IR 05000528/2017001

NRC Integrated Inspection Report 05000528/2017001, 05000529/2017001, and 05000530/2017001, and Independent Spent Fuel Storage Installation (ISFSI) Inspection Report 07200044/2017001

ML17130B002
Person / Time
Site:	Palo Verde
Issue date:	05/10/2017
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Bement R Arizona Public Service Co
GEOFFREY MILLER
References
IR 2017001
Download: ML17130B002 (61)

Text

UNITED STATES May 10, 2017

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2017001, 05000529/2017001, AND 05000530/2017001, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) INSPECTION REPORT 07200044/2017001

Dear Mr. Bement:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On April 12, 2017, the NRC inspectors discussed the results of this inspection with Mr. J. Cadogan and other members of your staff. The results of this inspection are documented in the enclosed 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 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; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.

If you disagree with the 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Geoffrey B. Miller, Branch Chief Project Branch D Division of Reactor Projects Docket Nos.:

50-528, 50-529, 50-530, 07200044 License Nos.:

NPF-41, NPF-51, NPF-74 Enclosure:

Inspection Report 05000528/2017001, 05000529/2017001, 05000530/2017001, and 07200044/2017001 w/Attachments:

1. Supplemental Information 2. Information Request for the Radiation Safety Team Inspection

SUNSI Review ADAMS Non-Sensitive Publicly Available By: Yes No Sensitive Non-Publicly Available OFFICE DRP/SRI DRP/RI DRP/RI C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PS2 NAME CPeabody DReinert DYou TFarnholts GWerner VGaddy HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/8/17 5/10/17 5/8/17 05/08/2017 05/8/2017 5/8/2017 5/9/2017 OFFICE TL:IPAT C:DRP/D NAME THipschman GMiller SIGNATURE /RA/ /RA/

DATE 5/8/17 5/10/17

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000528, 05000529, 05000530, 07200044 License: NPF-41, NPF-51, NPF-74 Report: 05000528/2017001, 05000529/2017001, 05000530/2017001, and 07200044/2017001 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: 5801 South Wintersburg Road Tonopah, AZ 85354 Dates: January 1 through March 31, 2017 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, PhD, Resident Inspector D. You, Resident Inspector C. Alldredge, Health Physicist M. Bloodgood, Emergency Response Specialist J. DeBoer, Emergency Preparedness Inspector J. Drake, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Emergency Preparedness Inspector B. Larson, Senior Operations Engineer S. Money, Health Physicist J. ODonnell, CHP, Health Physicist D. Stearns, Health Physicist C. Steely, Operations Engineer E. Simpson, Lead ISFSI Inspector, FCDB M. Davis, ISFSI Vendor Inspector, DSFM Approved Geoffrey B. Miller By: Chief, Project Branch D Division of Reactor Projects Enclosure

SUMMARY

IR 05000528, 529, 530/2017001, 07200044/2017001; 1/1/2017 - 3/31/2017; PALO VERDE

NUCLEAR GENERATING STATION INTEGRATED INSPECTION REPORT; MAINTENANCE RISK ASSESSMENTS AND EMERGENT WORK CONTROL The inspection activities described in this report were performed between January 1 and March 31, 2017, by the resident inspectors at Palo Verde Nuclear Generating Station and inspectors from the NRCs Region IV office and other NRC offices. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (i.e.,

Green, greater than Green, White, Yellow, or Red), determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. 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, dated July 2016.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the failure to establish procedure instructions for work authorization denials or deferrals. Specifically, this led to a 60 day extended unavailability of the diverse auxiliary feedwater actuation system when corrective maintenance was inappropriately deferred by the operations department.

Failure to provide adequate procedural guidance in the event of a denied work authorization, a circumstance anticipated to occur, is a performance deficiency. The performance deficiency is more than minor, because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability and reliability of equipment that responds to an initiating event. Specifically, because the corrective maintenance was not performed in a timely manner, both trains of the diverse auxiliary feedwater actuation system remained in bypass for an additional 60 days whereby the system was not capable of performing its required safety function. The inspectors evaluated the significance of the finding using Inspection Manual Chapter 0609, Appendix A,

Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions, Section A, Question 2, which required a detailed risk evaluation because the finding involved a loss of system safety function. A Region IV senior reactor analyst performed a detailed risk assessment of the finding and determined that the finding was of very low safety significance (Green). The inspectors determined that the finding had a cross-cutting aspect in the human performance area of Work Management. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the Unit Operations Managers decision to deny the work authorization was based on conservative but faulty assumptions, and if other work groups with greater specific technical knowledge had been involved, the corrective maintenance likely would have proceeded [H.5]. (Section 1R13)

