IR 05000528/2024001
| ML24120A140 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/02/2024 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Heflin A Arizona Public Service Co |
| References | |
| EA-20-054, EA-24-025 IR 2024001 | |
| Download: ML24120A140 (42) | |
Text
May 02, 2024
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION-INTEGRATED INSPECTION REPORT 05000528/2024001, 05000529/2024001, 05000530/2024001, 07200044/2024001, AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Adam Heflin:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station. On April 5, 2024, the NRC inspectors discussed the results of this inspection with Todd Horton, Senior Vice President, Nuclear Regulatory &
Oversight, 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. Two of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
The licensee identified a violation of 10 CFR 72.212(b)(6), associated with tornado hazard protection. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 22-001, Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations, and because the licensee was implementing compensatory measures and has taken or plans to take the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued Independent Spent Fuel Storage Installation handling operations. If you contest the violations or the significance or severity of the violations 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.
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 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:
05000528/2024001, 05000529/2024001, 05000530/2024001 and
07200044/2024001
Enterprise Identifier:
I-2024-001-0009 and I-2024-001-0017
Licensee:
Arizona Public Service
Facility:
Palo Verde Nuclear Generating Station
Location:
Tonopah, AZ
Inspection Dates:
January 1, 2024 to March 31, 2024
Inspectors:
L. Merker, Senior Resident Inspector
E. Lantz, Resident Inspector
N. Cuevas, Resident Inspector
L. Brookhart, Senior Spent Fuel Storage Inspector
S. Hedger, Senior Emergency Preparedness Inspector
J. Freeman, Spent Fuel Storage Inspector
Approved By:
John L. Dixon, Jr., Chief
Reactor 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 (PVNGS), 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 Adequately Monitor for Hydrogen Concentrations during Dry Cask Storage Welding Operations Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000528,05000529,05000530/2024001-01 Open/Closed Not Applicable 60855 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 72.212(b)(3) for the licensee's failure to conform to Condition 1 of the Certificate of Compliance by failing to monitor for hydrogen concentrations during welding operations as required in chapter 9 of the Final Safety Analysis Report.
Failure to Maintain Design Control of Accident Analyses Due to Modification Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000528/2024001-02 Open/Closed
[H.11] -
Challenge the Unknown 71111.18 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, when the licensee failed to apply design control measures to the reactor physics and accident analyses. Specifically, a modification was implemented which changed an input to the safety analyses involving the reactor coolant pump rotor seizure with loss of offsite power event and resulted in a lower calculated minimum departure from nucleate boiling ratio and a higher calculated percentage of fuel failure.
Failure to Perform Emergency Preparedness Review Based on Licensee Performance Indicators Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000528,05000529,05000530/2024001-03 Open/Closed
[H.11] -
Challenge the Unknown 71114.05 The inspectors identified a Green, non-cited violation of 10 CFR 50.54(t), for the licensees failure to evaluate all emergency preparedness program elements based on an assessment against performance indicators. Specifically, a 2023 audit surveillance report determined a 24-month review period was justifiable without review of a minimum emergency response facility and equipment capability performance indicator designed to measure the licensees performance in that area.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-24-025 Tornado Hazards Protection at Independent Spent Fuel Storage Installations (EGM 22-001)60855 Closed LER 05000529/2023-001-01 LER 2023-001-01 for PVNGS Unit 2 Automatic Reactor Trip on Low Steam Generator Water Level Due to Degraded Feedwater Flow 71153 Closed LER 05000529/2023-001-00 LER 2023-001-00 for PVNGS Unit 2 Automatic Reactor Trip on Low Steam Generator Water Level Due To Degraded Feedwater Flow 71153 Closed LER 05000528/2023-001-02 LER 2023-001-02 for PVNGS Unit 1 Reactor Trip Following a Main Turbine Trip 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 or near full power. On February 14, 2024, the licensee lowered power to 40 percent power to perform tube leak repairs in condenser hot well 1A. On February 17, 2024, the unit returned to full power where it remained for the remainder of the inspection period.
Unit 3 entered the inspection period at or near full power. On March 26, 2024, the unit began a coast down for refueling outage 3R24 and ended the inspection period at approximately 94 percent power.
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 2, high-pressure safety injection train A following maintenance, on January 17, 2024
- (2) Unit 1, low-pressure safety injection train A following maintenance, on January 19, 2024
- (3) Unit 1, essential spray pond train A following temporary modification installation and removal, on March 7, 2024
- (4) Unit 1, emergency diesel generator train A following maintenance, on March 13, 2024
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 1, emergency diesel generator train A room, fire zone 21A, on February 29, 2024
- (2) Unit 2, turbine-driven auxiliary feedwater pump room, fire zone 72, on March 4, 2024
- (3) Unit 2, class 1E 4kV switchgear B room, fire zone 5B, on March 19, 2024
- (4) Unit 1, class 1E 125 Vdc battery rooms, fire zones 8A, 8B, 9A, and 9B, on March 25, 2024
- (5) Units 1, 2, and 3, corridor building 120-foot elevation, on March 28, 2024
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1, emergency diesel generator train A, jacket water heat exchanger, on March 26, 2024
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 2 downpower to repair a condenser tube leak, on February 14, 2024.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 2 power ascension following repair of a condenser tube leak, on February 17, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator continued training simulator activities, on January 18, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Units 1, 2, and 3, review of the 10 CFR 50.65(a)(3) periodic evaluation, on February 22, 2024
- (2) Unit 1, emergency diesel generator train A, on March 27, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 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 3, high risk for emergent work on steam generator 2 economizer feedwater isolation valve, SGB-UV-137, on January 29, 2024
- (2) Unit 2, high risk for planned troubleshooting and replacement of power switch assembly card for subgroup 13 control element drive mechanism control system, on February 14, 2024
- (3) Unit 1, high risk for planned replacement of the main generator stator cooling water filter HI D/P alarm differential pressure cell, on February 14, 2024
- (4) Unit 2, high risk for emergent replacement of the control element drive mechanism control system subgroup 14 power switch assembly, on February 15, 2024
- (5) Unit 1, high risk for planned inspection and testing of circulating water pump D motor, on February 20, 2024
- (6) Unit 1, high risk for emergent maintenance to stop hydrogen leak on main generator hydrogen cooler A, on February 21, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, emergency diesel generator train A operability determination due to air leak on air intake manifold, on January 5, 2024
- (2) Unit 2, essential chiller train B operability determination due to refrigerant leak, on January 23, 2024
- (3) Unit 1, essential spray pond system A operability determination due to missing intake screen bolts, on March 8, 2024
- (4) Unit 2, emergency diesel generator train A operability determination due to fuel leak on main fuel header connection, on March 14, 2024
- (5) Unit 1, pressurizer operability determination due to degraded insulation matting, on March 15, 2024
- (6) Unit 3, steam generator 2 economizer feedwater isolation valve SGB-UV-137 operability determination due to hydraulic fluid leak, on March 20, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 1, permanent modification to enhance the main turbine sequential trip logic by zeroing VARs upon a turbine trip via the excitation system and providing a transfer to off-site power upon verification of main turbine stop or control valves and intercepts/intermediate stop valves are closed, on March 29, 2024
- (2) Unit 1, permanent modification to upgrade the control element drive mechanism control system with the new advanced rod control hybrid system to address component obsolescence and equipment failure issues, on March 29, 2024
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) (4 Samples)
- (1) Unit 2, emergency diesel generator train A post-maintenance testing following repair of fuel line leak, on February 12, 2024
- (2) Unit 3, steam generator 2 economizer feedwater isolation valve SGB-UV-137 post-maintenance testing following accumulator leak repair, on February 23, 2024
- (3) Unit 2, plant protection system channel B post-maintenance testing following replacement of current to voltage converter, on March 14, 2024
- (4) Unit 1, emergency diesel generator train A post-maintenance testing following maintenance outage, on March 27, 2024
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) Unit 1, high-pressure safety injection pump B time response testing, on January 22, 2024
- (2) Unit 3, class 1E 125 Vdc battery charger train A testing, on January 22, 2024
- (3) Unit 2, motor-driven auxiliary feedwater pump train B in-service testing, on March 4, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 1, essential spray pond train A in-service testing, on March 12, 2024
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between March 15, 2022, and March 9, 2024.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between March 15, 2022, and March 9, 2024. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.
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.
- Palo Verde Nuclear Generating Station Emergency Plan, revision 75 In addition, the inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between March 15, 2022, and March 9, 2024. The evaluation reviewed screenings and evaluations documenting implementation of the process.
The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between March 15, 2022, and March 9, 2024. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises; licensee audits and assessments; and the maintenance of equipment important to emergency preparedness.
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, 2023 through December 31, 2023)
- (2) Unit 2 (January 1, 2023 through December 31, 2023)
- (3) Unit 3 (January 1, 2023 through December 31, 2023)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (3 Samples)
- (1) Unit 1 (January 1, 2023 through December 31, 2023)
- (2) Unit 2 (January 1, 2023 through December 31, 2023)
- (3) Unit 3 (January 1, 2023 through December 31, 2023)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (3 Samples)
- (1) Unit 1 (January 1, 2023 through December 31, 2023)
- (2) Unit 2 (January 1, 2023 through December 31, 2023)
- (3) Unit 3 (January 1, 2023 through December 31, 2023)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) January 1, 2023 through December 31, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2023 through December 31, 2023 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) January 1, 2023 through December 31, 2023
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 ability to identify issues regarding operator staffing, evaluate each occurrence, and implement corrective actions. The inspectors determined evidence of an emerging trend in this area, verified the licensee was aware of this trend, and documented one observation and minor violation.
