ML16117A152
| ML16117A152 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/25/2016 |
| From: | Charley Peabody NRC/RGN-IV/DRP/RPB-D |
| To: | Edington R Arizona Public Service Co |
| Josey J | |
| References | |
| IR 2016001 | |
| Download: ML16117A152 (37) | |
See also: IR 05000528/2016001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
April 25, 2016
Randall K. Edington
Executive Vice President, Nuclear/CNO
Mail Station 7602
Arizona Public Service Company
P.O. Box 52034
Phoenix, AZ 85072-2034
SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000528/2016001, 05000529/2016001, AND
Dear Mr. Edington:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On April 6, 2016, the NRC
inspectors discussed the results of this inspection with R. Bement, M. Lacal, and other members
of your staff. Inspectors documented the results of this inspection in the enclosed inspection
report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
Two of these findings involved violations of NRC requirements.
Further, inspectors documented a licensee-identified violation which was determined to be of
very low safety significance in this report. The NRC is treating this violation as non-cited
violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or significance of the NCVs, 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 e 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 Regional Administrator, Region IV; and the NRC resident inspector at the
e 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
R. Edington -2-
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/
Jeffrey E. Josey, Acting 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 05000528/2016001,
05000529/2016001, 05000530/2016001
w/ Attachment: Supplemental Information
cc w/ encl: Electronic Distribution
SUNSI Review ADAMS Non-Sensitive Publicly Available Keyword:
By: JEJ Yes No Sensitive Non-Publicly Available NRC-002
OFFICE DRP/SRI DRP/RI DRP/RI C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PS1
NAME CPeabody DReinert DYou TFarnholtz GWerner VGaddy MHaire
SIGNATURE /RA-E/ /RA-E/ /RA/ /RA/ /RA/ /RA/ /RA/
JKirkland, for
DATE 4/25/16 4/25/16 4/25/16 4/19/16 4/20/16 4/22/16 4/20/16
OFFICE C:DRS/PS2 TL:IPAT C:DRP/D
NAME HGepford THipschman JJosey
SIGNATURE /RA/ /RA/ /RA/
DATE 4/21/16 4/21/16 4/25/16
Letter to R. Edington from J. Josey dated April 25, 2016
SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000528/2016001, 05000529/2016001, AND
DISTRIBUTION:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Charles.Peabody@nrc.gov)
Resident Inspector (David.You@nrc.gov)
Resident Inspector (Dustin.Reinert@nrc.gov)
PV Administrative Assistant (Yvonne.Dubay@nrc.gov)
Acting Branch Chief, DRP/D (Jeffrey.Sowa@nrc.gov)
Senior Project Engineer, DRP (Vacant)
Project Engineer, DRP/D (Jim.Melfi@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Project Manager (Margaret.Watford@nrc.gov)
Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)
RIV RSLO (Bill.Maier@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000528, 05000529, 05000530
License: NPF-41, NPF-51, NPF-74
Report: 05000528/2016001, 05000529/2016001, 05000530/2016001
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, 2016
Inspectors: C. Peabody, Senior Resident Inspector
D. Reinert, PhD, Resident Inspector
D. You, Resident Inspector
L. Carson II, Senior Health Physicist
N. Greene, PhD, Health Physicist
Approved Jeffrey E. Josey
By: Acting Chief, Project Branch D
Division of Reactor Projects
-1- Enclosure
SUMMARY
IR 05000528, 529, 530/2016001; 01/01/20106 - 03/31/2016; PALO VERDE NUCLEAR
GENERATING STATION; Occupational Dose Assessment and Follow-up of Events and Notices
The inspection activities described in this report were performed between January 1 and
March 31, 2016, by the resident inspectors at Palo Verde Nuclear Generating Station and
inspectors from the NRCs Region IV office and other NRC offices. Two findings of very low
safety significance (Green) are documented in this report. Two of these findings involve
violations 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 documented a self-revealing non-cited violation of Technical
Specification 3.7.2 Condition A for exceeding the allowed outage time of seven days.
Specifically Unit 3s MSIV-181 actuator B was found to be inoperable from May 1, 2015 until
August 15, 2015 when a design change installed a new swivel type fitting on an air-line
without taking into account vibrational forces, as required by the stations procedure. This
eventually resulted in the fatigue failure of the fitting, depressurizing the actuator B to less
than 5000 psig. The licensee entered this condition in their corrective action program and
performed a Level 2 cause evaluation under Condition Report 15-02686.
The inspectors concluded that the failure to take into account excessive vibrational stresses
as required by procedure 81DP-0EE10, Design Change Process Step J.2.9.1, when
implementing the design change was a performance deficiency. The performance
deficiency was more than minor because it affected the equipment performance attribute of
the Mitigating Cornerstone to ensure the availability, reliability, and the capability of systems
that respond to initiating events to prevent undesirable consequences. Specifically the
failure to account for the vibrational stresses resulted in the fatigue failure of the air-line
fitting which depressurized one of two hydraulic accumulators thereby reducing the reliability
of the system to initiate a fast closure of MSIV-181 upon receipt of a Main Steam Isolation
Signal. The inspectors performed the initial significance determination using NRC Inspection
Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Issue Date:
06/19/12. The finding screened as Green since the MSIV remained capable of performing
its safety function with the alternate accumulator. The finding has a cross-cutting aspect in
the area of human performance associated with the avoid complacency component.
Specifically the licensee assumed there were no factors affecting the mechanical design
requirements beyond the performance requirements. As a result the licensee failed to
perform a thorough review of the mechanical conditions (such as vibrations) the air-line was
subjected. [H.12]
-2-
Cornerstone: Occupational Radiation Safety
- Green. A self-revealing non-cited violation of 10 CFR 20.1701 was identified for the
licensees failure to implement adequate processes or engineering controls to control the
concentration of radioactive material in air and prevent internal dose to workers.
