IR 05000528/2015001
| ML15128A182 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/13/2015 |
| From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-D |
| To: | Edington R Arizona Public Service Co |
| References | |
| IR 2015001 | |
| Download: ML15128A182 (29) | |
Text
UNITED STATES May 13, 2015
SUBJECT:
Palo Verde Nuclear Generating Station - NRC INTEGRATED INSPECTION REPORT 05000528/2015001, 05000529/2015001, AND 05000530/2015001
Dear Mr. Edington:
On March 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Palo Verde Nuclear Generating Station Units 1, 2, and 3. The NRC inspectors discussed the results of this inspection on April 2, 2015, with Mr. R. Bement and other members of your staff, and again on May 8, 2015, with Mr. D. Mims and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the 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 Regional Administrator, Region IV; and the NRC resident inspector at the Palo Verde Nuclear Generating Station. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Geoffrey B. Miller, Chief Project Branch D Division of Reactor Projects Docket Nos: 50-528, 50-529, 50-530 License Nos: NPF-41, NPF-51, NPF-74
Enclosure:
Inspection Report 05000528/2015001, 05000529/2015001, and 05000530/2015001 w/ Attachment: Supplemental Information
REGION IV==
Docket: 05000528, 05000529, 05000530 License: NPF-41, NPF-51, NPF-74 Report: 05000528/2015001, 05000529/2015001, 05000530/2015001 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: 5801 South Wintersburg Road Tonopah, Arizona 85354 Dates: January 1 through March 31, 2015 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, Resident Inspector D. You, Resident Inspector L. Brandt, Project Engineer C. Steely, Operations Engineer M. Hayes, Operations Engineer G. Guerra, Emergency Preparedness Inspector Approved Geoffrey B. Miller By: Chief, Project Branch D Division of Reactor Projects 1 Enclosure
SUMMARY
IR 05000528, 529, 530/2015001; 1/1/2015 - 3/31/2015; Palo Verde Nuclear Generating Station
Units 1, 2, and 3, integrated inspection report, post-maintenance testing.
The inspection activities described in this report were performed between January 1, 2015 and March 31, 2015, by the resident inspectors at Palo Verde Nuclear Generating Station and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green)are documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red),
which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,
Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green, non-cited violation of Palo Verde Technical Specification 5.5.8 Inservice Testing Program which requires the in-service testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2001 Edition with Addenda through 2003. On April 26, 2013, the licensee did not test Unit 1 train A shutdown cooling isolation valve SIA-UV-651, an ASME Code Class 1 valve, in accordance with ASME OM Code Section ISTC-3310.The licensee entered this issue into the corrective action program as Palo Verde Action Request 4398843.
The failure to complete ASME OM Code required in-service testing on a Class 1 motor operated valve is a performance deficiency. This performance deficiency is more than minor, and therefore is a finding, because it affected the equipment performance attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Specifically, by not performing the required testing, the licensee did not maintain the requisite level of assurance of the equipments capability of performing its intended function. Using Inspection Manual Chapter 0609 Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the condition was not a design or qualification deficiency, did not involve an actual loss of safety function for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
Because the most-significant contributor to the finding was that Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained, the finding has a cross-cutting aspect in the Human Performance area and the aspect of Teamwork (H.4). (Section 1R19)
Licensee-Identified Violations
None
PLANT STATUS
Unit 1 operated at effective full power for the entire inspection period.
Unit 2 operated at effective full power for the entire inspection period with the exception of a five percent down-power during a loss of all charging and letdown event as directed by station abnormal operating procedures on March 20, 2015.
Unit 3 operated at effective full power for the entire inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness to Cope with External Flooding
a. Inspection Scope
On March 2, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose plant areas that were susceptible to flooding:
March 2, Unit 3 auxiliary building 51, 70, 88, and 100 elevations The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.