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 05000529/2023-001-00 and LER 05000529/2023-001-01, Unit 2 Automatic Reactor Trip on Low Steam Generator Water Level Due to Degraded Feedwater Flow, Agencywide Documents Access, and Management System (ADAMS)
Accession Nos. ML23213A189 and ML23313A162. The inspectors reviewed the original and updated LER submittals and determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foresee and correct and therefore was not reasonably preventable. No performance deficiency or violation of NRC requirements was identified.
- (2) LER 05000528/2023-001-02, Unit 1 Reactor Trip Following a Main Turbine Trip (ML24026A298). The inspectors reviewed the updated LER submittal. The previous LER submittals were reviewed in Inspection Report 05000528/2023004,
===05000529/2023004, and 05000530/2023004 (ML24039A131). The inspectors 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 as documented in FIN 05000528/2023004-05. A separate performance deficiency and violation of NRC requirements was identified during review of a modification implemented as a corrective action to preclude repetition associated with this event and are described in the inspection results section (Report Section 71111.18) of this report.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation Of An ISFSI The inspectors performed a review of the licensees Independent Spent Fuel Storage Installation (ISFSI) activities to verify compliance with requirements of the systems in use at the site. The systems include: the NAC UMS Certificate of Compliance (CoC) 72-1015, License Amendment 5 and the Final Safety Analysis Report (FSAR), revision 11, and the NAC MAGNASTOR CoC 72-1031, License Amendment 7 and FSAR revision 11. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with each certificates' technical specifications and requirements in the FSAR and NRC regulations.
Operation Of An ISFSI===
- (1) The inspectors evaluated the licensees dry cask storage operations from January 29 to February 1, 2024, during an on-site inspection. The PVNGS ISFSI is located outside the 10 CFR Part 50 protected area in its own protected area. The PVNGS ISFSI pad consists of 12 concrete pads designed to hold a total of 336 Transportable Storage Canisters (TSCs), each with 24 or 37 spent fuel assemblies. Currently the licensee had 152 UMS casks, each capable of containing one TSC containing 24 assemblies and 26 MAGNASTOR casks, each capable of receiving one TSC containing 37 assemblies. During the licensees loading campaign, PVNGS planned on loading 3 TSCs onto the ISFSI pad.
During the on-site inspection, the inspectors evaluated and observed the following activities:
- fuel selection and spent fuel placement into the TSC for canister 178
- drain down of the cask wash pit to allow for canister processing
- hydrostatic pressure testing of the TSC
- canister vacuum drying and helium backfill of the TSC The inspectors reviewed and evaluated the following documentation during the inspection:
- fuel selection evaluations for the canisters loaded since the last NRC ISFSI inspection (canisters 154-178)
- radiation surveys for radiological dose at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for 2020 through 2023
- selected ISFSI-related condition reports issued since the last NRC ISFSI inspection
- quality assurance program implementation, including recent audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations
- compliance to technical specifications for operational surveillance activities and FSAR required maintenance activities
- documentation of annual maintenance activities for the sites cask handling crane, canister hoist system, and special lifting devices
- reviewed selected licensee design changes and program changes for the ISFSI performed under the sites 10 CFR 72.48 program
- reviewed changes made by the licensee in the site's 10 CFR Part 72.212 Evaluation report
===92702 CONF - Enforcement Related Order Follow-Up-Only A review was completed to determine if adequate corrective actions had been implemented at PVNGS following the issuance of Confirmatory Order EA-20-054. A verification of the licensee's identified causal factors, extent-of-condition, and extent-of-cause actions was completed and that their generic implications had been addressed such that PVNGSs programs and practices had been appropriately enhanced to prevent recurrence. Inspectors determined whether the actions taken by PVNGS addressed the conditions of the confirmatory order.
Enforcement Related Order Follow-Up-Only===
- (1) Confirmatory Order Modifying License - PVNGS EA-20-054 dated November 17, 2020, (ML20323A035), relates to apparent violations of NRC requirements as discussed in NRC inspection reports 05000528/2020010, 05000529/2020010, 05000530/2020010, and 07200044/2020001, dated July 6, 2020, (ML20168A355). The apparent violations involved Arizona Public Services (APSs)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 ISFSI 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 conditions 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.
A follow-up inspection to confirmatory order EA-20-054 was conducted in January 2023 and documented in NRC inspection report 05000528/2023001, 05000529/2023001, 05000530/2023001 and 07200044/2023001, dated May 8, 2023, (ML23124A062). That report documented the review and completion of corrective actions A-F, and conditions A-E, I, and J.
During this inspection, the inspectors reviewed all remaining conditions that were on-going. The requirements of condition K had been fully met by the licensee during this inspection period and is documented below. The conditions F, G, H, and administrative items L-Q that are still open and on-going were also reviewed and discussed below.
.3 Training
a. Condition 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.
- 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 condition F to date.
.4 Reviews
a. Condition 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 each calendar year following the condition G reviews, APS will send a copy of the previous years 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 condition G to date.
b. Condition 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, 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 year's 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 which met the requirements above and communicated yearly status within the required timeline. The inspectors verified through document review that APS met all requirements of condition H to date.
.6 Effectiveness Review
a. Condition 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. By March 31 of each calendar year following the condition K reviews, APS will send a copy of the previous year's reviews and a copy of any additional corrective actions developed from the reviews to the NRC.
1. Observations/Conclusions
- APS performed the effectiveness review meeting the requirements above and communicated the 2021 and 2023 effectiveness review within the required timeline. The inspectors verified that APS met all requirements of condition K.
.7 Administrative Items
a. Conditions L-Q
1. Observations/Conclusions
- Other Administrative Items, listed in the confirmatory order had been completed to date.
INSPECTION RESULTS
Failure to Adequately Monitor for Hydrogen Concentrations during Dry Cask Storage Welding Operations Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000528, 05000529,05000530/2024001-01 Open/Closed Not Applicable 60855 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 72.212(b)(3) for the licensees failure to conform to Condition 1 of the Certificate of Compliance by failing to monitor for hydrogen concentrations during welding operations as required in chapter 9 of the Final Safety Analysis Report.
Description:
In 2020, PVNGS switched dry cask storage systems to utilize the NAC MAGNASTOR system. As part of this change, the licensee purchased new equipment to perform canister processing operations, such as, hydrogen monitoring, water removal, drying, and helium backfilling operations. The system purchased to perform these options was called the EMS Solutions E1000 Canister Processing System (CPS). The CPS system was equipped with a hydrogen monitor to monitor for hydrogen levels during canister welding operations. The specific hydrogen monitor used by PVGNS was a PureAire ST-46 LEL combustible gas monitor. The monitor samples the environment using a line that is attached to the vent port of the Transportable Storage Canister (TSC) closure lid.
After the TSC is filled with spent nuclear fuel, the closure lid of the canister is placed on the shell and approximately 70 gallons of borated spent fuel pool water is drained from the TSC. This voided area is required so that the closure lid-to-shell weld area stays dry to allow welding. The voided area, under the lid and inside the canister, is then backfilled with argon through the TSC drain port on the top of the closure lid. This argon is used to provide a backing gas for welding operations and to facilitate removal of any possible hydrogen gas out of the canister. Hydrogen generation is possible due to the interaction of the spent nuclear fuel with the borated spent fuel pool water and the canister's basket material. Monitoring for hydrogen gas is important to prevent a hydrogen deflagration event during the welding operations.
The NAC MAGNASTOR FSAR, chapter 9, section 9.1.1.42 requires sampling the gas volume below the closure lid to observe for hydrogen concentrations prior to commencing closure lid welding operations until the root pass of the closure lid-to-shell is complete. Welding operations must immediately stop if hydrogen concentration exceeds 2.4 percent.
During the onsite inspection, the inspectors reviewed the calibration and the manufacturers specifications related to the licensees PureAire ST-46 LEL hydrogen monitoring device.
From this review the inspectors identified that the hydrogen monitor was a catalytic monitor that requires oxygen to be present inside the line from the vent port on the closure lid to function properly. This style of catalytic monitor is not designed to get oxygen from the surrounding environment. During welding operations when argon is fed into the TSC via the drain port, the argon gas potentially displaces all hydrogen and oxygen from the canister. The vent port line from the TSC that supplies the hydrogen monitor may contain all argon gas and have very little to zero oxygen in the line. This hydrogen monitor is not designed to detect hydrogen in this inert argon atmosphere and is therefore incapable of performing its design function of detecting hydrogen concentrations.
Corrective Actions: The licensee entered the issue into the CAP and placed restrictions on the use of the PureAire ST-46 LEL hydrogen detector during canister welding operations.