Specifically, on April 14, 2015, the licensee implemented inadequate engineering and
radiological controls to remove a pre-filter and Y-connector from a high efficiency particulate
air (HEPA) ventilation unit resulting in an airborne radioactivity condition and two intakes.
The licensee was alerted to this issue when two radiation protection technicians alarmed
PM12 portal monitors upon their exit from the radiologically controlled area. The licensee
took immediate corrective actions and instructed these technicians to report to dosimetry for
whole body counting and evaluation. The licensee entered this issue into their corrective
action program as Condition Report (CR) CR 16-01093.
The failure to implement adequate engineering and radiological controls during HEPA unit
maintenance in accordance with procedures and the radiological exposure permit
requirements was a performance deficiency. The performance deficiency was more than
minor because it was associated with the Occupational Radiation Safety attribute of
Program and Process and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. This was evident by
two workers receiving unplanned intakes. Using IMC 0609, Appendix C, Occupational
Radiation Safety Significance Determination Process, issue date 8/19/2008, the finding was
determined to be of very low safety significance (Green) because it did not involve: (1) as
low as reasonably achievable (ALARA) planning and controls, (2) an overexposure, (3) a
substantial potential for an overexposure, or (4) an impaired ability to assess dose. The
inspectors concluded that the finding has a Conservative Bias cross-cutting aspect in the
Human Performance area because the licensee failed to use decision-making practices that
emphasized prudent choices over those that are simply allowable when they changed out
the HEPA pre-filter and Y-connector components [H.14]. (Section 2RS4)
Licensee-Identified Violations
A violations of very low safety significance that was identified by the licensee has been reviewed
by the inspectors. Corrective actions taken or planned by the licensee have been entered into
the licensees corrective action program. This violation and associated corrective action
tracking numbers are listed in Section 4OA7 of this report.
-3-
PLANT STATUS
Units 1, 2, and 3 operated at effective full power for the duration of the inspection period.
REPORT DETAILS
1R04 Equipment Alignment (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant
systems:
- January 5, 2016, Unit 3 4160V vital electrical bus A
- March 2, 2016, Unit 1 diesel generator B
- March 15, 2016, Unit 1 and Unit 3 diesel generators fuel oil head vent tanks
- March 24, 2016, Unit 2 diesel generator A fuel oil storage and transfer system
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 Walkdown
a. Inspection Scope
On March 29, 2016, the inspectors performed a complete system walk-down inspection
of the Unit 2 essential chilled water system. The inspectors reviewed the licensees
procedures and system design information to determine the correct essential chilled
water system lineup for the existing plant configuration. The inspectors also reviewed
outstanding work orders, open condition reports, temporary modifications, 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.
This activity constituted one complete system walk-down sample, as defined in
-4-
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05)
.1 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 five plant areas
important to safety:
- January 11, 2016, Unit 2 control room area, fire zone 17
- February 1, 2016, Unit 3 train A vital switchgear room, fire zone 5A
- February 16, 2016, Unit 2 diesel generator B, fire zones 21B and 22B
- February 18, 2016, Unit 3 diesel generator B, fire zone 21B
- February 18, 2016, Unit 1 diesel generator A, fire zone 21A
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 five quarterly inspection samples, as defined in Inspection
Procedure 71111.05
b. Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
On February 4, 2016, 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 that were susceptible to flooding:
- Unit 2 essential pipe chase tunnel
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
-5-
inspectors evaluated whether operator actions credited for flood mitigation could be
successfully accomplished.
This activity constitutes completion of one flood protection measure as defined in
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On January 27, 2016, 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.
This activity constitutes 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 January 19, 2016, the inspectors observed the performance of on-shift licensed
operators in the plants main control room. At the time of the observations, Unit 3 was in
a period of heightened activity due to conducting a 24-hour diesel generator B run
followed by a load rejection test and a hot start test.
In addition, the inspectors assessed the operators adherence to plant procedures,
including Conduct of Shift Operations procedure and other operations department
policies.
This activity constitutes completion of one quarterly licensed operator performance
sample, as defined in Inspection Procedure 71111.11
b. Findings
No findings were identified.
-6-
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-
related structures, systems, and components (SSCs):
- February 25, 2016, Unit 2 charging pump A, repetitive failures due to improper
finger plate installation
- March 30, 2016, Unit 2 diesel generator A, sheared support bolt for the fuel oil
head tank
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 two maintenance effectiveness samples, as
defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed four 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:
- February 8, 2016, Unit 1 weekly risk assessment
- February 15-21, 2016, Unit 3 work week 1607 risk assessment
- February 29, 2016, Unit 1 weekly risk assessment during train A super outage
- March 30, 2016, Unit 2 diesel generator B during the super outage
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.
Additionally, on March 16, 2016, the inspectors observed portions of one emergent work
activity that had the potential to affect the functional capability of mitigating systems:
-7-
- March 16, 2016, Unit 2 risk assessment revision due to discovery sheared bolt
on diesel generator A fuel oil head tank
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 five 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 (71111.15)
a. Inspection Scope
The inspectors reviewed seven operability determinations that the licensee performed
for degraded or nonconforming structures, systems, or components (SSCs):
- January 8, 2016, Unit 3 venturi fouling factor adjustment following the steam
generator #1 ultrasonic flow meter failure
- February 1, 2016, Unit 2 diesel generator A for non-qualified spray pond piping
configuration
- February 2, 2016, Unit 3 steam supply valve to auxiliary feedwater pump A
- February 2, 2016, Unit 3 diesel generator A for leaking roof hatch
- February 2, 2016, Unit 2 essential cooling water surge tank A automatic makeup
valve leaking by
- February 17, 2016, Unit 1 spray pond B return piping wall thinning
- March 2, 2016, Unit 2 auxiliary feedwater pump A trip/throttle valve for loose
mounting bolt
The inspectors reviewed the timeliness and technical adequacy of the licensees
evaluations. Where the licensee determined the degraded SSC to be operable, the
inspectors verified that the licensees compensatory measures were appropriate to
provide reasonable assurance of operability. The inspectors verified that the licensee
had considered the effect of other degraded conditions on the operability of the
degraded SSC.