PLANT STATUS

Units 1, 2, and 3 operated at full power for the entire inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed four partial system walk-downs of the following risk-significant systems:

• January 13, 2017, Unit 3 Technical Specification 3.8.1 required offsite power circuits during diesel generator B extended allowed outage time

• January 25, 2017, Unit 3 turbine driven auxiliary feedwater system

• March 6, 2017, Unit 2 diesel fuel oil storage and transfer system A

• March 20, 2017, Unit 3 125V DC Class 1E electrical distribution system B and D 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 systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On January 10, 2017, the inspectors performed a complete system walk-down inspection of the Station Blackout Generators. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed open condition reports, in-process design changes, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, 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 six plant areas important to safety:

• January 4, 2017, Unit 3 lower cable spreading room and corridor building, Fire Zone 14

• January 6, 2017, Unit 3 essential switchgear room A and seismic gap, Fire Zone 86A and 6A

• January 31, 2017, Unit 1 turbine-driven auxiliary feedwater pump room, Fire Zone 72

• February 16, 2017, Unit 2 containment spray pump room A, Fire Zone 30A

• March 7, 2017, Unit 2 main control room, Fire Zone 17

• March 21, 2017, Unit 1 main turbine bearings, Fire Zones TB9 and TB10 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 six quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On March 15, 2017, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components (SSCs) that were susceptible to flooding:

• Unit 2, diesel generator rooms A and B The inspectors reviewed plant design features and licensee procedures for coping with internal 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 operator actions credited for flood mitigation could be successfully accomplished.

In addition, on January 10, 2017, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected three underground bunkers that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:

• Unit 2 essential spray pond system A electrical cable vault (2EMHAKEM08)

• Unit 2 essential spray pond system B electrical cable vault (2EMHBKEM08)

• Unit 2 essential engineered safety features transformer area electrical cable vault (2EMHKNBM32)

The inspectors observed the material condition of the cables and splices contained in the bunkers and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.

These activities constituted completion of one flood protection measures sample and three bunker/manhole samples, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On February 27, 2017, 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 diesel generator A jacket water heat exchanger and the material condition of the heat exchanger internals. Additionally, the inspectors walked down the jacket water heat exchanger to observe its performance and material condition.

These activities constituted 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

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On February 17, 2017, the inspectors observed simulator training for an operating crew.

The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constituted 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 February 23, 2017, the inspectors observed the performance of on-shift licensed operators in the Unit 3 main control room. At the time of the observations, the plant was in a period of heightened risk due to troubleshooting activities on the control element drive mechanism system. The inspectors observed the operators performance of the pre-job brief and the control room oversight and communications of the activity.

In addition, the inspectors assessed the operators adherence to plant procedures, including Procedure 40DP-9OP02, Conduct of Shift Operations, and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Review

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.

To assess the performance effectiveness of the licensed operator requalification program, the inspectors reviewed both the written examination and operating test quality and observed licensee administration of an annual requalification test while on-site. The operating tests observed included 15 job performance measures and four scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensees effectiveness in conducting the operating test to ensure operator mastery of the training program content and to determine if feedback of performance analyses into the requalification training program was being accomplished.

On December 23, 2016, the licensee informed the inspectors of the completed cycle results for Palo Verde Nuclear Generating Station for both the written examinations and the operating tests:

• 17 of 17 crews passed the simulator portion of the operating test

• 95 of 95 licensed operators passed the simulator portion of the operating test

• 95 of 95 licensed operators passed the job performance measure of the operating test

• 94 of 95 licensed operators passed the written examination The individual that failed the written examination was remediated, retested, and passed their retake examination.

The inspectors observed examination security measures in place during administration of the examinations (including controls and content overlap) and reviewed any remedial training and re-examinations, if necessary. The inspectors also reviewed medical records of eight licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for three operators.

The inspectors reviewed simulator performance for fidelity with the actual plant and the overall simulator program of maintenance, testing, and discrepancy correction.