PVNGS reached out the welding vendor to procure a different hydrogen monitor that could detect hydrogen in an inert atmosphere for the current loading campaign. The licensee took other actions to notify other general licensees that may be susceptible to the same issue and actions to find an adequate replacement hydrogen monitor for their CPS system.
Corrective Action References: CR 24-01017
Performance Assessment:
None. The Reactor Oversight Process (ROP) does not specifically consider violations of 10 CFR Part 72 in its assessment of licensee performance. The inspectors determined that the violation was of more than minor safety significance, since if left uncorrected, the deficiency could lead to a more significant safety concern.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The ROP's significance determination process does not address 10 CFR Part 72 violations; therefore, it is necessary to address this violation using traditional enforcement. This violation was dispositioned per the traditional enforcement process using section 2.3 of the NRCs Enforcement Policy.
Traditional enforcement violations are not assessed for cross-cutting aspects.
Severity: Consistent with guidance in the NRC Enforcement Manual, part 1, section 1.2.6.D, if a violation does not fit an example in the Enforcement Policy violation examples, it should be assigned a severity level:
- (1) commensurate with its safety significance; and
- (2) informed by similar violation addressed in the violation examples. The inspectors determined that the violation was similar to section 6.5.d.2 of the NRC Enforcement Policy as a Severity Level IV violation. The violation was of very low safety significance because no hydrogen deflagration event occurred during the past canister welding operations and subsequent welding operations showed hydrogen levels to be low.
Violation: Title 10 of the Code of Federal Regulations (10 CFR) 72.212(b)(3) states, in part, that the general licensee must ensure that each cask used by general licensee conforms to the terms, conditions, and specifications of a Certificate of Compliance.
Certificate of Compliance 72-1031, NAC International MAGNASTOR System, Amendment 7, Condition 1 states, in part, written operating procedures shall be prepared for cask loading. The users site-specific written procedures shall be consistent with the technical basis described in chapter 9 of the FSAR.
The NAC MAGNASTOR FSAR, chapter 9, section 9.1.1.42 requires, in part, that sampling the gas volume below the closure lid to observe for hydrogen concentrations prior to commencing closure lid welding operations until the root pass of the closure lid-to-shell is complete.
Contrary to the above, from March 3, 2020, to January 31, 2024, the licensee failed to sample the gas volume below the closure lid to observe for hydrogen concentrations prior to commencing closure lid welding operations until the root pass of the closure lid-to-shell is complete. Specifically, the licensee used a monitor design that was incapable of sampling the volume below the closure lid for hydrogen concentrations during closure lid welding operations consistent with the technical basis described in chapter 9 of the FSAR.
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-24-025: Tornado Hazards Protection at Independent Spent Fuel Storage Installations (EGM 22-001)60855
Description:
Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM)22-001, Enforcement Discretion for Noncompliance of Tornado Hazards Protection Requirements at ISFSIs (ML22087A496), dated April 15, 2022, and subsequent revision 1 (ML23061A183), dated March 3, 2023, the licensee performed an assessment of all outdoor dry cask storage activities that were not explicitly analyzed for tornado hazards in the systems FSAR. Two configurations were identified by the licensee where transport activities did not have a related tornado wind and hazard analysis consistent with the casks design basis requirements. These two configurations occur when the loaded canister is being lowered from the transfer cask into the concrete cask inside the auxiliary building and when the loaded canister is inside the concrete cask on the rail car.
The NAC MAGNASTOR FSAR, chapter 2, which includes Section 2.3 Design Criteria for Environmental Conditions and Natural Phenomena, describes the general design criteria for the cask system. Specifically, FSAR Section A.2.3 states, This section presents the design criteria for site environmental conditions and natural phenomena applied in the design basis analyses of MAGNASTOR. Analyses to demonstrate that the design basis system meets the design criteria defined in this section are presented in the appropriate chapters. Tornado hazards are evaluated in the FSAR Section 2.3.1 Tornado Missiles and Wind Loadings, Section 2.3.1.1 Applicable Design Parameters, Section 2.3.1.2 Determination of Forces on Structures, and Section 2.3.1.3 Tornado Missiles. These sections of the FSAR do not include an analysis for tornado hazards when
- (1) the loaded canister is being lowered from the transfer cask into the concrete cask and
- (2) the loaded canister is inside the concrete cask on the rail car.
Corrective Actions: The licensee followed the guidance actions as described in the EGM. The issue was entered into the corrective action program (CAP) and the licensee established additional measures to mitigate tornado hazards, through procedures, during periods of ISFSI handling operations. These actions included, restricting outdoor dry cask storage activities during periods of adverse weather, establishing meteorological criteria, designating staff to monitor weather during ISFSI handling operations, describing actions to take in the event of severe weather necessary to place the cask in an analyzed condition, minimizing the duration of ISFSI handling operations during which ISFSI important to safety structures, systems, and components (SSCs) are in an unanalyzed condition, documentation that required weather checks were completed prior to the start of ISFSI handling operations, and documenting in the CAP a request for the Certificate of Compliance (CoC) holder to request an amendment within six months of the date of the EGM or implement physical design modifications and/or perform evaluations that demonstrate important to safety SSCs are designed to withstand the effects of natural phenomena, including tornadoes and tornado-generated missiles prior to the expiration date of the EGM (April 15, 2024).
Corrective Action References: CR 22-04574
Enforcement:
Significance/Severity: This violation was dispositioned in accordance with the traditional enforcement process using section 2.3 of the NRCs Enforcement Policy. This issue was determined by inspectors to be of more than minor safety significance, since if left uncorrected, the deficiency could lead to a more significant safety concern. Consistent with the guidance in section 1.2.6.D of the NRCs Enforcement Manual, if a violation does not fit an example in the enforcement policy violation examples, it should be assigned a severity level:
- (1) commensurate with its safety significance; and
- (2) informed by similar violations addressed in the violation examples. The violation was evaluated to be similar to a Severity Level IV violation in Enforcement Policy Section 6.5.d.2.
Violation: Title 10 CFR 72.212(b)(6), states, in part, that the general licensee must review the Safety Analysis Report referenced in the CoC or amended CoC and the related NRC Safety Evaluation Report, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports.
Contrary to the above, from January 22 to February 9, 2024, the licensee failed to determine whether or not reactor site parameters including analyses of tornado missiles were enveloped by the cask design bases. Specifically, the licensee failed to perform an analysis consistent with FSAR Section 2.3 to demonstrate the MAGNASTOR cask system ensures that exposure to credible site hazards does not impair their safety functions, such as, when
- (1) the loaded canister is being lowered from the transfer cask into the concrete cask and
- (2) the loaded canister is inside the concrete cask on the rail car as being potentially susceptible to a tornado missile.
Basis for Discretion: In general, the NRC has extensive history analyzing severe weather events including tornado hazard scenarios using probabilistic methods (or risk assessments)in licensing on a case-by-case basis to assess specific plant features to prevent a release of radioactivity exceeding regulatory limits. For ISFSIs, such methods can be employed, supported by analysis, to demonstrate that tornado hazards will not impair the capability of SSCs important to safety to perform their intended design functions.
The Office of Nuclear Reactor Regulation (NRR) completed a generic risk analysis of potential tornado missile protection non-compliances to examine the risk significance of tornado hazard scenarios (ML14114A556). In this case, the generic bounding risk analysis performed by NRR concluded that a tornado missile scenario is of low-risk significance at power reactor sites due in part to the low probability of wind speeds exceeding 75 miles per hour (less than 4x10-4 per year). This generic analysis did not specifically address ISFSI handling operations but there are several key insights in the analysis that may apply to a risk assessment for this issue. Specifically, rather than evaluate site-specific configurations, the NRR generic analysis used bounding assumptions regarding tornado and high winds initiating event frequencies (IEFs) coupled with bounding assumptions for missile strike area to develop conservative estimates of core-damage frequency. This generic analysis assumes that plants are in a condition vulnerable to a tornado for a full reactor-year worth of exposure time.
For ISFSI handling operations, the vulnerable configuration would be typically limited to a few weeks of exposure time per year which would result in additional conservatism to the results documented in the NRR generic analysis. Furthermore, ISFSI handling operations that may lead to loss of confinement of radioactive material due to a missile strike or high winds should be bounded by the assumptions regarding tornado and high winds IEFs. Appropriate administrative controls including compensatory measures would provide defense-in-depth and further reduce the likelihood of occurrence and mitigate loss of confinement events. This defense-in-depth approach should include provisions to
- (1) preclude ISFSI handling operations during periods of adverse weather or when adverse weather is predicted, and (2)provide compensatory measures to place important to safety SSCs in an analyzed condition or provide physical protection as necessary to maintain confinement of radioactive material during ISFSI handling operations.
In summary, the combination of the low probability of tornado events in conjunction with formally documented administrative controls that
- (1) restrict initiation of ISFSI handling operations during projected periods of adverse weather and,
- (2) cease ISFSI handling operations and place important to safety SSCs in a protected configuration or analyzed condition at the outset of adverse weather conditions, form the basis for the exercise of enforcement discretion for ISFSI handling operations. As a further condition of this enforcement discretion, licensees will conduct a site-specific assessment to determine the appropriate corrective actions to ensure that important to safety SSCs will not be adversely impacted by tornado hazards. The exercise of enforcement discretion limited to the conditions of this EGM will not impose significant additional risk to public health and safety.
