-foot emergency personnel airlock inner and outer door seals leak testing following planned containment entry, on March 15, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2, essential cooling water pump B in-service testing, on January 19, 2023
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency preparedness exercise conducted on March 22, 2023. The exercise scenario simulated a small RCS leak inside containment, loss of a safety electrical bus, elevated RCS activity levels, worsening RCS leak leading to a reactor trip and safety injection, failed containment penetration into auxiliary building, failed fuel barrier indicated by containment high range radiation monitors, and ultimately a release to the environment requiring protective action recommendations.
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 submitted Emergency Action Level and Emergency Plan changes:
Emergency Plan Revision 72, effective on March 4, 2022
Emergency Plan Revision 73, effective on June 1, 2022
Emergency Plan Revision 74, effective on August 11, 2022 This evaluation does not constitute NRC approval and changes are subject to future inspection.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on January 10, 2023, (ADAMS Accession No. ML23011A299)for the exercise scheduled to occur on March 7, 2023. The inspectors discussed the preliminary scenario with Shaun Bernat, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on February 3, 2023. The inspectors' review does not constitute NRC approval of the scenario.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
- (3) Unit 3 (January 1, 2022, through December 31, 2022)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (3 Samples)
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
- (3) Unit 3 (January 1, 2022, through December 31, 2022)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (3 Samples)
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
- (3) Unit 3 (January 1, 2022, through December 31, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) January 1, 2022, through December 31, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2022, through December 31, 2022 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) January 1, 2022, through December 31, 2022
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (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 self-assessments and audits processes and assessed the licensees problem identification threshold, evaluations, and corrective actions related to these self-assessments and audits.
Overall, the inspectors determined that the licensee has adequately followed site procedures to perform self-assessments and audits.
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 05000528, 05000530/2022-001-00, Units 1 and 3, Emergency Diesel Generator Actuation on Loss of Offsite Power to Class 4.16 kV Buses (ADAMS Accession No.
ML22285A000). The inspectors reviewed the LER submittal and determined that the cause of the condition described in the LER was reasonably within the licensees ability to foresee and correct and, therefore, was reasonably preventable. A performance deficiency and finding were identified and are described in the inspection results section of this report. No violation of NRC requirements was identified.
- (2) LER 05000529, 05000530/2022-001-00, Units 2 and Unit 3, Emergency Diesel Generator Actuation on Loss of Offsite Power to Class 4.16 kV Buses (ADAMS Accession No. ML22182A500). The inspectors reviewed the LER submittal and determined that the cause of the condition described in the LER was reasonably within the licensees ability to foresee and correct and therefore was reasonably preventable. A performance deficiency and finding were identified and are described in the inspection results section of this report. No violation of NRC requirements was identified.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===92702 CONF - Enforcement Related Order Follow-Up-Only To determine that adequate corrective actions have been implemented at Palo Verde Nuclear Generating Station (PVNGS) following the issuance of Confirmatory Order EA-20-054.
Verification of causal factors, extent-of-condition, or extent-of-cause actions have been identified, that their generic implications have been addressed, and that PVNGSs programs and practices have been appropriately enhanced to prevent recurrence. As well as ascertain whether the actions taken by PVNGS addressed the commitments of the Confirmatory Order.
Enforcement Related Order Follow-Up-Only===
(1)
Confirmatory Order Follow-up (1 Sample)
Confirmatory Order Modifying License - Palo Verde Nuclear Generation Station EA-20-054 dated November 17, 2020 (ADAMS Accession No. ML20323A035),relates to apparent violations of NRC requirements as discussed in NRC Inspection Report 05000528/2020010, 05000529/2020010, 05000530/2020010, and 07200044/2020001 dated July 6, 2020 (ADAMS Accession No. ML20168A355). The apparent violations involved Arizona Public Service Companys (APS) failure to
- (1) perform a written evaluation for a change to the NAC MAGNASTOR dry cask storage system and obtain a license amendment for a change in methodology for performing tip-over calculations, and
- (2) adequately analyze the consequences of a hypothetical MAGNASTOR CC5 spent fuel cask tip-over accident on the independent spent fuel storage installation pad.
An alternative dispute resolution (ADR) mediation was conducted on September 16, 2020. The Confirmatory Order contained actions to be implemented by APS as agreed upon during ADR. These actions included commitments to conduct communications to employees, training, causal evaluations, and program changes.
As part of the ADR the NRC agreed to not pursue any further enforcement action on the apparent violations identified in the NRCs July 6, 2020, letter if all actions of the Confirmatory Order were completed satisfactorily.
.1 Corrective Actions Completed Prior to Confirmatory Order
a. Review for Corrective Actions A-F
1. Observations/Conclusions
The inspectors reviewed the Level 1 Root Cause Analysis and extent of condition review. The inspectors determined the licensees root cause analysis and extent of condition review adequately identified corrective actions, causal factors, extent-of-conditions, or extent-of-causes to identify actions that would appropriately enhance procedures, training, and programs to prevent recurrence.
.2 Communications
a. Commitment A
Within 2 months of the issuance date of the Confirmatory Order, APS will develop a communication that will include: a summary of the Independent Spent Fuel Storage Installation event that resulted in the Confirmatory Order, the root and contributing causes, the corrective actions from the root cause evaluation, and the additional corrective actions from the Confirmatory Order, and APS will submit the proposed communication to the NRC for its review.
1. Observations/Conclusions
APS submitted the required documents listed above within the required timeline. NRC Inspectors verified the contents met all requirements of Commitment A.
b. Commitment B
Within 4 months of the issuance date of the Confirmatory Order, APS will issue the Condition A communication as a stand-alone communication from the Chief Nuclear Officer to all qualified personnel in the development, review, and approval of 10 CFR 50.59/72.48 Changes, test, and experiments documents. APS will retain a copy of the communication presented and verifiable evidence of the personnel receiving the communication. APS will document the reason for any person not obtaining the communication and the additional efforts used to provide the communication.
1. Observations/Conclusions
APS issued the communication listed above within the required timeline as well as documented individuals who received the required communication.
The inspectors verified the contents met all requirements of Commitment B.
c. Commitment C
Within 6 months of the issuance date of the Confirmatory Order, APS will develop a presentation and will submit the proposed presentation to the NRC for its review.