These activities constitute completion of seven operability and functionality review
samples, as defined in Inspection Procedure 71111.15.
-8-
b. Findings
No findings were identified.
1R18 Plant Modifications (71111.18)
a. Inspection Scope
On March 3, 2016, the inspectors reviewed one temporary plant modification that
affected risk-significant structures, systems, and components (SSCs): Unit 1 temporary
spray pond piping configuration during diesel generator outage.
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 constitute completion of one sample of temporary modifications, as
defined in Inspection Procedure 71111.18
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
One March 15, 2016, the inspectors reviewed one permanent plant modification that
affected risk-significant structures, systems, and components (SSCs): Unit 3 main
steam isolation valve 181 actuator B air supply line vibration dampener.
The inspectors reviewed the design and implementation of the modification. The
inspectors verified that work activities involved in implementing the modification did not
adversely impact operator actions that may be required in response to an emergency or
other unplanned event. The inspectors verified that post-modification testing was
adequate to establish the operability of the SSC as modified.
These activities constitute completion of one sample of permanent modifications, as
defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
-9-
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed seven post-maintenance testing activities that affected risk-
significant structures, systems, or components (SSCs):
- February 9, 2016, Unit 1 diesel generator A, air compressor B
- February 11, 2016, station blackout generator #2 following rebuild of pre-lube
motor
- March 1, 2016, Unit 1 essential chiller A, following replacement of temperature
controllers
- March 5, 2016, Unit 1 diesel generator A, following maintenance outage
- March 16, 2016, Unit 2 diesel generator A, following replacement of fuel oil head
tank bolts
- March 19, 2016, Unit 1 charging pump B, following 12 month and 24 month
preventive maintenance activities
- March 30, 2016, Unit 2 diesel generator B following super outage
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 seven post-maintenance testing inspection
samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed five 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:
- January 25, 2016, Unit 3 auxiliary feedwater train B inservice test
- 10 -
Other surveillance tests:
- January 18, 2016, Unit 3 diesel generator B surveillance test
- February 17, 2016, Unit 2 diesel generator B surveillance test
- March 14, 2016, Unit 3 control element assembly operability check
- March 17, 2015, Unit 1 diesel generator B surveillance test
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 five surveillance testing inspection samples, as
defined in Inspection Procedure 71111.22
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
On March 1, 2016, the inspectors observed an emergency preparedness drill to verify
the adequacy and capability of the licensees assessment of drill performance. The
inspectors reviewed the drill scenario, observed the drill from the TSC, 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.
.2 Training Evolution Observation
a. Inspection Scope
On January 27, 2016, the inspectors observed simulator-based licensed operator
requalification training that included implementation of the licensees emergency plan.
The inspectors verified that the licensees emergency classifications, off-site
- 11 -
notifications, and protective action recommendations were appropriate and timely. The
inspectors verified that any emergency preparedness weaknesses were appropriately
identified by the evaluators and entered into the corrective action program for resolution.
These activities constitute completion of one training observation sample, as defined in
b. Findings
No findings were identified.
2. RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS2 Occupational ALARA Planning and Controls (71124.02)
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining individual
and collective radiation exposures as low as is reasonably achievable (ALARA). The
inspectors performed this portion of the attachment as a post-outage review. During the
inspection the inspectors interviewed licensee personnel, reviewed licensee documents,
and evaluated licensee performance in the following areas:
- Radiological work planning, including work activities of exposure significance,
and radiological work planning ALARA evaluations, initial and revised exposure
estimates, and exposure mitigation requirements. The inspectors also verified
that the licensees planning identified appropriate dose reduction techniques,
reviewed any inconsistencies between intended and actual work activity doses,
and determined if post-job (work activity) reviews were conducted to identify
lessons learned.
- Verification of dose estimates and exposure tracking systems including the basis
for exposure estimates, and measures to track, trend, and if necessary reduce
occupational doses for ongoing work activities. The inspectors evaluated the
licensees method for adjusting exposure estimates and reviewed the licensees
evaluations of inconsistent or incongruent results from the licensees intended
radiological outcomes.
- Problem identification and resolution for ALARA planning and controls. The
inspectors reviewed audits, self-assessments, work-in-progress and post-job
ALARA reviews, and corrective action program documents to verify problems
were being identified and properly addressed for resolution.
These activities constitute completion of two of the five required samples of occupational
ALARA planning and controls as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
- 12 -
2RS4 Occupational Dose Assessment (71124.04)
a. Inspection Scope
The inspectors evaluated the accuracy and operability of the licensees personnel
monitoring equipment, verified the accuracy and effectiveness of the licensees methods
for determining total effective dose equivalent, and verified that the licensee was
appropriately monitoring occupational dose. The inspectors interviewed licensee
personnel, walked down various portions of the plant, and reviewed licensee
performance in the following areas:
- External dosimetry accreditation, storage, issue, use, and processing of active
and passive dosimeters
- The technical competency and adequacy of the licensees internal dosimetry
program
- Adequacy of the dosimetry program for special dosimetry situations such as
declared pregnant workers, multiple dosimetry placement, and neutron dose
assessment
- Audits, self-assessments, and corrective action documents related to dose
assessment since the last inspection
These activities constituted five occupational dose assessment samples, as defined in
Inspection Procedure 71124.04.
b. Findings
Introduction. The inspectors reviewed a self-revealing non-cited violation (NCV)
of 10 CFR 20.1701 of very low safety significance (Green) associated with the licensees
failure to implement adequate processes or other engineering controls, to the extent
practical, to control the concentration of radioactive material in air. Specifically, the
licensee failed to mist and bag a High Efficiency Particulate Air (HEPA) ventilation unit
component, use lapel samplers, complete breathing zone air samples, and use an
appropriate radiation exposure permit (REP) task. These failures led to an airborne
radioactivity condition that resulted in two workers having intakes resulting in internal
exposures of 15.2 millirem and 9.7 millirem, respectively.