Since this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 22-001, Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations, and because the licensee was implementing compensatory measures and has taken the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued ISFSI handling operations.
Failure to Maintain Design Control of Accident Analyses Due to Modification Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000528/2024001-02 Open/Closed
[H.11] -
Challenge the Unknown 71111.18 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to apply design control measures to the reactor physics and accident analyses. Specifically, a modification was implemented which changed an input to the safety analyses involving the reactor coolant pump rotor seizure with loss of offsite power event and resulted in a lower calculated minimum departure from nucleate boiling ratio and a higher calculated percentage of fuel failure.
Description:
On April 8, 2023, the Unit 1 control oil pump A tripped on an electrical protection ground fault, and control oil pump B automatically started. The running amps for control oil pump B indicated low, and the control oil system pressure continued to degrade. This delay in developing pressure led to a main turbine trip on low control oil header pressure. The turbine trip resulted in a reactor power cut back, but an automatic reverse power relay actuation did not occur to trip the generator switchyard output breakers. Operators manually opened the main generator switchyard output breakers per abnormal operating procedure 40AO-9ZZ08, Load Rejection, revision 35. Since the breakers were manually opened, a fast bus transfer did not occur, resulting in the de-energization of the 13.8 kV non-class buses, NAN-S01 and NAN-S02, which resulted in the loss of power to all four reactor coolant pumps and therefore a reactor trip and loss of forced circulation.
The licensee created modification MA-1866 as a corrective action to preclude repetition from the Unit 1 reactor trip. The purpose of the modification was to ensure that following a turbine trip, the transient highly reactive, i.e., VAR, condition is negated so that the primary and backup reverse power relays can identify the reverse power condition and open the generator switchyard output breakers. The design change would also provide a transfer to offsite power sources following the verification of the main turbine valves being closed to ensure that the unit does not experience a loss of forced circulation event. The licensee installed modification MA-1866 in Unit 1 from October 10 through November 14, 2023, during refueling outage
==1R24.
The inspectors noted modification MA-1866 would accomplish both tasks by repurposing a==
lockout relay to
- (1) provide input to the interposing relay in the main generator excitation system to activate the Zero VARs function by accelerating the reduction rate of reactive power and automatically disabling the line drop compensation and
- (2) upon actuation of the lockout relay, allow an immediate transfer to offsite power, if offsite power is available, following a turbine trip.
The inspectors questioned the licensee regarding the new timing of the modification. The licensee confirmed the repurposed lockout relay would allow an immediate transfer to offsite power, if offsite power is available, following a turbine trip instead of remaining connected to the main generator until the reverse power trip and pickup of the reverse power relays. The inspectors further questioned the licensee as this immediate transfer to offsite power appeared contrary to portions of the updated final safety analysis report stating a time delay in the reverse power relay is credited for a portion of the 3-second interval between a turbine trip and the loss of power to the reactor coolant pumps assumed in certain accident analyses.
Should the immediate break-before-make transfer to offsite power fail (i.e., a switchyard breaker fails to close), the reactor coolant pumps on that bus would lose power prior to three seconds, effectively bypassing the assumed 3-second delay.
During their review in response to the inspectors questions, the licensee determined the installation of modification MA-1866 placed Unit 1 in a nonconforming condition with respect to the following four updated final safety analysis report chapter 15 safety analyses:
- (1) steam generator tube rupture with a loss of offsite power and a single failure,
- (2) feedwater line break with a loss of offsite power and single failure for long term cooling,
- (3) reactor coolant pump shaft break with a loss of offsite power (sheared shaft), and
- (4) single reactor coolant pump rotor seizure with a loss of offsite power (seized rotor/locked rotor). The licensee reperformed the four affected safety analyses by removing the 3-second delay (i.e., having the loss of offsite power occur coincident with the turbine trip) and determined the impact was negligible for all affected chapter 15 safety analyses except the single reactor coolant pump rotor seizure with a loss of offsite power (seized rotor/locked rotor) event.
Prior to the modification, the reactor coolant pump shaft break with a loss of offsite power (sheared shaft) event was more limiting with a calculated minimum departure from nucleate boiling ratio of 1.07 resulting in a calculated 6.36% fuel failure. Following the modification, the single reactor coolant pump rotor seizure with a loss of offsite power (seized rotor/locked rotor) event became more limiting with a change in calculated minimum departure from nucleate boiling ratio from 1.10 to 1.00 resulting in a calculated 15.48% fuel failure. This increase in calculated fuel failure is below the updated final safety analysis report limiting fuel failure of 29.24%. The licensee revised the 10 CFR 50.59 evaluation for modification MA-1866 and concluded that no license amendment request was required.
The inspectors reviewed the condition reports, updated engineering evaluations, and 10 CFR 50.59 evaluations and concluded the documents had addressed the inspectors concerns. The inspectors also validated the licensee had appropriate corrective actions in place to update the associated calculations, updated final safety analysis sections, and modification paperwork.
Corrective Actions: The licensee reperformed the accident analyses to determine the impact of the modification. The licensee also performed new 10 CFR 50.59 evaluations that demonstrated reasonable assurance that no license amendment request was required.
Corrective Action References: Condition reports 23-03479, 23-12211, and 23-12784
Performance Assessment:
Performance Deficiency: The failure to apply design control measures to the reactor physics and accident analyses was a performance deficiency. Specifically, a modification was implemented which changed an input to the safety analyses involving the reactor coolant pump rotor seizure with loss of offsite power event.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee had to reperform the safety analyses to determine the impact of the modification, which resulted in a higher amount of calculated fuel failure.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated November 30, 2020, and determined that the Barrier Integrity cornerstone was affected.
Using Exhibit 3, Barrier Integrity Screening Questions, the finding was screened as having very low safety significance (Green) because the finding did not involve control manipulations that unintentionally added positive reactivity that challenged fuel cladding integrity (e.g.
inadvertent boron dilution, cold water injection, two or more inadvertent control rod movements, recirculation pump speed control), did not result in a mismanagement of reactivity by operator(s) that challenged fuel cladding integrity (e.g., reactor power exceeding the licensed power limit, inability to anticipate and control changes in reactivity during crew operations), did not result in the mismanagement of the foreign material exclusion or reactor coolant chemistry control program that challenged fuel cladding integrity (e.g., loose parts, material controls), and did not result from fuel handling errors, a dropped fuel assembly, a misplaced fuel bundle, or crane operations over the core or anywhere in the refueling pathway that challenged fuel cladding integrity or resulted in a release of radionuclides.
Additionally, the finding did not involve potential non-compliance with regulatory requirements for protection of the reactor pressure vessel against fracture (e.g., pressure-temperature limits or pressurized thermal shock issues) and did not involve reactor containment; the control room, auxiliary, reactor, or spent fuel pool building; or the spent fuel pool.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, when presented with conflicting information in a calculation and confusing information in several sections of the updated final safety analysis report, the licensee rationalized the calculation information rather than challenge the conflicting information in the updated safety analysis report and did not stop preparation of the modification to consult site transient analysis experts.
Enforcement:
Violation: Title 10 CFR Part 50, appendix B, criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design and that design control measures shall be applied to items such as reactor physics and accident analyses.
Contrary to the above, from November 14, 2023, through March 29, 2024, the licensee failed to apply design control measures to the reactor physics and accident analyses that provided for verifying or checking the adequacy of design. Specifically, with respect to the fast bus transfer modification, the modification was implemented which changed an input to the safety analyses involving the reactor coolant pump rotor seizure with loss of offsite power event and resulted in a lower calculated minimum departure from nucleate boiling ratio and a higher calculated percentage of fuel failure.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Perform Emergency Preparedness Review Based on Licensee Performance Indicators Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000528,05000529,05000530/2024001-03 Open/Closed
[H.11] -
Challenge the Unknown 71114.05 The inspectors identified a Green, non-cited violation of 10 CFR 50.54(t), for the licensees failure to evaluate all emergency preparedness program elements based on an assessment against performance indicators. Specifically, a 2023 audit surveillance report determined a 24-month review period was justifiable without review of a minimum emergency response facility and equipment capability performance indicator designed to measure the licensees performance in that area.
Description:
10 CFR 50.54(t) requires each reactor licensee to provide a periodic independent review of their emergency preparedness program. It requires the independent review at a default periodicity of 12 months, including adequacy reviews of the interfaces with state and local governments; and licensee drills, exercises, capabilities, and procedures.
The regulation was revised on March 29, 1999, to provide licensees the option to change the frequency of independent evaluations of their emergency preparedness programs (64 FR 14814). The amendment allowed licensees to conduct reviews at intervals not to exceed 24 months, based on an assessment of the program against performance indicators and after changes that could adversely affect the emergency preparedness program. An acceptable method to maintain compliance with this option was endorsed in Regulatory Guide 1.101, revision 6 (June 2021). NEI white paper, Implementing A 24-Month Frequency for Emergency Preparedness Program Reviews, [R. 0, ML19260G281], defines performance indicators to be used for this purpose are two pre-existing ones, and a new performance indicator. They are a) the NRC performance indicator (PI) for Drill and Exercise Performance, b) the NRC PI for ERO Participation, and c) the Emergency Response Facility and Equipment Readiness (ERFER) PI. The latter PI is described in the white paper, explaining what it is looking at, what data goes into it, and what threshold would trigger a 50.54(t) related review (details are in Attachment 1 of the document). Due to the pre-existing performance indicators not providing insight into how a licensee is maintaining emergency response facilities and equipment used for completing risk significant planning standard functions, it was designed to use in 50.54(t) audit frequency decision making.