These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
February 19, Unit 2 A auxiliary feedwater system February 26, Unit 3 B auxiliary feedwater system March 19, Unit 2 A channel 120Vac class 1E instrument power The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the trains were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
January 23, Unit 1, auxiliary feedwater rooms, fire zones 72 and 73 March 3, Unit 1, west & east piping penetration rooms, fire zones 37C and 37D March 20, Unit 2, auxiliary feedwater rooms, fire zones 72 and 73 March 24, Unit 3, diesel generator building, fire zones 23A and 23B For each area, the inspectors evaluated the fire plan against defined hazards and defense in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On February 23, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground vaults that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:
February 18, Unit 3 B diesel generator fuel oil vault February 23, Unit 3 A diesel generator fuel oil vault The inspectors observed the material condition of the cables and splices contained in the vaults and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.
These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
On March 16, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors observed the licensees inspection of the Unit 3 A Emergency Diesel Generator lube oil and jacket water heat exchangers and the material condition of the heat exchanger internals.
These activities constitute completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. This feeder is a continuation of the requalification program inspection that was documented in NRC Inspection Report 2014005. This continuation was necessary due to the timing of the facility exams at the end of the calendar year.
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On March 24, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
On March 5, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to performance of the A essential spray pond pump inservice testing using revised procedures.
In addition, the inspectors assessed the operators adherence to plant procedures, including Conduct of Shift Operations procedure and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.3 Biennial Inspection
a. Inspection Scope
To assess the performance effectiveness of the licensed operator requalification program, the inspectors conducted personnel interviews, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.
The inspectors interviewed five licensee personnel, consisting of three operators and two instructors, to determine their understanding of the policies and practices for administering requalification examinations. The inspectors also reviewed operator performance on the written exams and operating tests. These reviews included observations of portions of the operating tests by the inspectors. The operating tests observations included nine job performance measures and four scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content. The inspectors also reviewed medical records of twelve licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for four operators.
The results of these examinations were reviewed to determine the effectiveness of the licensees appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.
The inspectors interviewed members of the training department and reviewed minutes of training review group meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events. Examination results were also assessed to determine if they were consistent with the guidance contained in NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process.
In addition to the above, the inspectors reviewed examination security measures, simulator fidelity, and existing logs of simulator deficiencies.
Upon completion of the exam process the licensee informed the lead inspector of the results of the written examinations and operating tests for the Licensed Operator Requalification Program. The inspectors compared these results to the Appendix I, Licensed Operator Requalification Significance Determination Process, values and determined that there were no findings based on these results and because all of the individuals that failed the applicable portions of their exams and/or operating tests were remediated, retested, and passed their retake exams prior to returning to shift.
The inspectors completed one inspection sample of the biennial licensed operator requalification program.
b. Findings
A licensee-identified finding was documented in NRC Inspection Report 05000528; -529; -530/2014005.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed one instance of degraded performance or condition of safety-related structures, systems, and components (SSCs):
March 5, auxiliary building and main steam support structure floor drains, recent system failures pertaining to drain line blockages and check valve failures The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
March 5 Unit 3, A essential spray pond pump inservice testing March 16, Unit 3, B diesel generator and essential spray pond systems maintenance outage The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
The inspectors also observed portions of one emergent work activity that had the potential to cause an initiating event or to affect the functional capability of mitigating systems:
March 20, Unit 2, A and E charging pump failures with B charging pump functional but degraded due to discharge pulsation dampener failure The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components (SSCs).
These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed four operability determinations and one functionality assessment that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
January 2, operability determination of Unit 2 reactor vessel head inner seal o-ring pressure indicator January 27, operability determination of Unit 2 B diesel generator jacket water heat exchange corrosion January 27, operability determination of Unit 3 A diesel generator lube oil heat exchange corrosion February 19, functionality assessment of Unit 3 A auxiliary feedwater pump room high water level switch March 24, operability determination of Unit 1 shutdown cooling isolation valve SIA-UV-651 The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constitute completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed six post-maintenance testing activities that affected risk-significant structures, systems, or components (SSCs):
January 27, Unit 3 A auxiliary feedwater pump steam supply valve maintenance February 27, Unit 3 C battery charger test following scheduled preventive maintenance February 28, Unit 3 A diesel generator test following scheduled maintenance March 3, Unit 2 A auxiliary feedwater steam supply bypass valve torque switch replacement March 18, Unit 1 A auxiliary feedwater pump flow instrument calibration March 23, Unit 1, shutdown cooling isolation valve SIA-UV-651 following outage maintenance (final disposition of a previous quarters sample)
The inspectors reviewed licensing and design basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19
b. Findings
Introduction.
