IR 05000528/2019002
| ML19220B489 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/07/2019 |
| From: | John Dixon NRC/RGN-IV/DRP/RPB-D |
| To: | Bement R Arizona Public Service Co |
| References | |
| IR 2019002 | |
| Download: ML19220B489 (28) | |
Text
August 7, 2019
SUBJECT:
PALO VERDE UNITS 1, 2, 3 - INTEGRATED INSPECTION REPORT 05000528/2019002 AND 05000529/2019002 AND 05000530/2019002
Dear Mr. Bement:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Units 1, 2, 3. On July 16, 2019, the NRC inspectors discussed the results of this inspection with Mr. Todd Horton, Vice President, Site Operations and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are 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 or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Palo Verde. 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/
John L. Dixon, JR, Chief Reactor Projects Branch D
Docket Nos. 05000528 and 05000529 and 05000530 License Nos. NPF-41 and NPF-51 and NPF-74
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000528, 05000529 and 05000530
License Numbers:
Report Numbers:
05000528/2019002, 05000529/2019002 and 05000530/2019002
Enterprise Identifier: I-2019-002-0013
Licensee:
Arizona Public Service Company
Facility:
Palo Verde, Units 1, 2 and 3
Location:
Phoenix, AZ 85072-2034
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
C. Alldredge, Senior Enforcement Specialist
R. Bywater, Resident Inspector
L. Carson, Senior Health Physicist
J. Drake, Senior Reactor Inspector
P. Elkmann, Senior Emergency Preparedness Inspector
C. Peabody, Senior Resident Inspector
D. Reinert, Reactor Inspector
J. Reynoso, Resident Inspector, Diablo Canyon
D. You, Resident Inspector
Approved By:
John L. Dixon, JR, Chief
Reactor Projects Branch D
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Palo Verde Units 1, 3 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Develop Testing Program for Fuel Transfer Tubes Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000528, 05000529,05000530/2019002-01 Open/Closed None 71111.08P The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. Specifically, the licensee did not establish testing requirements and acceptance limits to detect degradation of the fuel transfer tubes as required by 10 CFR Part 50, Appendix B, Criterion XI. Failure to detect degradation of the fuel transfer tube could result in the fuel transfer tube being rendered inoperable and unable to meet its safety-related functions. The licensee entered this issue into their corrective action program as Condition Report 19-06854.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000528, 05000529,05000530/2019002-02 Design and Testing of the Fuel Oil Transfer System 71111.20 Open
PLANT STATUS
Unit 1 completed a planned refueling outage during the inspection period, but otherwise operated at or near rated thermal power.
Units 2 and 3 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 auxiliary feedwater system train A, on June 4, 2019
- (2) Unit 3 essential chilled water train A, on June 7, 2019
- (3) Unit 2 essential spray pond system train B on, June 20, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 essential spray pond system train B, on June 11, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (6 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 1 condensate storage tank, on April 4, 2019
- (2) Unit 2 train A diesel generator room, on April 9, 2019
- (3) Unit 1 train A auxiliary feedwater pump room, on June 4, 2019
- (4) Unit 2 battery rooms A, B, C, and D, on June 6, 2019
- (5) Unit 3 train A and train B essential spray pump rooms, on June 6, 2019
- (6) Unit 1 train B diesel generator room, on June 11, 2019
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities from April 8 to April 18, 2019:
03.01.a - Nondestructive Examination and Welding Activities
1. Magnetic particle examination
a. Steam generator blowdown, SG-48 weld 1 b. Steam generator blowdown, SG-48 weld 2
2. Ultrasonic examination
a. Pressurizer, pressurizer spray line weld overlay, Weld 5-30-OL b. Pressurizer, pressurizer spray line weld overlay, Weld 5-34-OL c. Steam generator blowdown, Weld 58-18R
3. Dye Penetrant Examination
a. Shutdown cooling, Line SI-72, Weld 75-1
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities
- The inspector reviewed the following visual examinations of penetrations: 1 through 16, 34 through 42, and 56 through 64
- There were no relevant indications accepted for continued service
- There were no weld repairs performed this outage
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities
The inspectors reviewed 18 condition reports and associated boric acid evaluations.