The inspectors completed one inspection sample of the biennial licensed operator requalification program, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Routine Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-significant SSCs:

• January 26, 2017, shutdown cooling system valves (Unit 2 SI-653, Unit 2 SI-185, and Unit 1 SI-185), return to (a)(2) monitoring status

• February 23, 2017, diesel generator system (Unit 3 diesel generator B master rod failure), (a)(1) evaluation, placement, and goal setting

• February 23, 2017, reactor coolant system (Unit 2 pressurizer safety valve lift set point failures) (a)(1) evaluation and rejection for continued (a)(2) monitoring 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 three maintenance effectiveness samples, 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:

• January 16, 2017 - January 22, 2017, Unit 3 weekly risk assessment, elevated risk levels due to extended diesel generator B unavailability and associated compensatory risk management actions

• January 30, 2017 - February 5, 2017, Unit 1 weekly risk assessment, elevated risk levels due to high pressure safety injection valve maintenance, as well as containment spray and essential chilled water surveillance tests The inspectors verified that these risk assessment 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 three emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:

• December 4, 2016 - February 23, 2017, Unit 2 diverse auxiliary feedwater actuation system bypassed for troubleshooting

• February 23, 2017, Unit 2 pressurizer spray valve 100F troubleshooting and repair

• February 23, 2017, Unit 3 control element assembly 80 failed timer card replacement 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 SSCs.

These activities constituted completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, for the failure to establish, implement, and maintain procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Specifically, the licensee did not establish or maintain adequate procedure instructions for work authorization denials or deferrals, which led to a 60 day extended unavailability of the diverse auxiliary feedwater actuation system when corrective maintenance was inappropriately deferred by the operations department.

Description.

On December 4, 2016, Unit 2 control room operators received alarm SAYS94, DAFAS-A Test/Trouble. The operators followed alarm response procedure 40AL-9RK5B, Panel B05B Alarm Responses, Revision 22, which instructed the operators to place both diverse auxiliary feedwater actuation system (DAFAS) channels A and B in bypass to prevent an inadvertent actuation at power. The alarm response procedure also instructed the operators to initiate a condition report for Instrumentation and Controls (I&C) Department to troubleshoot and correct the system circuitry. The operators immediately initiated condition report 16-19349 to request a corrective maintenance work order to troubleshoot and repair the DAFAS system. On December 7, 2016, I&C initiated Corrective Maintenance Work Order (CMWO) 4843803 to conduct the troubleshooting and on December 13, 2016, assigned it to the fix it now (FIN) team. When the FIN team requested work authorization from the operations department, the authorization was denied by the Unit 2 Operations Manager because of an extended Diesel Generator outage on Unit 3.

The inspectors reviewed the applicable station procedure 40DP-9WP01, Operations Processing of Work Orders, Revision 32. The procedure assigns the following responsibilities to the Unit Operations Managers (UOM) in Step 2.3.1: Authorize the release of Work Orders for their respective units; and ensure that out of service equipment is returned to service in a timely manner. The inspectors also reviewed section 4.6 of the same procedure which provides instructions for performing impact review and release authorizations and did not find any supporting guidance for the UOM in performing the responsibilities detailed in Step 2.3.1. Furthermore, neither the inspectors nor the licensee located any guidance that provided instructions for contingencies when a release authorization is denied or prohibited by the UOM.

Inspector interviews with the Unit 2 Operations Manager determined that he did not have adequate technical justification for deferring the maintenance. His decision was based on incorrect assumptions which over-estimated the initiating events risk of the activity, when in fact the maintenance could be performed safely online with very low risk impact to the operating plant (green risk management action level). The I&C FIN team, system engineer, maintenance rule experts, and risk assessment staff were all aware that the work could be performed safely at power but were never consulted as part of the deferral process. No station procedure directed the UOM to consult others to ensure that his decision to defer maintenance was correct.

Discussions between the Unit 2 Operations Manager and the FIN team continued from December 15, 2016, until February 7, 2017, when the Unit 2 DAFAS CMWO was approved. The FIN team replaced two faulty fiber optic modems inside the DAFAS control cabinet, which cleared the error and the system entered a two day monitoring period in bypass to ensure that the trip and trouble alarm did not return. When the operators repositioned the DAFAS 1A bypass key on February 9, 2017, the alarm returned, so the operators left the system in bypass and requested an amendment to the CMWO to correct the bypass key issue. The bypass key was worked on February 17, 2017, and the operators opted for an extended five day monitoring period with the system remaining in bypass. The DAFAS system was fully restored on February 23, 2017.

Analysis.

Failure to provide adequate procedural guidance in the event of a denied work authorization, a circumstance anticipated to occur, is a performance deficiency. The performance deficiency is more than minor, because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability and reliability of equipment that responds to an initiating event. Specifically, because the corrective maintenance was not performed in a timely manner, both trains of the diverse auxiliary feedwater actuation system remained in bypass for an additional 60 days whereby the system was not capable of performing its required safety function.