The inspectors identified a Green, non-cited violation of Palo Verde Technical Specification 5.5.8 Inservice Testing Program which requires in-service testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2001 Edition with Addenda through 2003. On April 26, 2013, the licensee did not test Unit 1 train A shutdown cooling isolation valve SIA-UV-651, an ASME Code Class 1 valve, in accordance with ASME OM Code Section ISTC-3310.
Description.
During Unit 1 refueling outage 1R17, the licensee performed maintenance on motor-operated valve SIA-UV-651 to correct seat leakage and to refurbish the actuator. Valve SIA-UV-651 has safety-related functions in both its closed and opened positions. In its closed position, valve SIA-UV-651 is the first pressure boundary between the reactor coolant system and the shutdown cooling system. The valve is also called upon in the licensees emergency operating procedures to remotely open when repositioned by control room operators establishing long term cooling following a loss of coolant accident.
The licensees motor-operated valve program implements the requirements of the ASME Operations and Maintenance Code. The licensee committed to the requirements of the 2001 ASME OM Code edition with 2003 Addenda. Code section ISTC-3310 requires that following any maintenance which could affect the performance of the valve, the valve must be stroke-time tested to either verify that the reference value was still valid, or set a new reference value.
Following the work on SIA-UV-651, the prescribed post-maintenance retests to be performed included a seat leakage check and a functional timed stroke. On April 25, 2013, when Unit 1 was in Hot Standby mode at the end of the refueling outage, the licensee conducted seat-leakage testing on SIA-UV-651. During the first test attempt, leakage past the valve exceeded the Technical Specification limit of 5 gpm. The licensee entered LCO 3.4.15 due to excessive leakage and initiated troubleshooting work order 4397107 to correct the condition. Maintenance activities performed on valve SIA-UV-651 during troubleshooting included lifting and re-landing electrical lead wires, adjusting motor operator torque switch settings, and de-coupling and manually manipulating the valve actuator. On April 26, 2013, the valve seat leakage requirements of Technical Specification 3.4.15 were met and the licensee left the valve closed, in the position that it was in when it passed the seat-leakage test.
Troubleshooting work order 4397107 included instructions to perform a post-maintenance test and an as-left functional timed valve stroke following the seat leakage test. However, the licensee did not perform either this test or the timed stroke. Instead, a valve services technician lined out the procedure step and noted at the bottom of the work order page that the functional stroke was not performed per direction from the Operations department.
Procedure 30DP-9WP02, Maintenance Work Order Process and Control, Revision 63, Appendix B describes the work order change process. This procedure describes a change to a retest as a method change, and states that if the work order originally required a technical approval, the changes to a method also require the performance of a technical approval. In this instance, the operations personnel who directed the valve services technician to line out the valve-stroke procedure steps did not recognize the importance of the retest requirement and did not request a technical approval to assess the deletion of those steps. The inspectors determined that had a technical review been performed, that the ASME OM Code requirements likely would have been identified as not met and corrected.
The inspectors also identified a second missed opportunity to recognize and address the missed retest requirement. After the licensee noted that they had failed to complete the functional test of the valve, a licensee engineer initiated PVAR 4398843, titled MOV Program Violations. This PVAR described how the lack of a post maintenance retest violated the licensees motor operated valve program. Operators performed an immediate operability determination (IOD) for this condition, as required by procedure 40DP-9OP26, Operations PVAR Processing and Operability Determination/Functional Assessment, Revision 34. That IOD offered justification that the valve remained operable because it had been electrically cycled several times as part of maintenance and troubleshooting activities during the refueling outage, and because the as-left torque switch settings would not impact the ability of the actuator to open the valve. In that IOD, the licensee concluded that the valve would open to fulfill its safety function. However, the licensees IOD did not acknowledge and therefore did not address the impact on assurance of operability of not performing the stroke-time test required by the ASME OM Code. Instead, the IOD requested a prompt operability determination (POD) to perform a more detailed assessment of the nonconformance with the ASME OM Code criteria.