03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities
- The licensee performed:
a. 100 percent full length bobbin testing using a 0.610 inch diameter bobbin probe for all tubes b. 100 percent X-Probe inspection of all bobbin flaw-like signals at tube support structures that had bobbin indicated depth greater than 20 percent through wall c. 100 percent tube plug visual inspection from the primary side in all steam generators d. Visual inspection of the channel head hot leg and cold leg primary side in all steam generators, including all visible clad surfaces
- No in situ pressure testing was required
The inspectors reviewed 16 notifications that dealt with inservice inspections issues and found that items were entered into the corrective action program at the appropriate level and addressed correctly.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated Unit 1 operators conducting a controlled cooldown for a refueling outage on April 6, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator continuing training simulator evaluation scenario on June 18, 2019. The inspectors assessed the performance of the operators and the control room simulator.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Maintenance effectiveness and reliability of the temperature control valves for the essential chill water system (1JECATV0029, 1JECBTV0030, 2JECATV0029, 2JECBTV0030, 3JECATV0029, 3JECBTV0030)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1 outage risk assessment during reactor coolant system lowered inventory, on April 17, 2019
- (2) Unit 1 unplanned yellow shutdown safety function assessment for containment pressure and temperature control, on April 29, 2019
- (3) Unit 3 entry into loss of annunciators AOP, on June 8, 2019
- (4) Units 1, 2, and 3 online weekly risk assessment, on June 24, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (7 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Seismic qualification of diesel generator fuel instrumentation, on April 11, 2019
- (2) Unit 1 hot leg vent path foreign material exclusion cover configuration change, on April 17, 2019
- (3) Unit 1 trisodium basket minimum inventory required, on April 24, 2019
- (4) Unit 3 steam generator number 2 non-conforming check valve installed in main steam isolation valve (MSIV-171), on May 1, 2019
- (5) GE Magneblast circuit breaker operating experience review, on May 14, 2019
- (6) Unit 3 high-powered hand-held radio affecting components in the control room, on May 30, 2019
- (7) Startup transformer number 2 carbon monoxide levels in alarm, on June 6, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Unit 1 CEDMCS SG8 reset upon CEA31 removal, WO 5115984, on April 1 and 2, 2019
- (2) Unit 1 class 1E battery ammeter shunt replacement, WO 3518597, on April 15, 2019
(3)72PA-9ZZ07, Unit 1 power ascension testing following nuclear fuel design change, on May 10, 2019
- (4) WO 4962631, Unit 1, feedwater isolation valve 137 leak testing, on May 14, 2019
- (5) Unit 2 train B charging pump testing following pulsation dampener repair, WO 5144591, on June 26, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 1R21 activities from April 6 to May 9, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1 containment isolation valve inspections (SI-225, SI-542, SI-543, SI-133), on April 11 and 17, 2019
Inservice Testing (IP Section 03.01) (3 Samples)
- (1) Unit 1 train A high pressure safety injection valve inservice testing, on April 4, 2019
- (2) Unit 2 essential spray pond pump B inservice test, on June 11, 2019
- (3) Unit 3 train A diesel fuel oil transfer pump DFA-P01 in-service test per procedure 73ST-9DF01, on June 26, 2019
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1)73ST-9ZZ18, Unit 1 steam generator number 2 main steam safety valve testing, on March 25 and 26, 2019
- (2) Unit 1 diesel generator B 24-hour continuous load test, load rejection, and hot restart test, on June 10, 2019
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
The inspectors observed the licensees performance during the biennial emergency preparedness exercise conducted on March 5, 2019, and subsequently observed the presentation of exercise results to site management on March 21, 2019. The inspectors evaluated the design and conduct of the exercise, the performance of the emergency response organization, and the licensee's ability to identify weaknesses and deficiencies resulting from the exercise. The inspectors also participated in a post-exercise Public Meeting conducted by FEMA Region IX.