The inspectors evaluated the significance of the finding using Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions, Section A, Question 2, which requires a detailed risk evaluation because the finding involved a loss of system safety function. A Region IV senior reactor analyst performed a detailed risk evaluation of the finding and determined that the finding was of very low safety significance (Green).

For the detailed risk evaluation, the analyst modeled anticipated transient without scram events where the auxiliary feedwater system would always fail due to the failure of the diverse auxiliary feedwater actuation system. To accomplish this, the analyst created a basic event representing the failure of the diverse auxiliary feedwater actuation system and inserted the basic event under fault tree AFW-A, Auxiliary Feedwater System, which is a fault tree used exclusively for anticipated transient without scram events. This new basic event for failure of the diverse auxiliary feedwater actuation system was set to TRUE, to model the condition. Manual initiations of the diverse auxiliary feedwater actuation system and the auxiliary feedwater system were not credited. The analyst assumed an exposure period of 80 days. These assumptions yielded an increase in core damage frequency of 3.8E-7/year from internal events. Contributions from external events were qualitatively screened because of the relatively low initiating event frequencies relative to the initiating event frequency of the dominant initiator (transients).

As a result, the total increase in core damage frequency was estimated to be very low safety significance (Green). Using Appendix H, Containment Integrity Significance Determination Process, of Manual Chapter 0609, the analyst determined that the increase in large early release frequency was 3.5E-9/year, or of very low safety significance (Green). Dominant initiators were transients which became anticipated transients without scram. Safety relief valves and the negative moderator temperature coefficient of the reactor remained to mitigate the increase in core damage frequency.

Palo Verde SPAR Model, Version 8.50, was run on SAPHIRE Version 8.1.5 with 1.0E-12 truncation to estimate the increase in core damage frequency for internal events.

The inspectors determined that the finding had a cross-cutting aspect in the human performance area of Work Management. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the Unit Operations Managers decision to deny the work authorization was based on conservative but faulty assumptions, and if other work groups had been involved, the corrective maintenance would have proceeded prior to exceeding the system Maintenance Rule performance criterion for unavailability [H.5].

Enforcement.

Palo Verde Technical Specification 5.4.1.a requires that procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, shall be established, implemented, and maintained. Section 1C of Appendix A requires procedures for equipment control. The licensee established, in part, procedure 40DP-9WP01 to meet the regulatory guide requirement. Contrary to the above, until April 11, 2017, procedure 40DP-9WP01 did not adequately establish or implement a procedure for equipment control in the event of a work authorization denial. As a result, required corrective maintenance on the diverse auxiliary feedwater actuation system was not promptly performed. The licensee initiated corrective actions under condition report 17-04957 to evaluate necessary revisions to the applicable station processes and procedures.

Because the finding is of very low safety significance, and has been entered into the licensee corrective action program, it is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000529/2017001-01 Failure to establish station procedure instructions for deferred work authorizations.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed seven operability determinations and functionality assessments that the licensee performed for degraded or nonconforming SSCs:

• January 12, 2017, Common Unit, functionality assessment of station blackout generator #2 cold start capability following ignition system fuel adjustments

• January 17, 2017, Unit 1 operability determination of spurious starts of diesel generator A and high pressure safety injection pump A

• February 8, 2017, Unit 3 operability determination of diesel generator B reliability testing requirements following engine overhaul

• February 21, 2017, Unit 3 operability determination of scaffolding impact on the Class 1E battery room B and D exhaust fans

• March 14, 2017, Unit 3 operability determination of diesel generator B following a review of applicable technical specification component condition records

• March 17, 2017, Unit 3 operability determination of main steam isolation valve 170 low nitrogen pre-charge pressure indication

• March 31, 2017, Unit 2 operability determination of diesel generator B broken bolt from 9R air manifold 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 constituted completion of seven operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

On March 28, 2017, the inspectors reviewed a temporary modification to install accelerometers on the Unit 1 shutdown cooling suction valve from reactor coolant loop 1A (SI-UV-0651) for vibration monitoring during operating cycle 20.