Description. On April 14, 2015, during Refueling Outage 18 for Unit 3, two radiation
protection technicians (RPTs) (one senior and one junior) were assigned to change out
the pre-filter for a HEPA stationed on the 100-foot level of the steam generator platform.
Although the assigned RPTs had performed this job in the past, the filter change out
activity was normally performed by decontamination technicians with RPT oversight.
However, the RPTs were confident that they could complete the assigned task without
an issue, and the radiation protection (RP) supervisor approved.
The tasks included removing the filter, misting it, bagging it, and disposing of the filter.
However, the same radiological and engineering controls were not implemented for the
radioactive Y-connector that was also removed from the HEPA. The two RPTs signed
- 13 -
onto REP 3-3306, Task 1, which was categorized as low radiological risk. This task
allowed the technicians to complete vacuum change outs, transport vacuums, and other
tasks authorized by an RP Leader. The task did not specify HEPA maintenance. The
HEPA maintenance was specified on Task 31 of this REP, which was categorized as a
medium radiological risk job. Task 1 of REP 3-3306 stated that continuous RP coverage
was required for change outs and identified numerous hold points for specific RP Leader
approval.
One of those hold points stated that No vacuum bag change out greater than
100 mrem/hr at 30 cm on this task. It also stated that DECON/DIRECT HANDLING OF
ITEMS > or = 1,000 mrem/hr on contact requires RP Leader authorization. The filter
removed from the HEPA was surveyed and measured 1,500 millirem per hour on
contact and 160 millirem per hour at 30 cm. Thus, based on the RP hold points for
Task 1, this job should have stopped for further RP Leader approval. Based on the
identified dose rates on the filter, additional radiological and engineering controls should
have been administered to the tasks and increased risk. The inspectors also noted that
this task did allow high radiation area entry.
The licensee confirmed in their post-evaluation that lapel samplers should have been
worn by the RPTs. In addition, breathing zone air samples should have been taken to
evaluate the airborne radioactivity in the work area once the pre-filter and aluminum
Y-connector were removed from the HEPA unit. These measures would have monitored
the airborne radioactivity concentration that the RPTs were breathing. Thus, the RPTs
failed to gain additional RP Leader approval for handling the high dose components
(filter and Y-connector), failed to wear lapel air samplers, failed to conduct breathing
zone air samples, and failed to sign in on the appropriate REP task.
Although the RPTs were incorrectly signed onto Task 1 of the REP, the inspectors
reviewed the TEDE-ALARA evaluation for Task 31 of REP 2-3306 provided by the
licensee. The evaluation estimated that the use of respirators would increase the
external dose to workers performing duties under this activity by nearly 14 percent.
Thus, respirators were not required for the task. However, the licensee stated that
internal dose for this evolution was estimated by the evaluation to be 3 millirem, on
average. The NRC inspectors determined that the estimated internal dose (3 millirem)
was not specifically documented in the evaluation reviewed. However, the RPTs
assigned to perform the HEPA pre-filter change out were not signed onto Task 31
of REP 3-3306, but rather on Task 1 of this REP, which did not have a TEDE-ALARA
evaluation. The inspectors determined the 15.2 millirem CEDE (for the senior RPT)
and 9.7 millirem CEDE (for the junior RPT) intakes were unintended or unplanned dose.
The licensee was alerted to this issue when the two RPTs exited the radiologically
controlled area and alarmed the PM12 portal monitors. The licensee took immediate
corrective actions and instructed these individuals to report to dosimetry for monitoring,
re-surveyed the areas, and conducted an extensive evaluation of the issue. The
licensee entered this issue into their corrective action program as CR16-01093.
Analysis. The failure to implement adequate engineering and radiological controls
during HEPA maintenance in accordance with procedures and the radiological exposure
permit requirements was a performance deficiency. The performance deficiency was
more than minor because it was associated with the Occupational Radiation Safety
attribute of Program and Process and adversely affected the cornerstone objective to
- 14 -
ensure the adequate protection of the worker health and safety from exposure to
radiation from radioactive material during routine civilian nuclear reactor operation. This
was evident by two workers receiving unplanned intakes. Using IMC 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, issue date
8/19/2008, the finding was determined to be of very low safety significance (Green)
because it did not involve: (1) as low as reasonably achievable (ALARA) planning and
controls, (2) an overexposure, (3) a substantial potential for an overexposure, or (4) an
impaired ability to assess dose. The inspectors concluded that the finding has a
Conservative Bias cross-cutting aspect in the Human Performance area because the
licensee failed to use decision-making practices that emphasized prudent choices over
those that are simply allowable when they changed out the HEPA pre-filter and
Y-connector components [H.14].
Enforcement. Title 10 CFR 20.1701 states, in part, that the licensee shall use, to the
extent practical, process or other engineering controls to control the concentration of
radioactive material in air. Contrary to the above, on April 14, 2015, the licensee failed
to use, to the extent practical, process or other engineering controls to control the
concentration of radioactive material in air. Specifically, the licensee failed to use the
correct REP task and follow the requirements of the assigned REP, mist and bag the
Y-connector of the HEPA, wear lapel samplers, and collect/analyze breathing zone air
samples. Consequently, the failure to use adequate radiological and engineering
controls resulted in two unplanned intakes. The licensee took immediate corrective
actions and instructed the workers to report to dosimetry for monitoring, re-surveyed the
areas, and conducted extensive evaluation of the issue. Due to these actions and no
potential for overexposures, this issue was not identified as an immediate safety
concern. Because the violation is of very low safety significance (Green) and the
licensee has entered the issue into their corrective action program as CR-1601093, this
violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC
Enforcement Policy: NCV 05000530/2016001-01, Failure to use adequate engineering
and radiological controls resulting in two unplanned intakes.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security
4OA1 Performance Indicator Verification (71151)
.1 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors reviewed licensee event reports (LERs) for the period of January, 1,
2015, through December 31, 2015 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.