On November 18, 2022, the licensee completed a full-scope emergency preparedness program review [Nuclear Assurance Department (NAD) Audit Report 2022-009]. Going into 2023, the licensee could have a) completed a full-scope review within 12 months, or b)extended the review to 24 months, based on review of the performance indicators. Documented in a surveillance document (NAD Report Number SR-23-0063, dated November 17, 2023), the licensee had not developed the ERFER PI for use in their evaluation process. Despite not having this minimum PI developed with data to evaluate justifying an audit date extension, the licensee decided to approve moving the review to 24 months.
The inspector asked why the review date extension was justified without having the minimum set of performance indicators available for decision making. The licensee communicated that they were attempting to resolve some internal questions dealing with how to set up and monitor the PI. Regardless of the development issues, the inspectors pointed out that there was no PI developed, so in that case, completing the standard 12-month review would have been acceptable until the issues were resolved. However, the licensee decided to make the extension without the necessary data determined to be part of the acceptable compliance method. Delaying the opportunity for independent audit staff to evaluate maintenance and health of emergency response facilities without basis (supported by performance indicators)can lead to issues in this area not being discovered and corrected in a timely manner.
Corrective Actions: The licensee entered these issues into the corrective action program.
Corrective Action References: Condition Report 24-02747
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to develop and use performance indicators assessing the quality of the emergency response facility and equipment reliability in support of a 24-month independent review frequency was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if emergency response facilities and equipment being in a non-functional state without compensatory measures is not identified, evaluated, and corrected in independent review processes.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. Using its Attachment 2 (issue date September 22, 2015); the performance deficiency was determined have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The finding had a cross-cutting aspect in the area of human performance associated with challenging the unknown because the licensee did not stop the plans for a 24-month review frequency when faced with uncertain conditions. Specifically, the licensee made a decision that the risks associated with emergency response facilities and equipment reliability were acceptable without review of the minimum necessary data to make a decision in compliance with the regulation.
Enforcement:
Violation: Title 10 CFR 50.54(t)(1) requires, in part, that the licensee shall ensure that all emergency preparedness program elements are reviewed at intervals not to exceed 12 months or, as necessary, based on an assessment against performance indicators, at least once every 24 months. Title 10 CFR 50.54(t)(2) requires, in part, the review must include an evaluation for adequacy of licensee capabilities.
Contrary to the above, from November 18, 2023, to March 22, 2024, the review for adequacy of licensee capabilities was not performed based on an assessment against performance indicators. Specifically, a 2023 audit surveillance evaluating whether to extend the review from 12 to 24 months did not make a decision on the need to review emergency response facilities and equipment capabilities based on the minimum performance indicator designed to measure the licensees performance in that area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Observation: Operations Below Minimum Staffing and Minor Violation 71152S The inspectors performed an in-depth review of the licensees ability to identify issues regarding operator staffing, evaluate each occurrence, and implement corrective actions. The inspectors determined evidence of an emerging trend in this area, verified the licensee was aware of this trend, and identified one observation and minor violation.
The inspectors reviewed 47 condition reports between December 2022 and March 2024 documenting operations staffing issues. The inspectors noted the staffing issues were distributed across the three units (15 condition reports for Unit 1, 12 condition reports for Unit 2, 19 condition reports for Unit 3, and 3 condition reports for the site, respectively) with a couple condition reports documenting multiple staffing issues. The inspectors also noted most of the operations staffing issues (27 condition reports) concerned auxiliary operators, whereas 11 condition reports concerned reactor operators, 7 condition reports concerned senior reactor operators, and 4 condition reports concerned shift technical advisors respectively. The inspectors determined the licensee adequately followed site procedures to document each operator staffing issue. However, the inspectors questioned the licensees evaluation and resolution of two operator staffing issues.
Procedure 40DP-9OP02, Conduct of Operations, revision 77, step 4.8.1.A states, in part, that the minimum required shift crew manning is one shift manager per unit. The composition of the shift crew may be one less than the minimum manning required for the above requirements for a period NOT to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to accommodate unexpected absence of on duty shift crew members. These restrictions are allowable provided immediate action is taken to restore crew manning to the minimum requirements. Step 4.8.3.A states the operations manager may direct the relief of the [shift manager] by another qualified individual.
The note before step 4.8.3.A clarifies the [shift manager] position may be filled by qualified individuals who hold active, valid [senior reactor operator] licenses. Normally these individuals are classified as [shift managers], [control room supervisor] upgraded to [shift manager] or higher management classifications.
Operations Department Practice ODP-2, Operations Shift Staffing and Scheduling Practices, revision 1, step III.A states, in part, the minimum shift coverage for a unit crew is defined as: one shift manager per crew. Step IV.A states, in part, the unit crews shall be able to cover the following staffing requirements to a single unit in the event of a transient and/or emergency condition, one shift manager. Step V.C.i states any control room supervisor that is not current in the shift managers training program is only qualified to fill the shift managers position for an unplanned absence with less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />' notice, and they must be
[emergency coordinator] qualified to meet emergency plan requirements. Step IX.C.iv.1 states, in part, if the site will be less than 3 [shift managers] write a [condition report]
annotating the procedural violation of 40DP-9OP02.
On June 15, 2023, a control room supervisor was flagged up to relieve the Unit 2 shift manager due to a medical event. The control room supervisor was emergency coordinator qualified and had a current, valid senior reactor operator licensee, but was not shift manager qualified. Another individual supporting a diesel maintenance outage was reassigned to ensure the control room supervisors position was covered for the shift.
On August 24, 2023, a shift technical advisor was flagged up to relieve the Unit 3 shift manager due to a short notice call off. The shift technical advisor was emergency coordinator qualified and control room supervisor qualified with a current, valid senior reactor operator licensee, but was not shift manager qualified. Another individual was called in to ensure the shift technical advisors position was covered for the shift.
The inspectors determined the licensee failed to follow the Conduct of Operations procedure to maintain the minimum shift complement of one qualified shift manager per unit due to following guidance in the lower-level operations department practice document. The inspectors determined this failure to follow the Conduct of Operations procedure was a performance deficiency.
The performance deficiency was minor because it could not be reasonably viewed as a precursor to a significant event; would not have the potential to lead to a more significant safety concern if left uncorrected; and while it was associated with the human performance attribute of the Mitigating Systems Cornerstone, it did not adversely affect the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to maintain the minimum shift complement of one qualified shift manager per unit was limited to two occurrences that each lasted less than a shift. The licensee has implemented actions to improve operator staffing levels.
Technical Specification 5.4.1a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, 1.k requires procedures for maintenance of minimum shift complement and call-in of personnel. Procedure 40DP-9OP02 implements the Regulatory Guide requirement and step 4.8.3.A states the operations manager may direct the relief of the [shift manager] by another qualified individual. Contrary to the above, on June 15 and August 24, 2023, the licensee failed to relieve the shift manager by another qualified individual. Specifically, during an unplanned absence of the shift manager, the licensee replaced the shift manager with an individual that was emergency coordinator qualified and control room supervisor qualified with a current, valid senior reactor operator licensee, but was not shift manager qualified.
This failure to comply with Technical Specification 5.4.1a constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this issue into the corrective action program under condition reports 23-06414 and 23-08756.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 1, 2024, the inspectors presented the Independent Spent Fuel Storage Installation Inspection results to Todd Horton, Senior Vice President, Nuclear Regulatory
& Oversight, and other members of the licensee staff.
- On March 22, 2024, the inspectors presented the emergency preparedness program inspection results to Cary Harbor, Senior Vice President, Site Operations, and other members of the licensee staff.