The inspectors verified that the licensee had installed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constituted completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed seven post-maintenance testing activities that affected risk-significant SSCs:

• January 28, 2017, Unit 3 diesel generator B 2-hour minimum loaded run followed by crank case inspection and hot torques

• February 7, 2017, Unit 3 diesel generator B 8-hour gradual incremental loaded run, hot torques, and fuel rack adjustments

• February 10, 2017, Unit 3 diesel generator B full load reject test

• February 23, 2017, Unit 2 pressurizer spray valve 100F troubleshooting and repair

• March 9, 2017, Unit 2 low pressure safety injection pump A suction valve rotor setting adjustment

• March 14, 2017, Unit 3 main steam isolation valve 170 accumulator pressure transmitter re-calibration

• March 17, 2017, diesel driven fire pump A start and run following starting motor and gland stud replacement 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 constituted completion of seven post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed eight risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

• January 26, 2017, Unit 3 essential spray pond pump A in-service test

• February 28, 2017, Unit 1 spent fuel pool cooling pump A in-service test Reactor coolant system leak detection tests:

• March 2, 2017, Unit 3 elevated reactor coolant system leak rates observed Other surveillance tests:

• January 12, 2017, station blackout generator #1 and #2 surveillance test

• January 18, 2017, Unit 1 reactor trip switchgear breaker D functional test

• January 23, 2017, Unit 3 diesel generator A surveillance test

• February 9, 2017, Unit 3 diesel generator B 24-hour fully loaded surveillance run

• March 1, 2017, SR 3.0.2 invocation and applicability during the current in-service testing program interval 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 constituted completion of eight surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

1EP1 Exercise Evaluation

a. Inspection Scope

The inspectors observed the March 7, 2017, biennial emergency preparedness exercise to verify the exercise acceptably tested the major elements of the emergency plan and provided opportunities for the emergency response organization (ERO) to demonstrate key skills and functions. The exercise demonstrated the licensees capability to implement its emergency plan by simulating:

• An operating basis earthquake affecting all three units

• A reactor coolant system leak on Unit 1 which escalated and required safety injection

• Escalation of the reactor coolant leak to a loss of coolant accident on Unit 1

• Failures in the Unit 1 containment spray system which prevented spraying the containment

• A pressure-induced failure of a Unit 1 containment penetration seal, creating a unfiltered monitored radiological release to the environment

• Dose assessment results which required additional protective action recommendations be made to offsite authorities During the exercise the inspectors observed activities in the control room simulator and the following dedicated emergency response facilities:

• Technical Support Center

• Operations Support Center

• Emergency Operations Facility

• Joint Information Center The inspectors focused their evaluation of the licensees performance on the risk-significant activities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations.

The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision-making authority and emergency function responsibilities between facilities, on-site and offsite communications, protection of emergency workers, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety, and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensees emergency response facilities, procedures for the performance of associated emergency functions, and other documents as listed in the attachment to this report.

The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended the formal presentation of critique items to plant management on March 21, 2017.

The inspectors reviewed the scenarios of previous biennial exercises and licensee drills, conducted between April 2015 and February 2017, to determine whether the March 7, 2017, exercise was independent and avoided participant preconditioning, in accordance with the requirements of 10 CFR Part 50, Appendix E, IV.F(2)(g). The inspectors also compared observed exercise performance with corrective action program entries and after-action reports for drills and exercises conducted between April 2015 and February 2017 to determine whether identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E, IV.F.

The inspectors discussed the integrated exercise with staff at the Federal Emergency Management Agency (FEMA), Region IX, to determine whether the exercise scenario supported the FEMA exercise evaluation objectives and the results continued to support that participants could adequately protect the health and safety of the public.

These activities constituted one exercise evaluation sample as defined in Inspection Procedure 71114.01.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspectors performed an in-office review of Palo Verde Nuclear Generating Station Emergency Plan, Revision 58. This revision updated course references for emergency plan training to non-ERO workers, and updated population demographic data for the area surrounding the plant.

This revision was compared to its previous revision, 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 revision 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, this revision is subject to future inspection.

These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the March 7, 2017, biennial exercise to the NRC on January 5, 2017, in accordance with the requirements of 10 CFR Part 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan, and provide opportunities for the ERO to demonstrate key skills and functions. The inspectors discussed the preliminary scenario with staff at the Federal Emergency Management Agency (FEMA), Region IX, to determine whether the preliminary scenario supported the FEMA exercise evaluation objectives.

These activities constituted completion of one exercise scenario evaluation sample as defined in Inspection Procedure 71114.08.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:

• The inspectors performed walk downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.

• The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.

• The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• During walkdowns and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis.

The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.

• Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology (NIST) traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.

• Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program and effluent releases made with inoperable radiation monitors.

• Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.

• Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, offsite dose calculation manual changes, and significant changes in reported dose values from previous years.

• Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors also verified that the licensee continued to implement the voluntary NEI/Industry Ground Water Protection Initiative. The inspectors reviewed or observed the following items:

• The inspectors observed selected air sampling and dosimeter monitoring stations, sampler station modifications, and the collection and preparation of environmental samples. The inspectors reviewed calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, and inter-laboratory comparison program results. The inspectors reviewed selected events documented in the annual environmental monitoring report and significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census. The inspectors evaluated the operability, calibration, and maintenance of meteorological instruments and assessed the meteorological dispersion and deposition factors. The inspectors verified the licensee had implemented sampling and monitoring program sufficient to detect leakage from structures, systems, or components with credible mechanism for licensed material to reach ground water, and reviewed changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

• Groundwater protection initiative (GPI) implementation, including assessment of groundwater monitoring results, identified leakage or spill events and entries made into 10 CFR 50.75

(g) records, licensee evaluations of the extent of the contamination and the radiological source term, and reports of events associated with spills, leaks, and groundwater monitoring results.

• Problem identification and resolution for the radiological environmental monitoring program. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

• Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.

• Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.

• Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors, calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.

• Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.

• Shipping records for LSA I, II, III, SCO I, II, Type A, or Type B radioactive material or radioactive waste shipments.

• Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive solid waste processing, and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.

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, 2016 through December 31, 2016, 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. 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 verification of the unplanned scrams per 7000 critical hours performance indicator for 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, 2016 through December 31, 2016, 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. 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 verification of the unplanned power outages per 7000 critical hours performance indicator for 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, 2016, and December 31, 2016. 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 verification of the unplanned scrams with complications performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors reviewed the licensees evaluated exercises, emergency plan implementations, and selected drill and training evolutions that occurred between January 2016 and December 2016 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and protective action recommendations to verify their timeliness and accuracy. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the drill/exercise performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training evolutions between January 2016 and December 2016 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees ERO in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill. The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the ERO drill participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors reviewed the licensees records of alert and notification system tests conducted between January 2016 and December 2016 to verify the accuracy of the licensees data for siren system testing opportunities. The inspectors reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the alert and notification system reliability performance indicator 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 January 15, 2017, station blackout generator system reliability 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 address the conditions.

• On March 16, 2017, maintenance activities deferred for Unit 3 license amendment 200 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 address the condition.

These activities constituted completion of two annual follow-up samples as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) at Operating Plants

(60855.1)

a. Inspection Scope

A routine ISFSI inspection was conducted of the Palo Verde Nuclear Generating Station (Palo Verde) ISFSI on February 26 - March 2, 2017, by an NRC Region IV Division of Nuclear Materials Safety inspector and two Division of Spent Fuel Management inspectors from NRC Headquarters. The inspectors observed and evaluated select licensee loading, processing, and heavy load procedures associated with the licensees current dry fuel storage loading campaign. The inspectors performed a review of the dry fuel storage records for the 18 transportable storage canisters (TSCs) loaded at the ISFSI since the last NRC inspection to verify that the licensee had loaded fuel in accordance with the NAC-UMS Universal Storage System Certificate of Compliance (CoC) Technical Specification (TS) approved contents. Documents reviewed included TSC loading plans and records containing fuel assembly specific information, such as fuel assembly serial numbers, decay heat (kW), cooling time (years), average U-235 enrichment (%), burn-up values (MWd/MTU), and other information. The canister contents reviewed during the inspection were found to meet all fuel requirements specified in the CoC.

The inspectors reviewed documentation related to maintenance of the cask handling crane, the annual maintenance of the licensees special lifting devices, and the calibration records for pressure gauges associated with fuel processing for dry cask storage. The inspectors were provided documents that demonstrated the cask handling crane was inspected on an annual basis in accordance with the requirements of the American Society of Mechanical Engineers (ASME) B30.2 standards prior to the current dry fuel loading campaign. The annual maintenance as required by American National Standards Institute (ANSI) N14.6 for special lifting devices was completed for the following special lifting devices: the SAFLIFT and the canister shield lift rig. The SAFLIFT is a device used at Palo Verde to interface between the cask handing crane main hook and the transfer cask. The SAFLIFT facilitates the transfer of the TSC from the transfer cask into the vertical concrete cask (VCC) where the TSC is stored.

Documentation reviewed included work order 4688400 and associated non-destructive examination records associated with the testing. All equipment passed the magnetic particle, liquid penetrant, and dimensional testing.