Part of the supporting documentation for the prompt operability determination, Engineering Evaluation 4398892, dated May 1, 2013, described that the lack of performance of a functional stroke constituted a failure to conform to the ASME OM Code Section ISTC-3310 retest requirement. Procedure 40DP-9OP26 Appendix G, Section 2.5 directs that prompt operability determinations consider the guidance in NRC Inspection Manual Chapter 0326, Appendix C for conditions involving ASME OM Code criteria. Inspection Manual Chapter 0326, Appendix C, Section C.08, Technical Specification Operability vs. ASME OM Code Criteria states the following:
The Technical Specifications normally applies to the overall performance of plant systems, but sometimes contains limiting values for the performance of certain components. The limiting values are specified to ensure that the design basis and safety analysis are satisfied. The values (e.g., pump flow rate, valve closure time, valve leakage rate, safety/relief valve set point pressure) are criteria that can be used to verify operability. If the values are not met at any time, the system must be declared inoperable, the LCO must be declared not met, and the applicable conditions must be entered.
After performing corrective maintenance on valve SIA-UV-651, the licensee did not establish the valve would function as intended by performing a functional stroke and collecting diagnostic data and therefore did not demonstrate that the performance of valve SIA-UV-651 met the limiting performance values mandated by the ASME OM code. The licensees subsequent immediate and prompt operability determinations failed to declare the valve inoperable, and the licensee took no action to correct the nonconformance with the ASME OM Code requirement during the operating cycle.
The licensee restored compliance with the ASME OM code testing requirements when the valve successfully stroked and passed diagnostic testing at the beginning of the next refueling outage on October 4, 2014.
The inspectors determined that the most-significant contributor to the finding was miscommunication between different licensee work groups. Specifically licensee engineers familiar with the in-service testing requirements did not communicate the apparent failure to meet ASME OM Code requirements to Outage Control Center and Control Room Operations staff responsible for making station level decisions.
The inspectors also determined that although the licensee engineers identified the IST program violations and initiated a condition report, these issues are NRC-identified because the inspectors identified the licensees failure to identify procedural non-compliances within their work management, corrective action program, and operability determination programs. The inspectors considered that if the licensee had followed their work management and operability determination processes, they likely would have corrected the in-service testing violations before operating for an entire cycle with the valve inoperable due to non-compliance with the ASME OM code.
Analysis.
The failure to complete ASME OM Code-required in-service testing on a Class 1 motor operated valve is a performance deficiency. This performance deficiency is more than minor, and therefore is a finding, because it affected the equipment performance attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events.
Specifically, by not performing the required testing, the licensee did not maintain the requisite level of assurance of the equipments capability of performing its intended function. Using Inspection Manual Chapter 0609 Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the condition was not a design or qualification deficiency, did not involve an actual loss of safety function for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Because the most-significant contributor to the finding was that Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained, the finding has a cross-cutting aspect in the Human Performance area and the aspect of Teamwork (H.4).
Enforcement.
Palo Verde Technical Specification 5.5.8, "Inservice Testing Program, requires the inservice testing of ASME Code Class 1, 2, and 3 components in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2001 Edition with Addenda through 2003. OM Code ISTC-3310 requires, in part, that when a valve has undergone maintenance that could affect the valves performance, a new reference value shall be determined by an inservice test run before the time it is returned to service. Contrary to the above, on April 26, 2013, the licensee did not test Unit 1 train A shutdown cooling isolation valve SIA-UV-651, an ASME Code Class 1 valve, in accordance with ASME OM Code Section ISTC-3310.
Specifically, after lifting and re-landing electrical lead wires, adjusting motor operator torque switch settings, and de-coupling and manually manipulating the valve actuator, the licensee failed to perform an inservice functional stroke SIA-UV-651 to determine new reference values for the valves performance. Because this finding is of very low safety significance and has been entered into the licensees corrective action program as PVAR 4398843, this violation is being treated as a non-cited violation in accordance with Section 2.3.2 of the Enforcement Policy: NCV 05000528/2015001-01, Failure to conduct required in-service testing in accordance with ASME OM Code.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:
In-service tests:
February 4, Unit 3 A auxiliary feedwater pump IST March 5, Unit 3 A essential spray pond pump IST Isolation Valve Testing March 10, Unit 1 FLEX piping tie in to A safety injection piping Other surveillance tests:
February 20, Unit 3 engineered safety features actuation system electrical relay testing The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspectors performed an in-office review of changes to Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Emergency Plan, Revision 54, and Emergency Plan Implementing Procedure EP-0905, Protective Actions, Revision 6, submitted by letters, dated January 9, and January 6, 2014, respectively. Both documents made changes to incorporate protective action strategy associated with implementing the guidance in NUREG-0654, FEMA-REP-1, Revision 1, Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power plants, Formulating a Protective Action Strategy, and several other editorial changes.