- 15 -
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, 2015, through December 31, 2015, 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 January, 1, 2015, through
December 31, 2015. 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 Safety System Functional Failures (MS05)
a. Inspection Scope
For the period of January, 1, 2015, through December 31, 2015, the inspectors reviewed
licensee event reports (LERs), maintenance rule evaluations, and other records that
- 16 -
could indicate whether safety system functional failures had occurred. The inspectors
used definitions and guidance contained in Nuclear Energy Institute Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 7, and
NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to
determine the accuracy of the data reported.
These activities constituted verification of the safety system functional failures
performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection
Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152)
.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 10, 2016, Unit 2 Class 1E inverter failure apparent cause evaluation
report
- March 17, 2016, Unit 2 pressurizer level control exceed the high level limit resulting
from control valve maintenance
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.
- 17 -
These activities constitute completion of two annual follow-up samples as defined in
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
These activities constitute completion of one event follow-up sample, as defined in Inspection
Procedure 71153.
.1 (Closed) Licensee Event Report 05000530/2015-004-01, Condition Prohibited by
Technical Specification 3.0.4 and 3.7.2 Due to an Inoperable Main Steam Isolation Valve
a. Event Summary
On August 13, 2015, at approximately 9:06 p.m., the Unit 3 main steam isolation valve
181 (MSIV-181) actuator B was declared inoperable and Technical Specification (TS)
Limiting Condition for Operation (LCO) 3.7.2, Condition A, was entered due to a failed
fitting on the air supply line. To correct the condition the failed fitting was replaced and
an additional pipe support was installed on the air-line. Following retests, the MSIV-181
actuator B was restored to operable status and LCO 3.7.2, Condition A, was exited on
August 15, 2015 at approximately 6:30 p.m. On May 19, 2015, a similar air-line fitting
failure had occurred on the same component.
The licensees investigation of this condition following the second failure determined the
MSIV-181 actuator B air-line configuration was modified in the spring 2015 refueling
outage and was inoperable from Mode 4 entry on May 1, 2015, at 2:58 a.m., following
the outage because the air-line tubing was not adequately supported following the
design change. The licensee also found that a lack of a local visual inspection of actual
plant conditions resulted in the excessive vibration remaining unnoticed prior to the
component failure. The excessive vibration ultimately caused the fitting on the air
supply line to fail resulting in the inoperability of the MSIV-181 actuator B. The
inspectors reviewed the licensee event report and dispositioned this issue as a self-
revealing non-cited violation. This licensee event report is closed.
b. Findings
Introduction. The inspectors reviewed a Green self-revealing non-cited violation of
Technical Specification 3.7.2 Condition A for exceeding the allowed outage time of
seven days. Specifically, Unit 3s MSIV-181 actuator B was found to be inoperable from
May 1, 2015, until August 15, 2015, when a design change installed a new swivel type
fitting on an air-line without taking into account vibrational forces. This eventually
caused a fatigue failure of the fitting, depressurizing the accumulator B to below
5000 psig.
Description. During the April 2015, Unit 3 refueling outage, the licensee implemented a
design change which was to install a new type of swivel fitting on the air line to MSIV-
181 actuator B. The purpose of this change was to facilitate online maintenance by
replacing the rigid type fittings with swivel type fittings. As part of the design change
process, the station procedure, 81DP-0EE10 Design Change Process, requires that
- 18 -
special mechanical requirements such as vibrations be identified and addressed. The
design change documentation noted no impact to any special mechanical requirements.
Unit 3 completed their refueling outage and entered Mode 1 on May 3, 2015.
On May 19, 2015, at 4:23 a.m., the Unit 3 control room received alarms when the MSIV-
181 accumulator B pressure unexpectedly dropped below 5000 psig. The operators
entered Technical Specification 3.7.2 Condition A for an inoperable actuator train on one
MSIV. Field operators found that the new swivel type fitting had completely sheared
resulting in an air leak from accumulator B. Accumulator A was unaffected. The failed
fitting was repaired and restored to an operable status later the same day. Additionally
the licensee initiated a level 2 cause evaluation for the component failure.
During a visual walkdown of the affected air supply line, engineers noted excessive
vibrations. A walkdown other air supply lines did not exhibit such vibration. A vibrational
analysis was performed and determined that the tubing would be susceptible to fatigue
failure. Engineering analysis concluded the fitting would last for approximately 300 days
under this cyclical load. However a second fitting failure occurred on August 13, 2015,
to the same fitting. The senior reactor operator declared MSIV-181 B accumulator
inoperable and entered Technical Specification Action Statements 3.7.2 Condition A for
an inoperable actuator train. In addition to replacing the fitting a second time, the
licensee added supports to the airline to dampen vibrations. The Unit 3 senior reactor
operator declared MSIV-181 operable on August 15, 2015.
The licensees cause evaluation found that no physical walkdown was performed to
determine special mechanical requirements as required in step J.2.9.1 of procedure
81DP-0EE10, Design Change Process. A past operability evaluation concluded that
MSIV-181 accumulator B was inoperable from May 1, 2015, until August 15, 2015.
Additionally Technical Specification Limiting Condition for Operability 3.0.4 was not met
due to entry into Mode 4 with an LCO not met and the conditional requirements of LCO 3.0.4 also not met.