1. Observations/Conclusions
APS created the presentation listed above and provided it to the NRC within the required timeline. The inspectors verified the contents met all requirements of Commitment C.
d. Commitment D
Within 15 months of the issuance date of the Confirmatory Order, APS will deliver the presentation to:
- (2) the NEI Used Fuel Conference, and
- (3) the NEI High Level Waste Working Group (subject to acceptance of the forum or conference organizing committee) as allowed by current COVID-19 considerations.
1. Observations/Conclusions
APS delivered the presentation listed above to the required parties within the required timeline. The inspectors verified the presentations were given to all three recipients of Commitment D.
.3 Training
a. Commitment E
Within 6 months of the issuance date of the Confirmatory Order, APS will develop a refresher training on 10 CFR 50.59/72.48 requirements and processes and will submit the proposed training to the NRC for its review.
1. Observations/Conclusions
APS developed the training listed above and provided it to the NRC within the required timeline. The inspectors identified that the refresher training adequately addressed causal factors and the content met all requirements of Commitment E.
b. Commitment F
Within 9 months of the issuance date of the Confirmatory Order, APS will provide the training to all qualified personnel in the development, review, and approval of 10 CFR 50.59/72.48 changes. APS will continue to provide the refresher training at intervals not to exceed 15 months until December 31, 2024. APS will retain a copy of the training and verifiable evidence of the personnel receiving the training. APS will document the reason for any person not obtaining the training and the additional efforts used to provide the training.
1. Observations/Conclusions
APS provided the initial training to all personnel listed above by the required timeline. The inspectors verified through training records that APS met all requirements of Commitment F to date.
.4 Reviews
a. Commitment G
Within 4 months of the issuance date of the Confirmatory Order, APS will create a challenge review board consisting of three 10 CFR 50.59 program single point of contact (SPOC) members who will review 10 CFR 72.48 screenings and evaluations prior to the change implementation until December 31, 2024. By March 31 of the calendar year following the Condition G reviews, APS will send a copy of the previous calendar reviews and a copy of any additional corrective actions developed from the reviews to the NRC.
1. Observations/Conclusions
APS created a challenge review board meeting the requirements above and communicated yearly status within the required timeline. The inspectors verified through document review that APS met all requirements of Commitment G to date.
b. Commitment H
APS will utilize a design review board to review NACs design changes with experienced qualified 10 CFR 50.59/72.48 individuals on both NAC MAGNASTOR and NAC UMS systems, applicable to APS, prior to all loading campaigns through December 31, 2024. By March 31 of the calendar year following the Condition H reviews, APS will send a copy of the previous calendar year reviews and a copy of any additional corrective actions developed from the reviews to the NRC.
1. Observations/Conclusions
APS utilized a design review board meeting the requirements above and communicated yearly status within the required timeline. The inspectors verified through document review that APS met all requirements of Commitment H to date.
.5 Training Assessment
a. Commitment I
Within 12 months of the issuance date of the Confirmatory Order, APS will perform a training needs analysis to determine what training should be provided to engineering personnel relative to software quality assurance. The training needs analysis will consider procedures and processes related to the APS software quality assurance program and aspects of the Spent Fuel Project Office Interim Staff Guidance - 21 (ISG-21), Use of Computational Modeling Software, NRCs Agencywide Documents Access and Management System (ADAMS) Accession No. ML061080669. APS will send the results of the training needs analysis and proposed training to the NRC for its review.
1. Observations/Conclusions
APS performed the training needs analysis meeting the requirements listed above and provided it to the NRC within the required timeline. The inspectors verified the contents of the training needs analysis met the requirements of Commitment I.
b. Commitment J
Within 24 months of the issuance date of the Confirmatory Order, APS will provide the training resulting from the training needs analysis discussed in Paragraph I to qualified personnel in the development, review, and approval of 10 CFR 50.59/72.48 changes.
1. Observations/Conclusions
APS provided training to the necessary personnel consisting of the aspects listed above within the required timeline. The inspectors verified the contents and training records met the requirements of Commitment J.
.6 Effectiveness Reviews
a. Commitment K
By December 31 of calendar years 2021 and 2023, APS will perform an effectiveness review of the implemented root cause evaluation corrective actions, and actions associated with the Confirmatory Order. The effectiveness review will include lessons learned from each action implementation or completion, new operating experience since issuance of the Confirmatory Order, and training feedback associated with 10 CFR 50.59/72.48 which occurred during the effectiveness review period. APS will modify its corrective actions, as needed and consistent with this Confirmatory Order, based on the results of the effectiveness review.
1. Observations/Conclusions
APS performed the effectiveness review meeting the requirements above and communicated the 2021 effectiveness review within the required timeline. The inspectors verified that APS met all requirements of Commitment K to date.
.7 Administrative Items
a. Commitment L-Q
1. Observations/Conclusions
Other Administrative Items, listed in the Confirmatory Order had been completed to date.
INSPECTION RESULTS
Failure to Perform Preventive Maintenance Results in Partial Loss of Offsite Power in Units 1 and 3 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000528,05000530/2023001-01 Open/Closed
[H.1] -
Resources 71153 The inspectors reviewed a self-revealed, Green, finding for the failure to perform inspections and maintenance on the Unit 2, 13.8 kV intermediate bus switchgear enclosure, 2E-NAN-S05. Specifically, the licensees failure to perform inspections and maintenance resulted in water intrusion and a fault in the 2E-NAN-S05A cubicle causing a partial loss of offsite power to Units 1 and 3. The partial loss of offsite power to Units 1 and 3 resulted in the valid actuation and loading of the Unit 1 emergency diesel generator B and Unit 3 emergency diesel generator A.
Description:
Offsite 525 kV AC power is supplied to each units 13.8 kV intermediate buses via a preferred and alternate secondary winding from two of the three startup transformers.
Each 13.8 kV intermediate bus provides power to one class 1E 4.16 kV bus, which provides power to one train of safety-related equipment. On a loss of offsite power, the associated trains safety-related emergency diesel generator provides power to the class 1E 4.16 kV safety bus.
On August 14, 2022, the station was experiencing heavy rainfall with high winds and gusts of up to 50 mph, when the Unit 1 and Unit 3 control rooms received indications of a loss of power to one of the two class 1E 4.16 kV buses for each unit. The licensee reported the event in Licensee Event Report (LER) 05000528, 05000530/2022-001-00.