- On April 5, 2024, the inspectors presented the integrated inspection results to Todd Horton, Senior Vice President, Nuclear Regulatory & Oversight, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855
Engineering
Evaluations
Independent
Spent Fuel
Storage
Installation
2.212 Evaluation
Report
NAC-UMS Universal Storage System at PVNGS
60855
Engineering
Evaluations
Independent
Spent Fuel
Storage
Installation
2.212 Evaluation
Report
MAGNASOTR at PVNGS
60855
Engineering
Evaluations
R-233432
NAC-UMS FSAR
60855
Engineering
Evaluations
R-246948
MAGNASTOR FSAR
60855
Miscellaneous
PV-E0867
NAC International Third Party Audit/Survey
60855
Miscellaneous
R-208436
Certification of Compliance - NAC-UMS 1015
01/12/2009
60855
Miscellaneous
R-235569
Certification of Compliance - MAGNASTOR Docket 72-1031
08/21/2017
60855
Miscellaneous
RE-03-C23-2022-
007
U3C23 SPENT FUEL SELECTION FOR DRY CASKS 170-
175 STORAGE
60855
Procedures
Condition Reporting Process
60855
Procedures
CFR 50.59 and 72.48 Screenings and Evaluations
60855
Radiation
Surveys
Environmental
Trending Data
2019-2023.pdf
Beta, Gamma, and Neutron totals for ISFSI
60855
Radiation
Surveys
ISFSI Map.pdf
Map of TLDs placed around the ISFSI
Corrective Action
Documents
2-08060, 20-14483, 21-14546, 18-06660, 18-06662, 22-
2573, 23-09883, 24-02145
Drawings
01-M-SIP-001
P & I Diagram Safety Injection & Shutdown Cooling System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
01-M-SPP-001
P & I Diagram Essential Spray Pond System
Drawings
01-M-SPP-002
P & I Diagram Essential Spray Pond System
Drawings
2-M-SIP-001
P & I Diagram Safety Injection & Shutdown Cooling System
Miscellaneous
24846
PVAR
Miscellaneous
TD #305021
1MDGAH01*02*ENGINE - Diesel Engine Emer
GENTERTRAIN A (304998)
Procedures
Installation and Removal of DG A Temporary Piping
Supports
Procedures
Control Building Watch Station Rounds
2
Procedures
Procedures
Essential Spray Pond (SP) Train A
Procedures
Diesel Generator A Test
Procedures
High Pressure Safety Injection System Alignment
Verification
Procedures
Train A LPSI and CS System Alignment Verification
Work Orders
5493066
Calculations
13-MC-FP-0807
Combustible Loads - Main Steam Support Structure
Drawings
2-M-FPP-004
P & I Fire Protection System CO2 System
Drawings
2-M-FPP-004
P & I Fire Protection System CO2 System
Drawings
2-P-FPF-304
Control Building Isometric Fire Protection System CO2
System
Miscellaneous
PVNGS DBM - Fire Protection System
Miscellaneous
Pre-fire Strategies Manual
Miscellaneous
13-NS-C072
Palo Verde Fire PRA Overview and Results
Miscellaneous
13-NS-F004
Fire PRA - Quantification and Screenings [FQ/QLS/QNS]
Procedures
Firewatch Requirements
Procedures
Fire System Impairments and Notifications
Procedures
Control of Transient Combustibles
Procedures
Operational Considerations Due to Plant Fire
Procedures
PR-0904
Fire Protection
Work Orders
5419180
Calculations
13-MC-DG-0411
DG Heat Exchanger Minimum Flow Rate vs. Inlet SP Water
Temp
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2-07864, 24-01827, 24-02199
Procedures
Heat Exchanger Visual Inspection
Procedures
Eddy Current Examination of Tubing
Work Orders
5492978, 5493040, 5487159
Corrective Action
Documents
24-01527
Miscellaneous
Unit 2 Operator Logs February 16 - 17, 2024
2/17/2024
Miscellaneous
Standard Maneuver Plan: Unit 2 Cycle 25 83% to 92.5% +
Stabilize
Miscellaneous
Standard Maneuver Plan: Unit 2 Cycle 25, 225 EFPD 100%
to 40%
Miscellaneous
NLR245010101
LOAF/Deliberate Acts
11/20/2023
Miscellaneous
NLR245010300
Control Room Fire
2/13/2023
Procedures
Emergency Notification and Response
Procedures
Conduct of Operations
Procedures
Operational Considerations due to Plant Fire
Procedures
CVCS Normal Operations
Procedures
Power Operations
151
Procedures
Control of Reactivity Maneuver Plans
Work Orders
5601778
Corrective Action
Documents
23-04885
Corrective Action
Documents
23-03441, 23-04046, 23-03984, 23-04013, 20-02176, 23-
04574, 23-04550, 23-04676, 23-04683, 23-04666
Procedures
Foreign Material Exclusion Controls
Procedures
Diesel Generator Integrated Meter and Transducer Loop
Test
Procedures
Cleaning, Inspection, and Testing of the Class 1E Diesel
Generator
Procedures
Maintenance Rule
Procedures
Maintenance Rule Monitoring Process
Work Orders
4747397, 5492993, 5493041, 5492937, 5391975, 5492970,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
5470681
Corrective Action
Documents
24-00698, 23-13030, 24-00785, 24-00092, 24-00960, 24-
01599, 24-01609, 23-12402, 24-00906
Drawings
13-M400-0314-
00090
Gasket Location
Miscellaneous
Red Sheet for U1 Hydrogen Cooler A Torque Check WO#
01/18/2024
Miscellaneous
Risk Management and Readiness Plan: Tightening of the
Unit 1 Hydrogen Cooler Fasteners to Stop Hydrogen Leak
01/17/2024
Miscellaneous
Risk Management and Readiness Plan to Replace Power
Switch Assembly on Subgroup 14 in Unit 2 CEDMCS While
Online
01/30/2024
Miscellaneous
Risk Management and Readiness Plan to Inspect/Test
1MCWNP01D Motor per Applicable Portions of 32MT-9ZZ22
01/30/2024
Miscellaneous
Site Integrated Risk Assessment Work Task 559629-0
01/25/2024
Miscellaneous
Phoenix Risk Monitor - PVGS Unit 3, Plant State as of
1/24/2024 07:53:00 PM
Miscellaneous
Phoenix Risk Monitor Unit 3 RICT, Event Start date
1/24/2024 07:53:00 PM
Miscellaneous
Risk Management and Readiness Plan - Unit 1 Stator
Cooling water HI D/P Alarm Replacement
Miscellaneous
301937
Operations Technical Document for
1MCWNP01D**MOTORX - D Circulating Water Pump
01/31/2024
Procedures
Management of Critical Evolutions and Infrequently
Performed Tests or Evolutions
Procedures
Management of Critical Evolutions and Infrequently
Performed Tests or Evolutions
Procedures
Online Integrated Risk
Procedures
Risk Challenge Meetings
Procedures
Removable Media and Portable Device Management
Procedures
Conduct of Maintenance
Procedures
Toolpouch and Minor Maintenance Process
Procedures
Maintenance Work Order Process and Control
Procedures
13.8 kV Motor Operational Testing
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Risk Management Actions
Procedures
RICT PRA Functionality Determination
Procedures
Procedures
Generator Hydrogen
Procedures
Main Generation and Excitation
Procedures
Control Element Drive Mechanism Control System
(CEDMCS) Operation
Procedures
Assessment and Management of Risk When Performing
Maintenance in Modes 1 and 2
Work Orders
5596239, 5588220, 5453208, 5596622, 5487121, 5582532,
5594719, 5597418
Corrective Action
Documents
24-00020, 23-13257, 23-13258, 17-06807-002, 24-01783,
10-00132, 23-11150, 23-12952, 24-00930, 24-00698, 24-
00997
Drawings
13-C-SPS-0376
Nuclear Service Spray Ponds Sections and Details - Sheet
Drawings
13-C-SPS-0382
Nuclear Service Spray Ponds Stop Gates & Sliding Screens
Details & Sections
Drawings
M018-00545
Fuel Oil Supply and Drain Lines - General arrangement
Drawings
M018-00546
Fuel Oil Supply and Drain Lines - Bill of Material
Miscellaneous
CRAI 3127427
Miscellaneous
Equipment Failure Analysis
03/14/2024
Miscellaneous
PVNGS Design Basis Manual - Essential Spray Pond
System
Miscellaneous
PVNGS Design Basis Manual - Reactor Coolant System
Miscellaneous
Unit 2 Control Room Logs
2/27/2023
Miscellaneous
PVNGS Design Basis Manual - Essential Chilled Water
System
Miscellaneous
CRAI 3566294
Miscellaneous
Schematic for Anchor/Darling Self Contained Hydraulic
Actuator
Miscellaneous
13-MS-031
Evaluation of Heat Loss to Containment from the Reactor
Coolant System
Miscellaneous
13-NS-C088
Mission Times for the EW, SP, SI, AF, and DG systems
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
13-VTD-C628-
00041
Cooper Energy Services Standard Maximum Spans for
Tubing Installation
Miscellaneous
13-VTD-C628-
00049
Cooper Energy Services, Modified by APS, Engineering
Standard Installing Tube Fittings
Miscellaneous
APW-89-0540000
Pressurizer Heater Capacity Study
Miscellaneous
PVNGS DBM
Diesel Generator, Class 1E Standby Generation, Fuel Oil
Storage and Transfer System
Miscellaneous
VTD-A391-00010