The Palo Verde ISFSI was located outside of the reactor site protected area and resided within its own protected area, approximately 0.5 miles east of the Unit 2 reactor building.

The inspectors assessed the radiological conditions of the Palo Verde ISFSI through the review of the most recent radiological survey and two years of thermoluminescent dosimeter (TLD) monitoring data from around the ISFSI pad. A radiation protection technician accompanied the NRC inspectors during their inspection of the ISFSI pad and VCCs. The pad was properly posted as a radioactive materials area. The NRC inspector carried a Ludlum Model-19 sodium-iodide survey meter (NRC #033906, calibration due July 13, 2017) and recorded confirmatory measurements on the ISFSI pad. The radiological conditions in and around the ISFSI were as expected for 142 currently loaded spent fuel storage casks. The Palo Verde ISFSI had 12 concrete pads, each with a capacity for 28 VCCs. Currently, five pads were fully loaded and a sixth pad had the two most recently loaded casks. The radiation levels on the pad ranged from background levels (approximately 3 µR/h) at the entrance to the outer fence (farthest from the loaded casks) to 1.2 mR/h between the two most recently loaded VCCs. The perimeter areas of the pads with spent measured from 50 - 200 µR/h. All accessible areas outside of the ISFSI fell below the 10 CFR 20.1502(a)(1) limit for unmonitored individuals of 500 mrem per year. Annual Radiological Environmental Operating Reports (AREORs) for Palo Verde were reviewed for the previous two years, and were produced by the Radiological Environmental Monitoring Program (REMP). Palo Verdes REMP was responsible for measuring direct radiation impacts at 50 TLD monitoring locations at both onsite and offsite locations. The TLD monitoring location with closest proximity to the ISFSI at the site boundary (TLD #17) documented the dose equivalent to any real individual located outside the site controlled area as being well below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem per year above background, due to the influence of the ISFSI.

An on-site review of the Quality Assurance (QA) audit and surveillance reports related to dry cask storage activities at Palo Verde was performed by the NRC inspectors. The QA audit report resulted in three Condition Reports (CRs) for issues determined to be adverse to quality. NRC inspectors reviewed the corrective actions described in the three CRs to ensure that the identified deficiencies were properly categorized based on their safety significance and properly resolved. The deficiencies had been properly categorized and resolved by the licensee. NRC inspectors reviewed vendor surveillance documents related to vendor inspections performed by Palo Verde personnel at NAC Industries facilities located in Norcross, GA and Ogden, UT. Notably, the vendor surveillance records documented several nonconformances related to a TSC being manufactured for use at Palo Verde. The nonconformances were adequately addressed by the vendor through removal and replacement of the nonconforming sections. The other QA surveillance reviewed by the NRC documented routine vendor inspection items. Lastly, NRC inspectors reviewed a list of ISFSI and cask handling crane CRs that were issued since the previous NRC inspection in February 2015. Of the list, 10 CRs were selected for closer review. The CRs reviewed by NRC were related to a variety of problems that arose during routine ISFSI operations. The CRs reviewed by NRC were well documented and properly categorized based on the safety significance of the identified conditions. The corrective actions taken were appropriate for the situations.

Based on the types of issued raised, the licensee demonstrated suitable attention to detail and a low threshold for problem identification. No NRC safety concerns were identified related to the audit report, vendor surveillances, or CRs reviewed.

The NRC inspectors reviewed NAC-UMS Universal Storage System daily temperature surveillance records from three randomly selected months to ensure that the NAC CoC TS 3.1.6 cask temperature surveillance requirements were being met for fuel stored on the Palo Verde ISFSI pad. The inspectors found that all the reviewed documentation demonstrated the licensee performed the required temperature surveillances with no abnormalities reported.

The licensees 10 CFR 72.212 Evaluation Report was reviewed to verify site characteristics were still bounded by the NAC-UMS Universal Storage Systems design basis. Palo Verdes 10 CFR 72.212 Evaluation Report at the time of the inspection was Revision 11, dated January 13, 2013. No revisions had been performed to the 10 CFR 72.212 Evaluation Report since the last NRC routine ISFSI inspection. As such, the Palo Verde ISFSI was found to be still bounded by the NAC-UMS design basis.

The licensees 10 CFR 72.48 screenings and evaluations for ISFSI program changes since the last NRC routine ISFSI inspection were reviewed to determine compliance with regulatory requirements. The 10 CFR 72.48 screens reviewed by NRC were primarily for basic maintenance activities associated with the ISFSI. Palo Verde had performed one 10 CFR 72.48 safety evaluation to reduce the TSC shield lid weld size from 3/8 to 5/16. The evaluation determined that NRC approval would not be required to decrease the TSC shield lid weld size down to 5/16 from 3/8. An evaluation from the vendor, NAC, was used in support of their conclusion.