These revisions were compared to their previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that the revisions did not reduce the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.
These activities constitute completion of two emergency action level and emergency plan change samples as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on February 5, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the emergency offsite facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports (LERs) for the period of January 1, 2014, through December 31, 2014, to determine the number of scrams that occurred.
The inspectors compared the number of scrams reported in these LERs to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted three samples for verification of the unplanned scrams per 7000 critical hours performance indicator on Units 1, 2, and 3 respectively, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Unplanned Power Changes per 7000 Critical Hours (IE03)
a. Inspection Scope
The inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of January 1, 2014, through December 31, 2014, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted three samples for verification of the unplanned power outages per 7000 critical hours performance indicator Units 1, 2, and 3 respectively, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between January 1, 2014, and December 31, 2014. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.
These activities constituted three samples for verification of the unplanned scrams with complications performance indicator Units 1, 2, and 3 respectively, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected two issues for an in-depth follow-up:
On February 19, the licensees response to a series of repetitive main steam isolation signal spurious half-leg actuations in Unit 3.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.
On March 18, the adequacy of the licensees post-maintenance testing of diesel generator governor replacements with regard to the requirements of IEEE 387 Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations on Units 1, 2, and 3.
The inspectors reviewed the requirements of IEEE 387, both the current revision and an earlier version to which the licensee has formally committed. The post-modification requirements for both versions are the same with differing requirements for major and minor changes. The inspectors determined that the licensee had correctly applied the post-maintenance testing requirements for the preventive replacement of the governors on all six diesel generators.
Specifically, like-for-like part replacements are categorized as minor changes per IEEE 387-1995 Section 6.6.b and can be analyzed and tested in accordance with existing licensee programs, without having to go through the full initial qualification testing program described by IEEE 387-1995 section 6.2. The purpose of the testing program is to verify the ruggedness of the engine and generator itself by subjecting it to hundreds start and load tests. The inspectors did confirm that the licensee satisfied the requirements for the installed engines during plant construction.
These activities constitute completion of two annual follow-up samples as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The inspectors debriefed Mr. T. Mock, Director, Operations, and other members of the licensee's staff of the results of the licensed operator requalification program inspection on November 20, 2014, and telephonically exited with Mr. D. Heckman, Senior Consultant, Nuclear Regulatory Affairs, and other staff members on January 13, 2015. The licensee representatives acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On March 24, 2015, the inspectors conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan to Mr. R. Davis, Director, Nuclear Security & Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented.
On April 2, 2015, the inspectors presented the inspection results to Mr. R. Bement, Senior Vice President, Nuclear Site Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On May 8, 2015, the inspectors presented the inspection results to Mr. D. Mims, Senior Vice President, Nuclear Regulatory Assessment, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Bement, Vice President Operations
- D. Mims, Vice President Support
- R. Lange, Operations Training Manager
- G. Andrews, Director, Nuclear Regulatory Affairs
- S. Banks, License Operator Training Supervisor
- J. Allison, Exam and Simulator Support Supervisor
- M. McGhee, Compliance Supervisor, Nuclear Regulatory Affairs
- F. Oreshack, Licensing Engineer, Nuclear Regulatory Affairs
- S. Dornseif, Licensing Engineer, Nuclear Regulatory Affairs
- D. Elkington, Licensing Engineer, Nuclear Regulatory Affairs
- D. Heckman, Senior Consultant, Nuclear Regulatory Affairs
NRC Personnel
- C. Steely, Operations Engineer
- M. Hayes, Operations Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Failure to conduct required in-service testing
- 05000528/2015001-01 NCV in accordance with ASME OM Code (Section 1R19)