Per the licensees cause analysis evaluation, the most probable cause of the loss of power was water intrusion into the Unit 2 13.8 kV switchgear cubicle, 2E-NAN-S05A. The water intrusion resulted in an electrical fault which tripped open the 525 kV breakers and de-energized startup transformer AE-NAN-X02. This resulted in a loss of power to the Unit 1 train B and Unit 3 train A 13.8 kV intermediate buses and consequently, a loss of power to the respective class 1E 4.16 kV safety buses. As designed, the Unit 1 emergency diesel generator B and Unit 3 emergency diesel generator A automatically started upon the undervoltage conditions and restored power to their respective class 1E 4.16 kV safety buses.
The inspectors reviewed the licensees cause analysis evaluation and determined the licensees failure to perform preventive maintenance on weatherstripping and insulating boots in 2E-NAN-S05 switchgear directly contributed to the fault. The preventive maintenance task ensures that if insulating boots are degraded, they are replaced, and it also ensures the weatherstripping is intact to prevent water intrusion.
The frequency of the preventive maintenance is based on industry standards and vendor technical document, which recommends that a regular maintenance schedule should be established to obtain best service and reliability from switchgear or bus duct. The vendor document states that the plant operating and local conditions will dictate the frequency the inspection is required. The licensee had established a preventive maintenance schedule to inspect the intermediate bus switchgear, 2E-NAN-S05, every four refueling cycles, but deferred this preventive maintenance an additional two refueling cycles due to cost and insufficient personnel availability.
Corrective Actions: Operators restored offsite power to the affected buses from the alternate sources and replaced the insulating boots and weatherstripping in the cubicle. The licensee entered the issue into the corrective action program and performed a cause evaluation.
Corrective Action References: Condition report 22-08517
Performance Assessment:
Performance Deficiency: The failure to perform preventive maintenance on the intermediate bus switchgear, 2E-NAN-S05, per the licensees preventive maintenance program was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform preventive maintenance on switchgear enclosure, 2E-NAN-S05, resulted in water intrusion and a fault that caused a partial loss of offsite power to Units 1 and 3. The partial loss of offsite power to Units 1 and 3 resulted in the valid actuation and loading of the Unit 1 emergency diesel generator B and Unit 3 emergency diesel generator A.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the Initiating Events and Mitigating Systems cornerstones were affected. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors considered that the finding involved the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g.,
seismic snubbers, flooding barriers, tornado doors) for greater than 14 days and required further screening under Exhibit 4, External Events Screening Questions. Using Exhibit 4, the inspectors considered the equipment and safety function of the offsite AC power system as unavailable, and the loss of this equipment or function by itself during the external initiating event it was intended to mitigate would degrade one or more trains of a system that supports a risk significant system or function requiring performance of a detailed risk evaluation.
A senior reactor analyst performed a detailed risk evaluation considering the impacts on both affected cornerstones. For the initiating events cornerstone impact, the analyst added a basic event to fault tree ACP-PBB-S04 that considered that a heavy rain event would result in water intrusion into the Unit 2 13.8 kV switchgear cubicle, 2E-NAN-S05A. The analyst assumed that the frequency of a heavy rain event was 2.5E-1/year based on point precipitation frequency estimates of 1 inch in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for Tonopah, Arizona, taken from the National Weather Service Hydrometeorological Design Studies Center (https://hdsc.nws.noaa.gov/hdsc/pfds/pfds_map_cont.html?bkmrk=az). This change resulted in an increase in the frequency of an event initiated by the loss of one train of an engineered safety features bus from 2.94E-3/year to 3.96E-3/year, and an increase in core damage frequency of 2.3E-7/year. The analyst then reviewed the increase in core damage frequency from the Mitigating Systems Cornerstone by reviewing the impact of the unavailability of an engineered safety features bus for Units 1 and 3. The analyst set basic event ACP-CRB-CO-S05A to TRUE to model the unavailability of transformer AE-NAN-X02 for a conservative exposure time of 1 week. This analysis estimated an increase of core damage frequency of 6.6E-8/year. Combining these two results yielded an estimate of the increase in core damage frequency of 3.0E-7/year for Units 1 and 3, characterizing the issue as having very low safety significance (Green). Dominant core damage sequences were losses of AC and DC buses mitigated by remaining offsite power availability.
These results were run on the Palo Verde SPAR model, Version 8.80, using SAPHIRE, Version 8.2.8. External events were considered in the change made for the initiating events portion of the analysis and were qualitatively estimated to be insignificant for the mitigating systems portion. The analyst noted that none of the dominant core damage frequency sequences were significant contributors to large early release frequency and therefore considered core damage frequency as the best representation of the risk impact of the finding.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, on June 18, 2021, licensee approved the deferral of preventive maintenance to postpone inspections on the Unit 2, 13.8 kV intermediate bus switchgear enclosure, 2E-NAN-S05, due to insufficient personnel availability and costs.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Follow the Design Change Process Results in Partial Loss of Offsite Power in Units 2 and 3 Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000529,05000530/2023001-02 Open/Closed None (NPP)71153 The inspectors reviewed a self-revealed, Green, finding for the failure to follow the design change process. Specifically, the licensees failure to follow procedures during the design change process resulted in an unintended second ground being installed in the current transformer circuit of the AE-NAN-X01 startup transformer causing a partial loss of offsite power to Units 2 and 3 during a fault on an unrelated non-class load center. The partial loss of offsite power to Units 2 and 3 resulted in the valid actuation and loading of the Unit 2 emergency diesel generator A and Unit 3 emergency diesel generator B.
Description:
Offsite 525 kV AC power is supplied to each units 13.8 kV intermediate buses via a preferred and alternate secondary winding from two of the three startup transformers.
Each 13.8 kV intermediate bus provides power to one class 1E 4.16 kV bus, which provides power to one train of safety-related equipment. On a loss of offsite power, the associated trains safety-related emergency diesel generator provides power to the class 1E 4.16 kV safety bus.
On May 4, 2022, the Unit 1 control room received multiple alarms indicating a loss of power of three non-class load centers, 1ENGNL02, 1ENGNL06, and 1ENGNL16. At the same time, all three units received indications of startup transformer AE-NAN-X01 tripping offline, resulting in a loss of power to one of the two class 1E 4.16 kV safety buses in Units 2 and 3.
As designed, the Unit 2 emergency diesel generator A and the Unit 3 emergency diesel generator B automatically started upon the undervoltage conditions and restored power to their respective class 1E 4.16 kV safety buses. The licensee reported the event in Licensee Event Report (LER) 05000529, 05000530/2022-001-00.