Analysis. The failure to take into account excessive vibrational stresses as required by
procedure 81DP-0EE10, Design Change Process step J.2.9.1, when implementing the
design change to an air-line fitting was a performance deficiency. The performance
deficiency was more-than-minor and therefore a finding because it affected the
equipment performance attribute of the Mitigating Systems Cornerstone to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically the failure to account for the vibrational
stresses resulted in the fatigue failure of the air-line fitting depressurizing one of two
hydraulic accumulators thereby reducing the reliability of the system to initiate a fast
closure of MSIV-181 upon receipt of a Main Steam Isolation Signal. The inspectors
performed the initial significance determination using NRC Inspection Manual 0609,
Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Issue Date: 06/19/12.
The finding screened as Green since the MSIV remained capable of performing its
safety function with the alternate accumulator. The finding has a cross-cutting aspect in
the area of human performance associated with the avoid complacency component.
Specifically the licensee assumed there were no factors affecting the mechanical design
requirements beyond the performance requirements. As a result the licensee failed to
perform a thorough review of the mechanical conditions (such as vibrations) the airline
was subjected. [H.12]
- 19 -
Enforcement. Technical Specification 3.7.2 requires that all four Main Steam Isolation
Valves (MSIVs) and their associated actuator trains shall be operable. Condition A
allows a single accumulator to be inoperable for a period of 7 days. Contrary to the
above a past operability determination found that Unit 3s MSIV-181 actuator B was
inoperable from May 1, 2015, to August 15, 2015. The inoperability of the actuator B
was the result of the licensee failing to account for vibrational stresses when
implementing a design change of an air-line fitting. The vibrational stresses eventually
caused the fatigue failure of the fitting resulting in the depressurization of the hydraulic
accumulator B rendering it inoperable. The licensees immediate corrective actions were
to install additional supports to dampen the vibrations of the air line and conducted an
inspection for excessive vibrations on the other pneumatic lines to ensure the problem
does not exist on any other plant components. Because this finding is of very low safety
significance and has been entered into the licensees corrective action program as
Condition Report 15-02686, this violation is being treated as a non-cited violation in
accordance with Section 2.3.2 of the Enforcement Policy: NCV 05000530/2016001-02,
Fatigue failure of a pneumatic fitting due to excessive vibrations.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On January 22, 2016, the inspectors presented the radiation safety inspection results to
Mr. G. Andrews, Director of Nuclear Regulatory Affairs, 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 April 6, 2016, the inspectors presented the inspection results to R. Bement, M. Lacal, 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.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and
is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for
being dispositioned as a non-cited violation.
- Technical Specification 5.4.1, Procedures, requires that procedures be established,
implemented, and maintained covering the applicable procedures in Regulatory Guide
1.33. Regulatory Guide 1.33, Appendix A, Section 9 requires, in part, that maintenance
that can affect the performance of safety-related equipment be properly preplanned and
performed in accordance with written procedures. Contrary to the above, prior to
October 1, 2015, licensee work management personnel failed to perform an activity
affecting quality in accordance with written procedures.
Specifically, the licensee did not conduct an adequate review of technical specification
LCO implications of a planned Unit 2 essential spray pond outage in accordance with
procedure 51DP-9OM08, Look Ahead Process. Work planners did not recognize that
the removal of two spray pond piping spool pieces was an activity required to restore
spray pond system operability and therefore did not establish a tracking mechanism to
ensure that the spool pieces were removed before the Unit 2 essential spray pond A was
- 20 -
declared operable. Consequently, the Unit 2 essential spray pond A would not have
been able to provide cooling to the essential cooling water heat exchanger following a
seismic event. The inspectors evaluated the significance of the issue under the
Significance Determination Process, as defined in Inspection Manual Chapter 0609.04,
Initial Characterization of Findings, and 0609 Appendix A, The Significance
Determination Process (SDP) for Findings at-Power, dated June 19, 2012. Inspectors
concluded the finding was of very low safety significance (Green) because all questions
in Exhibit 2 could be answered no. The licensee entered the issue into the corrective
action program as CR 15-08352. The licensee now plans and controls the removal and
re-installation of spray pond spool pieces using the stations temporary modification
process.
- 21 -
ATTACHMENT 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
R. Bement, Sr. Vice President of Nuclear Operations
M. Lacal, Sr. Vice President of Regulatory and Oversight
J. Cadogan, Vice President, Engineering
C. Kharrl, Plant General Manager for Operations
M. McLaughlin, Plant General Manager of Site Support
D. Vogt, Assistant Plant Manager Unit 2
D. Wilson, Shift Manager
H. Ridenour, Director Maintenance
G. Andrews, Director Regulatory Affairs
D. Wheeler, Director Performance Improvement
K. Graham, Director Plant Engineering
K. House, Director Design Engineering
M. McGhee, Department Leader, Nuclear Regulatory Affairs
J. Glass, Department Leader, Performance Improvement