The NRC inspectors determined that the licensee had not made any modifications to the cask handling crane or SAFLIFT device since the previous NRC inspection. Therefore, there were no 10 CFR 50.59 screens or evaluations associated with the cask handing crane to review. The NRC inspectors determined that all 10 CFR 72.48 screens and evaluation were adequately evaluated by the licensee.

b. Findings

No findings were identified.

.2 Temporary Instruction 2515/192, Inspection of the Licensees Interim Compensatory

Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems.

a. Inspection Scope

The objective of this performance based Temporary Instruction was to verify implementation of interim compensatory measures associated with an open phase condition design vulnerability in electric power system for operating reactors. The inspectors conducted an inspection to determine if the licensee implemented the following interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection, and protection schemes are installed and declared operable for open phase condition design vulnerability. The inspectors verified the following:

• The licensee identified and discussed with plant staff the lessons-learned from the open phase condition events at the US operating plants including the Byron Station open phase condition and its consequences. This included conducting operator training for promptly diagnosing, recognizing consequences, and responding to an open phase condition.

• The licensee updated plant operating procedures to help operators promptly diagnose and respond to open phase conditions on off-site power sources credited for safe shutdown of the plant.

• The licensee established and implemented periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible open phase condition.

• The licensee ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On December 12, 2016, the inspectors briefed Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the licensees staff, of the results of the licensed operator requalification program inspection. A final telephonic exit was conducted with Ms. Lacal and other members of the licensees staff on January 19, 2017. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On January 27, 2017, the inspectors presented the radiation safety inspection results to Mr. J. Cadogan, Senior Vice President, Nuclear Operations and Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, along with 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 February 9, 2017, the inspectors discussed the in-office review of the preliminary scenario for the 2017 biennial exercise, submitted January 5, 2017, with Mr. J. Fearn, Manager, Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented.

On March 2, 2017, the NRC exited the Palo Verde ISFSI inspection by meeting with Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other staff members. The lead inspector presented the inspection results to members of the licensee management and staff. Licensee personnel acknowledged the information presented. The inspector asked the licensee whether any materials examined during the inspection should be considered propriety.

No propriety information was identified.

On March 23, 2017, the inspectors presented the results of the on-site inspection of the biennial emergency preparedness exercise conducted March 7, 2017, to Mr. J. Cadogan, Senior Vice President, Nuclear 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 March 23, 2017, the inspectors presented the Temporary Instruction 2515/192 inspection results to Mr. J. Cadogan, Senior Vice President, Nuclear Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. No proprietary information was identified.

On April 12, 2017, the resident inspectors presented the inspection results to Mr. J. Cadogan, Senior Vice President, Nuclear 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.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Cadogan, Senior Vice President, Nuclear Operations

M. Lacal, Senior Vice President, Regulatory and Oversight

G. Andrews, Director Regulatory Affairs

R. Black, Radiation Monitoring Systems Engineer, OCS

R. Carbonneau, Acting Director, Nuclear Assurance

R. Davis, Director, Nuclear Security and Emergency Preparedness

T. Dickenson, Superintendent, Radiation Protection Operations

P. Donnelley, Senior Technician, Radiation Protection

D. Elkington, Section Leader, Compliance

J. Fearn, Manager, Emergency Preparedness

K. Graham, Director, Plant Engineering

B. Hansen, Department Leader, ISFSI Engineering

G. Haught, Senior Technician, Radiation Protection

D. Heckman, Consultant, Regulatory Affairs

K. House, Director Design Engineering

C. Kharrl, Plant General Manager for Operations

M. McGhee, Department Leader, Nuclear Regulatory Affairs

M. McLaughlin, Plant General Manager, Site Support

C. Moeller, Director, Technical Support (Acting)

M. Radspinner, Department Leader, System Engineering

B. Rash, Vice President, Engineering

H. Ridenour, Director Maintenance

R. Routolo, Manager, Radiation Protection (Acting)

C. Shelton, Supervisor, Chemistry

C. Tuma, Technician, Radiation Protection

D. Wheeler, Director Performance Improvement

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000529/2017001-01 NCV Failure to establish station procedure instructions for denial work authorizations (Section 1R13)

Closed

Inspection of the Licensees Interim Compensatory Measures 2515/192 TI Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (Section 4OA5)