During post-event failure analysis, the licensee concluded that water intrusion into the Unit 1 non-class 480V load center, 1ENGNL02, had caused a fault on an exposed shielded wire.
This fault resulted in a ground potential gradient across the site. The AE-NAN-X01 startup transformers differential protection relays subsequently tripped due to sensing an elevated input current without an elevated output current. Further troubleshooting discovered that a modification installed in December 2018 had inadvertently introduced a second ground in the startup transformer AE-NAN-X01 current transformer circuit. The ground potential gradient from the 1ENGNL02 fault caused a voltage difference between the two grounds which was sensed by the AE-NAN-X01 startup transformer's differential protection relays to trip and de-energize the startup transformer.
The inspectors reviewed the licensees cause evaluation and noted three examples of the licensees failure to follow the stations design change process procedure, 81DP-0EE10, Design Change Process, revision 42, that directly resulted in the introduction of an unplanned ground on the current transformer circuitry:
- (1) Step C.2.1.4 discussed required walkdowns that are to be performed by the design modification engineering section leader during the development of a modification. This included a mandatory constructability walkdown of all units and a design validation walkdown to be performed prior implementation of the modification. Step C.2.1.4.4 stated that the engineering section leader discusses with the APS section leader responsible for the modification being implemented in the Containment Building or in areas that are not accessible during plant operations about the constructability and pre implementation walkdowns. These walkdowns may need to be postponed until the earliest opportunity these walkdowns can be performed. The walkdowns shall be performed prior to start of implementation. Due to the modification location being in a normally energized electrical cabinet, it was properly documented in the modification disposition that the constructability walkdown would need to be performed prior to installation. However, this note did not get included in the work instructions, resulting in the walkdowns not being performed as required in step C.2.1.4.4.
- (2) Section C.13 discussed required design testing. Step C.13.7.1 stated, in part, that the scope of the testing shall demonstrateall new or disturbed electrical connections shall be verified including overlap testing from the nearest untouched electrical connection. Contrary to this step, the design validation testing did not test the existing secondary wiring for the new slip over current transformer feeding the differential relay installed during the modification.
The licensee noted that none of the design validation testing would have caused the technicians to identify or interface with the extra unplanned ground. Additionally, step C.13.8.7 stated, in part, that standards against which the success or failure of the inspections, tests, or measurements will be judged. Account for measurement errors and uncertainties. Contrary to this step, the testing instructions provided a calculated current value to compare with the acquired reading but did not include any acceptable tolerances.
This resulted in technicians not challenging the variance in values between the phases of the in-service current readings taken during installation.
- (3) Section C.18 discussed problem resolution related to design and installation of design modifications. Step C.18.1 stated, in part, that scope or intent changes, after the modification has been approvedshall be subject to the same level of review and approval applied to the original design. During extent of condition walkdowns following the May 4, 2022, event, the licensee discovered that the same wiring discrepancy was present in startup transformer AE-NAN-X03, however startup transformer AE-NAN-X02 did not have the extra ground. The licensee deduced that during the installation of the modification on AE-NAN-X02 in February 2018, the existing shield wire causing a second ground was discovered and corrected.
Contrary to this step, no evidence could be found documenting the discovery of the existing wire or the change to the modification. Additionally, there was no evidence of a review of either the modification for startup transformer AE-NAN-X03, which had already been installed in January 2018, or startup transformer AE-NAN-X01 which was to be installed in December 2018 after the completion of the installation in startup transformer AE-NAN-X02.
The transformer differential protection upgrade design modification that inadvertently introduced a second ground into the current transformer circuit was initiated in 2016 under procedure 81DP-0EE10, Design Change Process, revision 42. In the summer of 2017, the licensee transitioned to revision 43, which completely changed the design change process to align with the common industry design process. In accordance with the procedure, since the modification was started using revision 42, it was completed using revision 42.
Corrective Actions: Operators restored offsite power to the affected buses from the alternate sources. The licensee entered the issue into the corrective action program and performed a cause evaluation. The licensee performed an extent of condition inspection and removed an extra ground from the same modification that was discovered on startup transformer AE-NAN-X03.
Corrective Action References: Condition reports 22-05012 and 22-05238
Performance Assessment:
Performance Deficiency: The failure to perform a design change on the startup transformer, AE-NAN-X01, per the licensees design change process procedure is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, from December 21, 2018, to May 4, 2022, the licensees failure to follow procedures during the design change process resulted in an unintended second ground being installed in the current transformer circuit of the AE-NAN-X01 startup transformer causing a partial loss of offsite power to Units 2 and 3 during a fault on an unrelated non-class load center on May 4, 2022. The partial loss of offsite power to Units 2 and 3 resulted in the valid actuation and loading of the Unit 2 emergency diesel generator A and Unit 3 emergency diesel generator B.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the Initiating Events and Mitigating Systems cornerstones were affected. Using Exhibit 1, Initiating Events Screening Questions, the inspectors considered that the condition resulted in an actual partial loss of the AC power support system requiring performance of a detailed risk evaluation.
A senior reactor analyst performed a detailed risk evaluation considering the impacts on both affected cornerstones. Since the extent of condition of the performance deficiency affected transformers AE-NAN-X01 and AE-NAN-X03, which are the normal offsite power supplies to both Unit 2 engineered safety features buses, the analyst focused the risk evaluation on Unit
2. For the initiating events cornerstone impact, the analyst added a basic event to fault trees
2ACP-PBB-S03 and 2ACP-PBB-S04 that modeled the design change vulnerability for the loss of transformers AE-NAN-X01 and AE-NAN-X03. The analyst assumed that the frequency of an event occurring due to the design change vulnerability was 3.0E-1/year based on the occurrence of one event while the vulnerability existed. This change resulted in an increase in the frequency of events initiated by the loss of one train of either engineered safety features buses from 2.94E-3/year to 4.2E-3/year, and an increase in core damage frequency of 5.8E-7/year. The analyst then reviewed the increase in core damage frequency from the Mitigating Systems Cornerstone by reviewing the impact of the unavailability of an engineered safety features bus for Units 2 and 3. The analyst set basic event 2ACP-CRB-CO-S05A to TRUE to model the unavailability of transformer AE-NAN-X01 for a conservative exposure time of 1 week. This analysis estimated an increase of core damage frequency of 6.6E-8/year.