M. Radspinner, Department Leader, System Engineering
R. Tremayne, Department Leader, Work Management
M. Hooshmand, Department Leader, Nuclear Assurance
G. Cameron, Section Leader, Nuclear Regulatory Affairs
H. Lesan, Section Leader, Performance Improvement
L. McKinney, Section Leader, Security
J. Rodriguez, Compliance Engineer
S. Dornseif, Compliance Engineer
C. Stephenson, Licensing Engineer
J. Bungard, Superintendent, Technical Support (Acting)
T. Dickinson, Unit 3 RMC Supervisor, Radiation Protection
D. Heckman, Senior Compliance Consultant, Regulatory Affairs
G. Jones, Supervisor, Radiation Protection
S. Lantz, Dosimetry Section Leader, Radiation Protection
C. Moeller, Director, Technical Support (Acting)
R. Routolo, Manager, Radiation Protection (Acting)
M. Wagner, Supervisor, ALARA and Radiation Protection
NRC Personnel
C. Peabody, Senior Resident Inspector
D. Reinert, Resident Inspector
D. You, Resident Inspector
L. Carson II, Senior Health Physicist
N. Greene, PhD. Health Physicist
A1-1 Attachment 1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000530/2015-004-01 LER Condition Prohibited by Technical Specifications 3.0.4 and 3.7.2
due to an inoperable main steam isolation valve
(Section 4OA3.1)05000530/2016001-01 NCV Failure to use adequate engineering and radiological controls
resulting in two unplanned intakes05000530/2016001-02 NCV Fatigue failure of pneumatic fitting due to excessive vibrations
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
Procedures
Number Title Revision
40OP-9PB01 4.16kV Class 1E Power (PB) 31
40OP-9DG02 Emergency Diesel Generator B 73
40OP-9DF01 Diesel Fuel Oil Storage and Transfer (DF) 42
40OP-9EC02 Essential Chilled Water Train B 29
40OP-9EC02 Essential Chilled Water Train A 30
Miscellaneous
Number Title Date
System Health Report - Essential Chilled Water September 30, 2015
Section 1R05: Fire Protection
Procedures
Number Title Revision
40AO-9ZZ19 Control Room Fire 31
14OP-9FP02 CO2 Fire Protection (CARDOX) 9
18FT-9FP39 Functional Test of Appendix A Fire/HELB Doors 0
Condition Reports (CRs)
16-02078
A1-2
Miscellaneous
Number Title Revision/Date
Pre-Fire Strategies Manual 25
Pre-Fire Strategies Manual 25
13-VTD-C285- Chemtron Low Pressure Carbon Dioxide Systems,
0005-1 Operation & Maintenance Manual, [PUB # 11B]
85-FP-110 Engineering Evaluation Request November 16, 2015
Section 1R06: Flood Protection Measures
Calculations
Number Title Revision
13-MC-ZY599 Essential Pipe Density Tunnel Flooding
Section 1R11: Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number Title Revision/Date
40DP-9OP02 Conduct of Shift Operations 68
SES-0-03-Q-09 Licensed Operator Continuing Training Simulator December 22, 2015
Evaluation Scenario
Section 1R12: Maintenance Effectiveness
Condition Reports (CRs)
15-07224 16-01437
Miscellaneous
Number Title Revision/Date
CH-1203 Maintenance Rule (a)(1) Issue Tracking Form 6
System Health Report Q4-2015
System Health Report - Diesel Generator Q4-2015
Unit 2 Maintenance Rule SSC Unavailability Report March 3, 2016
Palo Verde Maintenance Rule Manager Database
A1-3
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
Number Title Revision
40ST-9EC03 Essential Chilled Water and Ventilation Systems Inoperable 20
Actions Surveillance
70DP-0RA01 Shutdown Risk Assessments 50
Condition Reports (CRs)
16-02709 16-04066
Miscellaneous
Number Title Date
Schedulers Evaluation for PV Unit 1 February 7, 2016
Schedulers Evaluation for PV Unit 1 February 29, 2016
Schedulers Evaluation for PV Unit 2 March 16, 2016
Schedulers Evaluation for PV Unit 2 March 24, 2016
Section 1R15: Operability Determinations and Functionality Assessments
Procedures
Number Title Revision
40OP-9ZZ05 Power Operations 143
40DP-9OP26 Operations Condition Reporting Process and Operability 42
Determination/Functional Assessment
Condition Reports (CRs)
15-13087 16-00265 15-08352-002 15-08352 16-01578
06-02062 15-10486 15-10883 15-10418 16-00245
16-02578 16-01561 16-03246
Miscellaneous
Number Title Revision/Date
4732426 Engineering Evaluation January 6, 2016
M018-00322 Lube Oil Circulation Pump Motor Data
13-MC-ZZ-0217 Engineering Calculation 7
A1-4
Miscellaneous
Number Title Revision/Date
4740953 Engineering Evaluation
4723071 Engineering Evaluation
4749946 Engineering Evaluation
Section 1R18: Plant Modifications
Procedures
Number Title Revision
81DP-0DC17 Temporary modification Control 36
Work Orders
4745046
Miscellaneous
Number Title Revision
4435636 Design Equivalent Change: Alternate Air Fitting for 3
MSIV/FWIV Air check Valve Connection to Manifold
Section 1R19: Post-Maintenance Testing
Procedures
Number Title Revision
40ST-9GT03 Station Blackout Generator 2 Monthly Test 6
40ST-9DG01 Diesel Generator A Test 45
73ST-9CH06 Charging Pumps - Inservice Test 26
40ST-9DG02 Diesel Generator B Test 49
Condition Reports (CRs)
16-04066 16-04136 16-04152
Work Orders
4743659 4592359 4754245 4754870 4580405
4603460 4486471 4542945 4542965 4732477
4479572 4725145
A1-5
Section 1R22: Surveillance Testing
Procedures
Number Title Revision
73ST-9SG08 Class 1E Diesel Generator Load Rejection, 24 Hour Rated 10
Load and Hot Start Test Train B
73ST-9AF03 Auxiliary Feedwater B - Inservice Test 27
40ST-9DG02 Diesel Generator B Test 49
40ST-9SF01 CEA operability check 35
Work Orders
4575857 4580516 4589871
Section 1EP6: Drill Evaluation
Procedures
Number Title Date
SES-0-03-Q-09 Licensed Operator Continuing Training Simulator December 22, 2015
Evaluation Scenario
Section 2RS2: Occupational ALARA Planning and Controls
Procedures
Number Title Revision
75DP-0RP06 ALARA Committee 06
75DP-0RP08 Managing Radiological Risk 02
75RP-9RP02 Radiation Exposure Permits 29
75RP-9RP12 ALARA Reports 05
75RP-9RP28 Radioactive Process Filter Management 06
75TD-9RP02 ALARA Work Planning 08
75RP-9RP25 Temporary Shielding 14
75TD-9RP04 Operations Manual 06
Radiation Exposure Permits
Number Title Revision
1-3306 Primary Side Steam Generator Maintenance 01
3-3002 Reactor Destack and Restack 04
9-1021 LR Evaporator & BAC System Maintenance 03