Anchor/Darling Instruction Manual for Main Steam Valves
and Feedwater Isolation Valves
Miscellaneous
VTD-C628-00124
Cooper-Bessemer/Service News; KSC Nuclear and
Commercial Oil ad Seepage Nuisance Leaks
Miscellaneous
VTD-C628-0037
Cooper Energy Services ET-24 Turbocharger for Nuclear
Standby Service
Procedures
Fluid Leak Management
Procedures
Procedures
Diesel Generator A Test
Procedures
Lubrication of Plant Equipment
Procedures
RCS Heat Loss Measurement
Procedures
Class 1E Diesel Generator Load Rejection, 24 Hour Rated
Load and Hot Start Test Train A
Work Orders
5479088, 5590478, 5477653, 5597452, 5356683, 5596239,
5157752
Calculations
13-EC-MA-0224
Electrical Equipment Heat Dissipation
Calculations
13-EC-MA-0232
Main Generator Reverse Power Relay Actuation Time
Calculations
13-MC-HA-0269
Auxiliary Building Normal HVAC System Heating and
Cooling Load Calculation
Corrective Action
Documents
23-03479, 23-10247, 23-10371, 23-12042, 23-12061, 23-
211, 23-12784, 24-00164
Drawings
01-E-MAB-008
Elementary Diagram Main Generation System Generator &
Transformer Primary Protection Unit Tripping
Drawings
01-E-MAD-001
Logic Diagram Generator Tripping
Drawings
M400-0315-
00453
APS - Unit 1 Marshaling Panel Terminations 1-J-MBN-C06
Engineering
23-03479-030
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Miscellaneous
CFR 50.59 Screening/Evaluation for EC 4655260
Miscellaneous
Transient Analysis Response to NRC Resident Inspector
03/29/2024
Miscellaneous
E-23-0002
50.59 Screening and Evaluation for [Engineering Change]
23-03479-030
Miscellaneous
E-23-0002
50.59 Screening and Evaluation for [Engineering Change]
23-03479-030
Miscellaneous
E-24-0001
50.59 Screening and Evaluation for [Engineering Change]
23-03479-030
Miscellaneous
Control Element Drive Mechanism Control System
Replacement Modification/Advanced Rod Control Hybrid
ARCH SF-1669 - SMP Phase 2
Miscellaneous
INL/LTD-21-
01672
Human Factors Engineering Support for the Palo Verde
Generating Station Strategic Modernization Project Phase 2
Upgrades
Miscellaneous
JN1034-A00296
Post Installation Test of the Advanced Rod Control Hybrid
ARCH System Palo Verde Unit 1
Procedures
Time Critical Actions Program
Procedures
Control Element Drive Mechanism Control System Operation
Procedures
CEA Operability Checks
Procedures
Engineering Work Orders and Evaluations
Procedures
Design Change Process
Procedures
Conduct of Modifications
Procedures
CFR 50.59 and 72.48 Screenings and Evaluations
Procedures
CFR 50.59 and 72.48 Administrative Guideline
Work Orders
5547291, 5537808, 5418985, 5419154, 5364109, 5570109
Calculations
13-JC-SB-0202
Acceptance Criteria for RPS and ESFAS Response Time
Testing
Calculations
13-JC-SG-0203
Steam Generator Pressure (SGX-P-1013X, X=A, B, C, D),
and (SGX-P-1023X, X=A, B, C, D) Uncertainty and Setpoint
Calculation
Calculations
13-JC-SP-0201
Essential Spray Pond Flow Instruments (SPA-F-0005, SPB-
F-0006, SPN-F-0007, & SPN-F-0008) Setpoint and
Uncertainty Calculation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
13-MC-SP-0307
SP/EW System Thermal Performance Design Bases
Analysis
Corrective Action
Documents
24-00002, 24-00415, 24-00930, 24-01284, 24-00698, 24-
00997, 3307565, 18-17388, 24-02236, 24-02301, 24-02308,
24-02378, 24-02513, 24-02009, 24-02032, 24-02037, 24-
2045, 24-02048, 24-02145
Drawings
01-M-SIP-0001
P & I Diagram Safety Injection & Shutdown Cooling System
Drawings
03-E-PHA-001
Main Line Diagram 480V Class 1E Power System Motor
Control Cener 3E-PHA-M31
Drawings
03-E-PHA-005
Main Line Diagram 480V Class 1E Power System Motor
Control Cener 3E-PHA-M35
Drawings
03-E-PKA-001
Main Line Diagram 125V DC Class 1E and 120V AC Vital
Inst Power System
Drawings
M018-00545
Fuel Oil Supply and Drain Lines - General Arrangement
Drawings
M018-00546
Fuel Oil Supply and Drain Lines - Bill of Material
Miscellaneous
PVNGS DBM - Class 1E 125 VDC Power System
Miscellaneous
Risk Informed Completion Time Estimate with Technical
Specification 3.3.6.B.1 Entry
03/08/2024
Miscellaneous
1A EDG Recommended Sequence of Retest Guideline
Miscellaneous
Heise HQS Module 200 psi +/- 0.1% FS Reference Library
Worksheet
2/06/2006
Miscellaneous
OP3125 Environmental Conditions for H138, HQS-2, 200
GPX. 10%
01/09/2007
Miscellaneous
OP3094 Environmental Conditions for H138, PTE-1
10/23/2006
Miscellaneous
Schematic for Anchor/Darling Self Contained Hydraulic
Actuator
Miscellaneous
13-VTD-C628-
00041
Cooper Energy Services Standard Maximum Spans for
Tubing Installation
Miscellaneous
13-VTD-C628-
00049
Cooper Energy Services, Modified by APS, Engineering
Standard Installing Tube Fittings
Miscellaneous
Calc 03-EC-PK-
207
DC Battery Sizing and Minimum Voltage
Miscellaneous
TSCCR 5607337
3.3.6 ESFAS Logic and Manual Trip
03/09/2024
Miscellaneous
VTD-A391-00010
Anchor/Darling Instruction Manual for Main Steam Valves
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
and Feedwater Isolation Valves
Procedures
Battery Charger Preventive Maintenance
Procedures
Class 1E Battery Charger 18 Month Surveillance Test
Procedures
Plant Protection System Bistable and Bistable Relay
Response Time Test
Procedures
36ST-9SB60, PPS Input Loop Calibration for Channel B
Parameters 5, 6, 11, 12, 14 and 15
Procedures
36ST-9SB60, PPS Input Loop Calibration for Channel B
Parameters 5, 6, 11, 12, 14 and 15
14a
Procedures
Panel B05A Alarm Responses
Procedures
Procedures
Procedures
Diesel Generator A Test
Procedures
Assessment and Management of Risk When Performing
Maintenance in Modes 1 and 2
Procedures
Pump and Valve Inservice Testing Program
Procedures
Pump and Valve Inservice Testing Program
2a
Procedures
Auxiliary Feedwater B - Inservice Test
Procedures
Class 1E Diesel Generator Load Rejection, 24 Hour Rated
Load Hot Start Test Train A
Procedures
HPSI Pumps Miniflow - Inservice Test
Procedures
Essential Spray Pond Pumps - Comprehensive Pump Test
Procedures
Essential Spray Pond Pumps - Comprehensive Pump Test
24a
Work Orders
5483306, 5480970, 5480195, 5597452, 5596239, 5157752,
5487643, 5480079, 5500006, 5553473, 5606973, 5607336,
5607405, 5602573, 5487526
Corrective Action
Documents
Condition Reports
2-06065, 22-06748, 22-07315, 22-12976, 22-13334, 22-
13335, 23-03292, 23-03326, 23-04511, 23-07519, 23-07678
Miscellaneous
Palo Verde Nuclear Generating Station, Alert and
Notification System (ANS) FEMA 350 Report, July 2019
Procedures
Emergency Preparedness Equipment Testing
Procedures
Prompt Notification System
Work Orders
Work Orders
4573821, 5055124, 5319407, 5489842
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
2-03054, 22-06093, 22-13558
Miscellaneous
22 2nd Quarter - Unannounced Emergency Preparedness
Augmentation Drill Report
08/16/2022
Miscellaneous
22 3rd Quarter - Emergency Preparedness Augmentation
Drill Report
09/20/2022
Miscellaneous
22 4th Quarter - Emergency Preparedness Augmentation
Drill Report
2/29/2022
Miscellaneous
23 1st Quarter - Emergency Preparedness Augmentation
Drill Report
03/24/2023
Miscellaneous
23 2nd Quarter - Emergency Preparedness Augmentation
Drill Report
07/13/2023
Miscellaneous
23 3rd Quarter - Emergency Preparedness Augmentation
Drill Report
09/15/2023
Miscellaneous
23 4th Quarter - Emergency Preparedness Augmentation
Drill Report
01/18/2024
Miscellaneous
22 1st Quarter - Emergency Preparedness Augmentation
Drill Report
03/30/2022
Procedures
Notifications
Procedures
EP Drills and Exercises Development Guide
Procedures
ERO/ERF Activation and Operation
Procedures
WROP-8ZZ02
Conduct of Shift Operations
Corrective Action
Documents
Condition Reports
24-00153
Miscellaneous
2-08721-SB
Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2,
and 3 and Independent Spent Fuel Storage Installation
(ISFSI); Docket Nos. 50-528, 50-529, 50-530 and 72-44;
License Nos. NPF-41, NPF-51 and NPF-74; PVNGS
Emergency Plan, Revision 75
01/23/2024
Miscellaneous
Evaluation
Tracking Number:
22-002E
HU2.1 Update to Include NEI 99-01 Revision 6 Developer
Notes for Seismic Occurrence
03/10/2022
Miscellaneous
Evaluation
Tracking Number:
Revision 75 of Palo Verde Emergency Plan
2/23/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23-001E
Miscellaneous
Screening
Tracking Number
22-05S
Revision 74 to Palo Verde Emergency Plan to include HU2.1
revision and elimination of H2 Recombiners
8/3/2022
Miscellaneous
Screening
Tracking Number
23-001S
PBX EC 22-00202-002 QF 1848
2/7/2023
Procedures
Emergency Plan Maintenance
16, 17
Procedures
Analysis of Seismic Event
Corrective Action
Documents
Condition Reports
21-06893, 21-10262, 22-02654, 22-02729, 22-02816, 22-
2865, 22-02898, 22-03411, 22-08314, 22-08393, 22-08394,
2-08417, 22-10231, 22-10281, 23-00670, 23-01724, 23-
01867, 23-02314, 23-03015, 23-03059, 23-03162, 23-
200, 23-04110, 23-08743, 23-13291, 24-01650, 24-02128
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
24-02747, 24-02749
Miscellaneous
Palo Verde Nuclear Generating Station Event Reporting
Manual
Miscellaneous
23 Onsite Contaminated Injury Medical Emergency Drill
2308 Report
03/12/2024
Miscellaneous
201 ERO Dress Rehearsal Drill - ERO Green Team
(February 1st 2022)
03/18/2022
Miscellaneous
Dose Assessment User Manual
2/2/2023
Miscellaneous
22 Annual Review of PVGS Emergency Plan Letters of
Agreement and Offsite Program Commitments
2/30/2022
Miscellaneous
Annual Review of PVGS Emergency Plan Letters of
Agreement and Offsite Program Commitments
2/9/2024
Miscellaneous
23 Offsite Medical Services/Contaminated Injury Drill
01/18/2024
Miscellaneous
202 Full Scale Exercise - ERO Green Team (March 8th,
22)
05/27/2022
Miscellaneous
203 (Jul 19th White Team) and 2204 (Aug 9th Blue Team)
Drill Report
09/8/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
205 (Aug 30th Gold Team) and 2206 (Sep 6th Red Team)
ERO Drill
10/12/2022
Miscellaneous
207 Onsite Contaminated Injury Medical Emergency Drill
Report
03/23/2023
Miscellaneous
Emergency Preparedness INPO EMPE Drill - January 31,
23
04/13/2023
Miscellaneous
Emergency Preparedness NRC Evaluated Exercise Report -
March 7th, 2023
05/10/2023
Miscellaneous
Emergency Preparedness 2304 Drill Report - Drill Date Aug
8, 2023
09/8/2023
Miscellaneous
Organizational Health Quarterly Report, 1st Quarter 2022
04/22/2022
Miscellaneous
Organizational Health Quarterly Report, 2nd Quarter 2022
07/12/2022
Miscellaneous
Organizational Health Quarterly Report, 3rdt Quarter 2022
11/1/2022
Miscellaneous
Organizational Health Quarterly Report, 4th Quarter 2022
01/31/2023
Miscellaneous
Organizational Health Quarterly Report, 1st Quarter 2023
05/5/2023
Miscellaneous
Organizational Health Quarterly Report, 2nd Quarter 2023
08/23/2023
Miscellaneous
Nuclear Assurance Department (NAD) Audit Report, Audit
22-009, Emergency Preparedness
11/18/2022
Miscellaneous
Emergency Preparedness 2305, 2306 Drill Report - Drill
Dates, Sep 19th, Sep 26th 2023
11/3/2023
Miscellaneous
Emergency Preparedness Environmental Monitoring Drill
2307
04/13/2023
Miscellaneous
Postponed 2021 Offsite Medical Services/Contaminated
Injury Drill
05/27/2022
Miscellaneous
2-08421-
JF/SMB
Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2,
and 3 and Independent Spent Fuel Storage Installation
(ISFSI); Docket Nos. 50-528, 50-529, 50-530 and 72-44;
License Nos. NPF-41, NPF-51 and NPF-74; PVNGS
Evacuation Time Estimate Study
04/1/2022
Miscellaneous
Form EP-504
PVNGS Emergency Preparedness, Soil/Vegetation
Sampling Instructions
C
Miscellaneous
KLD TR-1308
Palo Verde Nuclear Generating Station, 2023 Population
Update Analysis
2/23/2023
Miscellaneous
Report #: SR-23-
Functional Area: Emergency Preparedness/Beyond Design
11/17/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0063
Basis FLEX Programs; Dates: 9/26/2023-10/6/2023; Scope:
Verify Emergency Preparedness Program Meets Criteria for
Nominal 24-Month Audit Frequency
Miscellaneous
SWMS No. 22-
13558-002
Formal Self-Assessment Report, Emergency Preparedness
23, Completed 01/16/23 - 01/20/23
03/1/2023
Procedures
Condition Reporting Process
Procedures
Condition Reporting Process Administrative Guideline
Procedures
Emergency Medical Response
Procedures
Conduct of Emergency Preparedness Operation
Procedures
Emergency Preparedness Drill and Exercise Program
Management
Procedures
Emergency Preparedness Offsite Program
Procedures
Emergency Preparedness Equipment Out of Service
Procedures
Internal Audits
Procedures
Actions for Non-Functional Radiation Monitors: Preplanned
Alternate Sampling Program
Procedures
Protective Actions
Procedures
Termination and Recovery
Work Orders
Work Orders
28712, 5431201, 5438135, 5455674, 5551478, 5558633,
5583648
71151
Corrective Action
Documents
23-01389
71151
Corrective Action
Documents
Condition Reports
2-09508, 23-00326, 23-00817, 23-04957, 23-11859, 23-
2766
71151
Miscellaneous
Palo Verde Nuclear Generating Station Siren Operating
Manual
2/29/2023
71151
Miscellaneous
Units 1, 2, and 3 Power Profile PI Vision, January 1, 2023
through December 31, 2023
71151
Miscellaneous
Units 1, 2, and 3 Control room logs, January 1, 2023 through
December 31, 2023
71151
Miscellaneous
Unit 2 Daily Plant Status Reports: 2/24/2023-3/06/2023
71151
Miscellaneous
Form EP-0936
ERO Drill Participation Evaluation Checklist
C
71151
Procedures
Performance Indicator Emergency Preparedness
Cornerstone
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2-12115, 22-12592, 22-13534, 23-00826, 23-01310, 23-
247, 23-01728, 23-01908, 23-02003, 23-02588, 23-
2611, 23-02891, 23-03220, 23-05697, 23-05978, 23-
230, 23-06414, 23-06472, 23-06531, 23-06532, 23-
06936, 23-06937, 23-06946, 23-07586, 23-07597, 23-
257, 23-08756, 23-08917, 23-09399, 23-09790, 23-
09849, 23-09959, 23-10389, 23-10491, 23-11328, 23-
11833, 23-12383, 23-12590, 23-12641, 23-12666, 23-
13113, 23-13279, 24-00401, 24-01106, 24-01427, 24-
01386, 24-01423, 24-01427, 24-02035, 24-02065, 24-
2078, 24-02217, 24-02219, 24-02299, 24-02769, 24-
2831, 24-02971, 24-03101
Miscellaneous
23 NRC Annual Operations Exam E-Plan Related Failures
09/26/2023
Miscellaneous
Miscellaneous
Miscellaneous
OPD-02
Operations Department Practices: Operations Shift Staffing
and Scheduling Practices
Procedures
Condition Reporting Process
Procedures
Condition Reporting Process
Procedures
Condition Reporting Administrative Guideline
Procedures
Condition Reporting Administrative Guideline
Procedures
Trend Analysis Administrative Guideline
Procedures
Self-Assessment and Benchmarking Administrative
Guideline
Procedures
Systematic Approach to Training
Procedures
Conduct of Operations
Procedures
Conduct of Operations
77a
Procedures
Internal Audits
Corrective Action
Documents
23-03479, 23-03648
Corrective Action
Documents
23-05432, 23-05886, 23-05635, 23-05990, 23-05956, 23-
05983, 23-05990, 23-05997, 23-06003, 23-06125, 23-06128
Engineering
Evaluations
23-05990-003
Nuclear Safety Assessment
06/02/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Evaluations
23-05990-005
Control Systems Evaluation
06/3/2023
Miscellaneous
PVNGS Design Basis Manual - Feedwater Control System
Miscellaneous
PVNGS Design Basis Manual - Feedwater System
Miscellaneous
Event Reporting Manual
Miscellaneous23-004 June 02,
23
Emergent PRB for U2 Short Notice Outage Restart
Miscellaneous
23-05990-012
Maintenance Rule Functional Failure Determination
Procedures
Degraded Electrical Power
Procedures
Standard Post Trip Actions
Procedures
Procedures
Item Procurement Specification (IPS) Requirements
Procedures
Regulatory Interaction and Correspondence Control
Procedures
Regulatory Interaction and Correspondence Control
26a
Work Orders
5539629, 5537359
2702
CONF
Engineering
Evaluations
23-07089-001
Evaluate design changes for Batch 3 MAGNASTOR
2702
CONF
Engineering
Evaluations
RCTSAI 5358572
Confirmatory Order - Condition Report Closure Review
Board Package CR 20-15366 - 72.48's screened
2702
CONF
Miscellaneous
Effectiveness
Review.pdf
23 Effectiveness Review of Confirmatory Order EA-20-
054
2/30/2023
2702
CONF
Miscellaneous
RCTSAI 5358569
Confirmatory Order - Condition Report Closure Review
Board Package Training of individuals 50.59/72.48
0