Combining these two results yielded an estimate of the increase in core damage frequency of 6.5E-7/year characterizing the issue as having very low safety significance (Green).
Dominant core damage sequences were losses of AC and DC buses mitigated by remaining offsite power availability.
These results were run on the Palo Verde SPAR model, Version 8.80, using SAPHIRE, Version 8.2.8. External events were unaffected by the performance deficiency for the initiating events portion of the analysis and were qualitatively estimated to be insignificant for the mitigating systems portion. The analyst noted that none of the dominant core damage frequency sequences were significant contributors to large early release frequency and therefore considered core damage frequency as the best representation of the risk impact of the finding.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 11, 2023, the inspectors presented the PVNGS ISFSI confirmatory order follow-up inspection results to Todd Horton, Senior Vice President, Site Operations, and other members of the licensee staff.
On February 3, 2023, the inspectors presented the emergency preparedness exercise scenario review inspection results to Shaun Bernat, Manager, Emergency Preparedness, and other members of the licensee staff.
On April 11, 2023, the inspectors presented the emergency preparedness exercise and performance indicator inspection results to Adam Heflin, Executive Vice President &
Chief Nuclear Officer, and other members of the licensee staff.
On April 18, 2023, the inspectors presented the integrated inspection results to Todd 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
18-07456, 20-15054, 22-05222, 21-09097, 22-08279,
2-06789, 22-06790, 23-02667
Drawings
01-M-AFP-001
P & I Diagram Auxiliary-Feedwater System
Drawings
01-M-CTP-001
P & I Diagram Condensate Storage and Transfer
System
Drawings
03-M-DGP-001
P & I Diagram Lube Oil Diesel Generator System
Drawings
03-M-SPP-001
P & I Diagram Essential Spray Pond System
Drawings
03-M-SPP-002
P & I Diagram Essential Spray Pond System
2-M-ECP-001
P & I Diagram Essential Chilled Water System
2-M-EWP-001
P & I Diagram Essential Cooling Water System
Miscellaneous
PVNGS DBM - Essential Spray Pond System
Miscellaneous
DBM, Essential Chilled Water System
Procedures
Essential Auxiliary Feedwater System
Procedures
Procedures
Essential Spray Pond (SP) Train A
Procedures
Auxiliary Feedwater Pump AFN-P01 Monthly Valve
Alignment
Procedures
Diesel Generator A Test
Procedures
Essential Chilled Water Valve Verification
Work Orders
3304346
Calculations
13-MC-FP-0802
Fire Hazard Zones Surface Areas
Calculations
13-MC-FP-0803
Combustible Loads - Control Building
Calculations
13-MC-FP-0809
Combustible Loads - Auxiliary Building
Corrective Action
Documents
2-13120, 22-10874, 23-01297, 23-01320, 23-00952,
2-07832, FSCCR 5462472, 23-00666, 23-00674, 23-
00675, 23-00676, 23-02446
Drawings
2-E-ZPL-001
Power Block Safe Shutdown Emergency Lighting Sheet
Drawings
03-M-FPF-501
Fuel Building Isometric Fire Protection System
Fire Plans
Pre-fire Strategies Manual
Miscellaneous
Firewatch Tour Addition for Unit 3 [Fire Zone] 8B
01/24/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Unit 3 Control Building Firewatch Tour Logs from
January 23 - 30
01/30/2023
Miscellaneous
5468208
Transient Combustible Control Permit
Miscellaneous
5506459
Open Door Permit for Door J-1-14
01/24/2023
Miscellaneous
NPL41-D-1Q1C-23
Palo Verde Generating Station Fire Department C Shift
Unannounced Fire Drill Unit 1 Summary Report
2/13/2023
Miscellaneous
NPL41-D-1Q2B-23
Palo Verde Generating Station Fire Department B Shift
Back-Shift/Unannounced Fire Drill Unit 2 Summary
Report
03/09/2023
Miscellaneous
NPL41-D-1Q3A-23
Palo Verde Nuclear Fire Department A Shift
Unannounced Fire Drill Unit 2 Summary Report
03/24/2023
Procedures
Firewatch Requirements
Procedures
Fire System Impairments and Notifications
Procedures
Emergency Notification and Response
Procedures
Control of Transient Combustibles
Procedures
Halon Cylinder Liquid Level and Pressure (License and
Non-License Commitment)
Procedures
Exide Emergency Lighting System 8 Hour Fire
Protection Service Test for QDN-F02
Procedures
Appendix-R Emergency Lighting Fixture Battery
Discharge Test (Wall Mounted Types KE, KF, and KG)
Procedures
Control of Doors, Hatches and Floor Plugs
Procedures
Operational Considerations Due to Plant Fire
Procedures
PR-0904
Fire Protection
Work Orders
5383403, 5506473, 5506476
Corrective Action
Documents
23-00326, 23-00817
Miscellaneous
Specific Maneuver Plan: 457 EFPD 100 to 70%,
Miscellaneous
2301311920
Evaluation Summary Sheet - 2023 Cycle 1 Crew 012
01/31/2023
Miscellaneous
SES-0-03-Q-11
Licensed Operator Continuing Training Simulator
Evaluation Scenario
06/01/2018
Procedures
Control of Reactivity Maneuver Plans
Procedures
Power Operations
151
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Conduct of Operations
Corrective Action
Documents
23-02062, 23-01993, 23-01999, 23-02392, 23-02015
Miscellaneous
Unit 3 MSPI Unavailability Reports 3/1/2022 - 3/23/2023
03/23/2023
Miscellaneous
Unit 3 MSPI EDG System Run Demands Failures Report
3/1/2022 - 3/23/2023
03/23/2023
Miscellaneous
VTD-C628-00051
Cooper Energy Instruction Manual for KSV