A1-6
Radiation Exposure Permits
Number Title Revision
9-1105 Fuel Handling 01
1-3003 Reactor Vessel Head (RVH) O-Ring Maintenance and 03
Flange Inspection
2-3509 Contamination Control Outage Tasks 05
3-3306 Primary Side Steam Generator Maintenance 06
Palo Verde Condition Reports
1601058 1510580 1508339 1508336 1505025
1504942 1504939 1503936 1503147 1503090
1502333 1502221 1502040 1502034
Miscellaneous Documents
Number Title Date
Unit-3 3R18 Outage Report June 18, 2015
ALARA 5 Year Plan 2015 - 2019 November 7, 2015
PCR 4677906 UFSAR Section 12 Per Dry Cask Special Tools November 20, 2015
DMWO 4304156 ALARA Design Review HPSI Piping December 9, 2013
Unit-2 2R19 Outage Report December 22, 2015
Radiological Safety Trends December 31, 2015
Audits, Self-Assessments, and Surveillances
Number Title Date
2014 Annual ALARA/Management Evaluation Report June 29, 2015
A1-7
Section 2RS4: Occupational Dose Assessment
Procedures
Number Title Revision
75DP-0RP01 RP Program Overview 11
75DP-0RP06 Managing Radiological Risk 02
75RP-9ME21 TLD Issue, Exchange and Termination 13
75RP-9ME23 Exposure Evaluation for Lost, Damaged, or Suspect Dosimetry, 12
and Anticipated EPD Dose Rate Alarm
75RP-9ME24 Dosimetry Processing, Evaluation, and Documentation 05
75RP-9ME25 TLD Reader Calibration and Response Check 06
75RP-9RP02 Radiation Exposure Permits 29
75RP-9RP03 Bioassay Analysis 10
75RP-9RP05 Contamination Dose Evaluation 07
75RP-9RP16 Special Dosimetry 20
Audits, Self-Assessments, And Surveillances
Number Title Date
100536-0 NVLAP Onsite Assessment Summary May 6, 2014
218-03732- 2013 Annual Radiation Protection Program Summary May 30, 2014
TSG/GRN Report
Palo Verde Condition Reports
1501820 1502248 1503644 1505076 1507237
1508308 1508385 1508590 1508823 1509662
1509732 1510410 1510844 1510977 1511554
1511845 1601093
Radiation Exposure Permits (REPs)
Number Title Revision
1-3003 Reactor Vessel Head (RVH) O-Ring Maintenance and Flange 03
Inspection
2-3509 Contamination Control Outage Tasks 05
3-3306 Primary Side Steam Generator Maintenance 06
A1-8
Miscellaneous Documents
Number Title Revision/Date
Dosimetry Program Quality Manual 16
Dosimetry Comparison Failures 2015
100536-0/F, G 2014 NVLAP Proficiency Testing Report June 13, 2014
2-3306-31 TEDE/ALARA Evaluation July 23, 2015
100536-0/H, I 2014 NVLAP Proficiency Testing Report August 15, 2014
TLD Reader TLD Reader Calibration and Response Check September 24, 2015
No. 468119
100536-0 NVLAP Certificate of Accreditation to ISO/IEC October 1, 2015
17025:2005
Waste Stream Report: Unit 1 Dry Active Waste January 5, 2016
Waste Stream Report: Unit 2 Dry Active Waste January 5, 2016
Waste Stream Report: Unit 3 Dry Active Waste January 5, 2016
218-03946- Fourth Quarter 2015 ISFSI Area TLD Monitoring January 7, 2016
JER Results
TLD Reader TLD Reader Calibration and Response Check January 15, 2016
No. 256069
Section 4OA1: Performance Indicator Verification
Miscellaneous Documents
Number Title Revision
NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7
Section 4OA2: Problem Identification and Resolution
Condition Reports (CRs)
4654418 4639503 4650188 4650483
A1-9
Attachment 2
The following items are requested for the
Occupational Radiation Safety Inspection
Integrated Report 2016-001
at
Palo Verde Nuclear Station
(January 19-22, 2016)
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 8, 2016
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1- A, applicable organization charts in file/folder 1- B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at (817)200-1221,
Louis.Carson@nrc.gov or Natasha Greene at (817)200-1154, Natasha.Greene@nrc.gov
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
A2-1 Attachment 2
2. Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection: April 17, 2015
A. List of contacts and telephone numbers for ALARA program personnel
B. Applicable organization charts
C. Copies of audits, self-assessments, and LERs, written since date of last inspection,
focusing on ALARA
D. Procedure index for ALARA Program
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Committee
3. Radiation Work Permit Preparation
F. A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the ALARA program. In addition
to ALARA, the summary should also address Radiation Work Permit violations,
Electronic Dosimeter Alarms, and RWP Dose Estimates
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that the
inspector can perform word searches.
G. List of work activities greater than 1 rem, since date of last inspection
Include original dose estimate and actual dose.
H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of
record)
I. Outline of source term reduction strategy
J. If available, provide a copy of the ALARA outage report for the most recently completed
outages for each unit
K. Please provide your most recent Annual ALARA Report.
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection: April 17, 2015
A. List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
B. Applicable organization charts
A2-2
C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1. Occupational Dose Assessment
D. Procedure indexes for the following areas
1. Occupational Dose Assessment
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
3. Personnel Dosimetry Program
4. Radiological Posting and Warning Devices
5. Air Sample Analysis
6. Performance of High Exposure Work
7. Declared Pregnant Worker
8. Bioassay Program
F. List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
4. Bioassays or internally deposited radionuclides or internal dose
5. Neutron dose
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that the
inspector can perform word searches.
G. List of positive whole body counts since date of last inspection, names redacted if
desired
H. Part 61 analyses/scaling factors
I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)
accreditation report or, if dosimetry is provided by a vendor, the vendors most recent
results
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
A2-3