Turbocharged Diesel Generating Unit for Nuclear Power
Plant Emergency Stand-by Service
Procedures
13-NS-C075
MSPI Bases Document
Procedures
Procedures
Maintenance Rule
Procedures
Performance Index Data Mitigating Systems
Cornerstone
Work Orders
5391965, 5391913, 5391914
Corrective Action
Documents
2-00530, 23-01049, 23-01478, 23-01510, 23-01557,
23-01634, 22-13005, 23-02021
Miscellaneous
Unit 2 Phoenix Risk Summary
01/18/2023 -
01/19/2023
Miscellaneous
Protected Equipment Scheme for Unit 2 EBOP OOS
01/19/2023
Miscellaneous
High Risk Activity Mitigation Summary - Work Week
2303
01/19/2023
Miscellaneous
Unit 1 Phoenix Risk Monitor-WW 2305 Schedule
Evaluation 01/30/2023-2/05/20203
2/02/2023
Miscellaneous
Protected Equipment Scheme for NAN-HS-928
2/02/2023
Miscellaneous
Unit 3 WW 2305 Schedule Evaluation (1/30/2023-
2/5/2023),
01/26/2023
Miscellaneous
High Risk Activity Mitigation Summary - Work Week
2305
2/01/2023
Miscellaneous
Site Integrated Risk Assessment Work Task 5351630-0
06/23/2021
Miscellaneous
Risk Management and Readiness Plan for Clearance
434696 - Stator Cooling Water Pump B / CEN-P01B
2/12/2023
Miscellaneous
Risk Management and Readiness Plan for WO# 5511033, Stator Cooling B Pump and Motor
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Replacement
Miscellaneous
Risk Management and Readiness Plan for 5511033-1:
De-term/Re-term Motor in Support of Mechanical Task 0
2/12/2023
Miscellaneous
Phoenix Risk Monitor - PVGS Unit 3 WW 2310
Schedule Evaluation (3/6/2023 - 3/12/2023)
03/03/2023
Miscellaneous
Risk Management and Readiness Plan for WO# 5495816, Unit 3, [Control Oil] B - Change Out Main
Fluid Filters. Inspect Components for Contamination and
Damage
Miscellaneous
Risk Management and Readiness Plan for Unit 3 B
Control Oil Pump Filter Change, WO# 5495816
Miscellaneous
Protected Equipment Scheme for CONP01B OOS
03/06/2023
Miscellaneous
Protected Equipment Scheme for CENP01B OOS
2/12/2023
Miscellaneous
TD# 294250
Clearance 434696 - CEN-P01B: Replace CEN-P01B to
Correct Identified Deficiencies
2/12/2023
Procedures
Operational Decision Making
Procedures
Online Integrated Risk
Procedures
Online Integrated Risk
Procedures
Online Integrated Risk
Procedures
Risk Challenge Meetings
Procedures
Supplementary Protection System Response Time Test
Procedures
Protected Equipment
Procedures
Equipment Deficiency Tracking
Procedures
Operations Department Online Nuclear Risk
Determination Modes 1 and 2
Procedures
Risk Management Actions
Procedures
Main Turbine Lube Oil System
Procedures
Assessment and Management of Risk When Performing
Maintenance in Modes 1 and 2
Work Orders
5505326, 5504218, 5351630, 5511033, 5495816
Calculations
13-MC-XM-0204
Thread Engagement for Partially Engaged Fasteners
Calculations
13-MC-XM-0205
Thread Engagement Evaluations for Mechanical Design
Responsibility Bolted Connections
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2-13557, 22-13554, 22-13480, 23-01503, 23-01561
Miscellaneous
Palo Verde Generating Station DBM - Main Steam
Miscellaneous
Evaluation of ADV Open Stroke Time Testing - CRAI
3796813
Miscellaneous
PVNGS DBM, Auxiliary Feedwater System
Miscellaneous
L4 Evaluation 18-00282-004
Miscellaneous
13-VTD-G153-0001-1
Gimpel Motor Operated Trip Throttle Valves
Miscellaneous
13-VTD-G153-0002
Gimpel Operating Instructions Easy Flow Body
Combined Trip Throttle Valve
Miscellaneous
DSG-ME-2.19
Design Guide for Bolted Joints
Procedures
Fastener Tightening/Preload
Procedures
Preventive Maintenance Program
Procedures
Surveillance Testing
Procedures
ADVs - Inservice Test
Procedures
Auxiliary Feedwater A - Inservice Test
Work Orders
5375058, 5373925, 5129144, 5129135
Calculations
JN1036-A00007
APS Palo Verde Motor and Generator Set Sizing
Calculation
Corrective Action
Documents
2-01752, 22-06836, 22-10602, 22-10677, 22-10764,
2-10867, 22-10912, 22-10958, 22-11560, 22-11638,
2-11920, 22-11902, 23-00661, 23-00667, 23-01400
Engineering
Changes
4542596
Engineering
Evaluations
E-21-0003
Miscellaneous
EVS-EV-021-CVER3
Strategic Modernization Program (SMP) Phase 2 MG
Set Upgrade Factory Acceptance Test Report
Miscellaneous
JN1017-A00017
[Motor Generator] Set Replacement Design Verification
Test - EC 4542596
Miscellaneous
JN1036-A00073
[Rod Drive Power Supply Motor Generator] Set
Inspection and Component Test Results
Procedures
Conduct of Modifications
Procedures
CR 50.59 and 72.48 Administrative Guideline
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
5359105, 5363803, 5363810, 5488735
Corrective Action
Documents
21-14311, 15-08425, 18-19630, 23-00869, 22-12706,
23-02011, 23-02196, 23-02244, 23-02245, 23-02262,
23-02861, 22-13479
Miscellaneous
PVNGS DBM - Essential Cooling Water System
Miscellaneous
PVNGS DBM - Safety Injection System
Miscellaneous
PVGNS DBM, Diesel generator, Class 1E Standby
Generation, Fuel Oil Storage and Transfer System
Miscellaneous
Diesel Engine Report Palo Verde Unit 3A - Tonopah, AZ
03/06/2023
Miscellaneous
2-P-SIF-202
Auxiliary Building Isometric Safety Injection System ESF
Pump Suction Lines - Train B
Miscellaneous
2-P-SIF-208
Auxiliary Bldg. Isometric Safety Injection System LPSI
and Cont. Spray Disch. - Train B
Miscellaneous
Study 13-MS-B086
Development of ECCS Suction Side Piping Arc Lengths
Associated with Calculated Max Void Volumes
Miscellaneous
VTD-I075-00014
Ingersoll-Rand Operation and Maintenance Instructions
and parts catalog for 16X23S Essential Cooling Water
Pumps
Procedures
Charging Pump Disassembly and Assembly
Procedures
FBEVAS, CREFAS, and CRVIAS 18 Month Functional
Test
Procedures
Diesel Generator Test Record
Procedures
Procedures
Procedures
Procedures
Recovery From Shutdown Cooling to Normal Operating
Lineup
21
Procedures
Diesel Generator A Test
Procedures
RAS Line Fill Check
Procedures
Train B LPSI and CS System Alignment Verification
Procedures
Ultrasonic Thickness Measurement
Procedures
Pump and Valve Inservice Testing Program
Procedures
Charging Pumps Inservice Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Containment Airlock Door Seal Leak Test
Procedures
Diesel Fuel Oil Transfer Pumps - Inservice Test
Procedures
Class 1E Diesel Generator Load Rejection, 24Hour
Rated Load and Hot Start Test Train B
Procedures
Essential cooling Water Pumps - Inservice Test
BASIS
Procedures
ADVs - Inservice Test
Procedures
IST Program Off-Line Set Pressure Verification
Work Orders
5379423, 5382994, 5381876, 538792, 538793,
5385258, 5385246, 5385239, 5398881, 5318625,
5509927, 5316853, 5391913, 5391914, 5391971,
5393072, 5398794, 5399318, 5399330, 5399020
Corrective Action
Documents
2-08393, 23-00817, 23-00326, 22-08393, 23-00817,
23-00326, 21-02480, 21-03109, 21-02824, 21-02172,
21-03108, 22-04722, 22-08184, 22-07428, 22-06065,
21-08627, 22-09138, 22-01144, 21-02741, 22-01272,
21-10590, 21-03153, 22-09034, 22-00466, 21-11052,
2-09751, 21-03458, 21-08212, 21-07648, 21-02688,
21-10672, 22-10474, 21-02732, 21-02817, 21-03736,
2-11986, 22-02729
Miscellaneous
Drill Report - 2101 Full-Scale Dress Rehearsal - ERO
WHITE Team (February 2021)
03/08/2021
Miscellaneous
Drill Report - 2102 Full-Scale Exercise - ERO WHITE
Team (March 2021)
04/23/2021
Miscellaneous
Drill Report - 2106 ERO Drill - ERO GREEN Team
(June 8th, 2021)
07/09/2021
Miscellaneous
Drill Report - 2111 ERO Drill - ERO RED Team
(November 23rd, 2021)
2/08/2022
Miscellaneous
Drill Report - 2201 ERO Dress Rehearsal Drill - ERO
Green Team (February 1st, 2022)
03/18/2022
Miscellaneous
Drill Report - 2202 Full Scale Exercise - ERO Green
Team (March 8th, 2022)
05/27/2022
Miscellaneous
Drill Report - 2203 (Jul 19th White Team) and 2204 (Aug
9th Blue Team) ERO Drill
09/08/2022
Miscellaneous
Drill Report - 2205 (Aug 30th Gold Team) and 2206 (Sep
10/12/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
6th Red Team) ERO Drill
Miscellaneous
Drill Report - 1902 Full-Scale NRC Graded Exercise -
05/15/2019
Procedures
Emergency Response Organization Position Instructions
Procedures
Assistant Emergency Operations Director - EOF
Procedures
Dose Assessment Health Physicist - EOF
Procedures
Emergency Coordinator - TSC
Procedures
OSC Manager
Procedures
Radiological Assessment Coordinator - EOF
Procedures
Repairs Coordinator - OSC
Procedures
Classifications
Procedures
Notifications
Procedures
Accident Assessment
Procedures
Protective Action Recommendations
Miscellaneous
50.54(q) Effectiveness Evaluation for Eplan Rev. 73
05/26/2022
Miscellaneous
50.54(q) Effectiveness Evaluation for Eplan Rev. 74
08/05/2022
Miscellaneous
50.54(q) Effectiveness Evaluation for HU2.1 Update
03/10/2022
Miscellaneous
License Amendment Request Submittal and Request
For Additional Information Responses Regarding Issued
License Amendment No. 213
Miscellaneous
50.54(q) Effectiveness Evaluation for Eplan Rev. 72
2/24/2022
Procedures
Emergency Plan Maintenance
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
23-00670
Miscellaneous
1902 - Full Scale Exercise, Emergency Preparedness,
March 5, 2019
01/02/2019
Miscellaneous
2-08211-CLS
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; 2021
PVNGS NRC Evaluated Exercise Manual
2/18/2020
Miscellaneous
2-08558-SB
Palo Verde Nuclear Generating Station (PVNGS) Units
01/10/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1, 2, and 3 and Independent Spent Fuel Storage
Installation; Docket Nos. 50-528, 50-528, 50-530, and
2-44; License Nos. NPF-41, NPF-51 and NPF-74; 2023
PVNGS NRC Evaluated Exercise Manual
Procedures
Classifications
Procedures
Protective Actions
71151
Corrective Action
Documents
23-00662
71151
Miscellaneous
Units 1, 2, and 3 Power History
2/07/2023
71151
Miscellaneous
Unit 2 Daily Plant Status Reports: 1/15-1/24/2022
71151
Miscellaneous
ANS Test Results and PI Data 1Q2022 - 4Q2022
71151
Miscellaneous
ERO Participation PI Tracking Data 1Q2022 - 4Q2022
71151
Miscellaneous
DEP Opportunity PI Data 1Q2022 - 4Q2022
71151
Procedures
Performance Indicator Emergency Preparedness
Cornerstone
71151
Procedures
Emergency Preparedness Equipment Testing
71151
Procedures
Prompt Notification System
71152S
Corrective Action
Documents
2-00308, 22-01722, 22-01730, 22-01757, 22-01798,
2-02184, 22-02741, 22-06447, 22-02184, 22-05653,
2-06844, 22-06860, 22-06976, 22-07102, 22-07150,
2-07248, 22-08881, 22-09630, 22-10234, 22-12947,
23-00509
71152S
Miscellaneous
PVNGS Operations Quality Assurance Program
Description (QAPD)
71152S
Miscellaneous22-005
Nuclear Assurance Department Maintenance and
Modifications Audit Report
08/19/2022
71152S
Miscellaneous22-006
Nuclear Assurance Department Corrective Action Audit
Report
09/16/2022
71152S
Procedures
Condition Reporting Process
71152S
Procedures
Condition Reporting Process Administrative Guideline
71152S
Procedures
Trend Analysis Administrative Guideline
71152S
Procedures
Self-Assessment and Benchmarking Administrative
Guideline
71152S
Procedures
Conduct of Security Training
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152S
Procedures
Time Critical Action (TCA) Program
71152S
Procedures
Internal Audits
71152S
Procedures
Internal Audits
71152S
Procedures
Motor Operated Valve (MOV) Program
71152S
Procedures
MSIVs - Inservice Test
71152S
Procedures
MSIVs - Inservice Test
46A
Corrective Action
Documents
2-08519, 22-08548, 22-08712, 22-08531, 22-08517,
2-04997, 22-05000, 22-05012, 22-05238, 22-06347
Drawings
01-E-MAF-026 SH 3
Control Wiring Diagram Main Generation System Startup
XFMR A-E-NAN-X01 Billing & Metering
Drawings
13-E003-00032
Wiring Diagram Start-Up XFMRs AE-NAN-X01,2,3,4S
Drawings
13-E003-00032
Wiring Diagram Start-Up XFMRs AE-NAN-X4S
Drawings
13-E003-00034
Connection Wiring Diagram Start-Up XFMERSs AE-
NAN-X01,02,03,04s
Drawings
13-E003-00034
Connection Wiring Diagram Start-Up XFMERs AE-NAN-
X01,02,03,04s
Miscellaneous
Preventive Maintenance Deferral Request RM-PM
5087755
Miscellaneous
Preventive Maintenance Program Basis 247479
Miscellaneous
PVNGS DBM - Offsite Power
Miscellaneous
2016-00664
AENANX01 Implementing EDC DMWO 4728616 R1 for
Transformer Leads Upgrade Electrical/I&C
Miscellaneous
2016-00665
AENANX02 Implementing EDC DMWO 4728616 R1 for
Transformer Leads Upgrade Electrical I&C
Miscellaneous
Valid Actuation of Unit 2 and Unit 3 Emergency Diesel
Generators and Unit 3 Auxiliary Feedwater Pump
05/05/2022
Miscellaneous
NO DBM
Design Basis Manual - Offsite Power
Miscellaneous
VTD-G080-0394
General Electric Instructions For Metal-Clad Switchgear
Types M26 and M36
Procedures
Conduct of Maintenance
Procedures
Start-Up Transformer Maintenance
Procedures
Inspection/Cleaning of 13.8 kV and 4.16kV Switchgear
Procedures
Engineering Preventive Maintenance Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Design Change Process
Procedures
Design Change Process
Procedures
Design Change Process
Work Orders
5466936, 4825093
2702
CONF
Calculations
SN030I-A00081
APS MAGNASTOR VCC Tip-Over Analysis
2702
CONF
Engineering
Changes
21-08156-001
Complete a Design Change Package for MAGNASTOR
Batch 2 Changes
2702
CONF
Engineering
Changes
2-00808-004
Design change for MAGNASTOR Batch 2 NCRs
2702
CONF
Engineering
Evaluations
24072001
NAC UMS-24 - PVGS SITE-SPECIFIC VCC TIP-OVER
ANALYSIS
2702
CONF
Engineering
Evaluations
20-07210-007
MAGNASTOR Tip-Over Analysis Method Different
from NAC FSAR LEVEL 1 CAQ ROOT CAUSE
ANALYSIS REPORT
2702
CONF
Engineering
Evaluations
2.48 S-20-001
Incorporate a site-specific LS-DYNA Tip-Over analysis
(NAC Calculation 30032-2010) that was performed for
Palo Verde Generating Station
2702
CONF
Engineering
Evaluations
EDC 2020-00134
APS has made the decision to implement the
MAGNASTOR dry cask storage system at Palo Verde
Generating Station (PVGS).
2702
CONF
Engineering
Evaluations
Independent Spent
Fuel Storage
Installation 72.212
Evaluation Report for
the MAGNASTOR
System
PVGS MAGNASTOR ISFSI 72.212 Evaluation Report
2702
CONF
Engineering
Evaluations
NAC 02-UMS-085
CFR 72.48 Screening from NAC
2702
CONF
Engineering
Evaluations
PV-E0373
CFR 72.48 Screening / Evaluation
2702
CONF
Engineering
Evaluations
PV-E0772
Extent of Condition Level 3 Evaluation Report 20-10023-
001
2702
Miscellaneous
50.59 SPOC
List of personnel qualified as a Single Point of Contact
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CONF
MEMBERS.pdf
Information regarding 50.59 and 72.48 reviews.
2702
CONF
Miscellaneous
5309420 -RCTSAI
Condition H - Design Review Board and Comments
2702
CONF
Miscellaneous
AI 20-15366-014
Perform an Effectiveness Review (2021) for Condition K
of the Confirmatory Order
2702
CONF
Miscellaneous
CONFIRMATORY
ORDER CONDITION
C FINAL
PRESENTATION.PDF
PVGS MAGNASTOR Tip-Over Analysis
Apparent Violation Experience Sharing
2702
CONF
Miscellaneous
Lesson Plan #:
NGS03X000110
Approved Lesson Plan for NGS03 - 10 CFR 50.59/72.48
Requalification Training
2702
CONF
Miscellaneous
LESSON PLAN FOR
NGS03 REV 9.pdf
CFR 50.59/72.48 Requalification Training
2702
CONF
Miscellaneous
LESSON PLAN FOR
NGS59
Engineering Training (Program) - Classroom Lesson
2702
CONF
Miscellaneous
NAC-MAGNASTOR
STORAGE CASK
Modular Advanced Generation Nuclear All-purpose
Storage Final Safety Analysis Report
2702
CONF
Miscellaneous
NGS79-B-001-01
NGS79: Confirmatory Order Briefing - 10 CFR 50.59/72.48 Workers
2702
CONF
Miscellaneous
PV Report ID 646
List of individuals who completed NGS79
03/17/2021
2702
CONF
Miscellaneous
PV Report ID 652
List of qualified 50.59 and 72.48 individuals.
03/17/2021
2702
CONF
Miscellaneous
PV-E0233
Needs Analysis Worksheet - Tracking number 20-15369-
007. Determine if NGS03 should be revised to fulfill NRC
Confirmatory Order EA-20-054.
2702
CONF
Miscellaneous
PV-E2419
CFR 72.48 Challenge Review Board (Confirmatory
Order EA-20-054, Condition G)
2702
CONF
Procedures
MAGNASTOR Cask Loading Operations
10A
2702
CONF
Procedures
CFR 50.59 and 72.48 Screenings and Evaluations
2702
Procedures
Regulatory Commitment Tracking
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CONF