- (1) The exercise scenario simulated an operating basis earthquake and aftershocks, a reactor coolant system leak into containment which escalated into a loss of coolant accident, failures of the high pressure safety injection system and containment spray system, and a radiological release to the environment following a containment penetration failure.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated an emergency response drill on June 11,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) The inspectors verified the following sealed sources are accounted for and are intact:
- Unit 1 refueling outage 21 RW/RAM bag in the containment building, on April 18, 2019
- Unit 1 refueling outage 21 RW/RAM bag in the radwaste and auxiliary buildings, on April 17, 2019
- Unit 1 calibration lab bunker: two shepherd calibration sources, on April 17, 2019
High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)
- (1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Instructions to Workers (IP Section 02.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) Alarming Dosimeters
- 18-05806: Unanticipated dose rate alarm in the Unit 1 letdown heat exchanger room, on April 11, 2018
- 18-06005: SRD dose rate alarm Unit 3 Shutdown Heat Exchanger Room, on April 18, 2018
Labeling of Containers
- Unit 1 refueling outage 21 RW/RAM bag in the containment building, on April 18, 2019
- Unit 1 refueling outage 21 RW/RAM bag in the radwaste and auxiliary buildings, on April 17, 2019
- Unit 1 calibration lab bunker: two shepherd calibration sources, on April 17, 2019 Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)
- (1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
Radiological Hazard Assessment (IP Section 02.01) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
- (1) The inspectors reviewed the following:
Radiological Surveys
- 0-M-20180110-3: Calibration lab bunker, on January 10, 2018
- 0-M-20190325-2: Calibration lab bunker, on March 25, 2019
- 1-M-20190320-7: 140 RW - Neutron source room quarterly, on March 20, 2019
- 1-M-20190415-31: Unit 1 containment steam generator 1 bowl, cold leg, on April 15, 2019
- 1-M-20190415-35: Unit 1 containment steam generator 2 bowl, hot leg, on April 15, 2019
Risk Significant Radiological Work Activities
- RWP 1-3521: Safety injection check valve V217 rework and changeout, on April 7, 2019
- RWP 1-3306: Steam generator 1 pre-HEPA filter changeout, on April 18, 2019
- RWP 1-3306: Steam generator 2 pre-HEPA filter changeout, on April 16, 2019
- RWP 1-3306: Steam generator 1 and 2 Eddy current testing, on April 17, 2019
Air Sample Survey Records
- 1-19-00350: Core offload, fuel handling building bridge, on April 12, 2019
- 1-19-00352: Fuel movement, spent fuel pool, on April 12, 2019
- 1-19-00351: Core offload, fuel handling building bridge, on April 13, 2019
- 1-19-00394: Steam generator-1 pump bay room hot & cold leg diaphragms removal, on April 15, 2019
- 1-19-00459: Steam generator-2 HEPA filter area
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) Radiological work package for areas with airborne radioactivity
- RWP 1-3521: safety injection check valve V217 rework and changeout, on April 17, 2019
- RWP 1-3306: steam generator 1 pre-HEPA filter changeout, on April 18, 2019
- RWP 1-3306: Steam Generator - 2 pre-HEPA filter changeout, on April 16, 2019
- RWP 1-3306: Steam Generator 1 and 2 Eddy current testing, on April 17, 2019
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 02.03) (1 Sample)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed the following activities:
- RWP 1-3306 Primary Side Steam Generator Maintenance
- RWP 1-3319 Reactor Coolant Pump Maintenance with Motor Replacement
- RWP 1-3521 High Risk - Inboard Loop Discharge Check Valve Disassembly, Inspection and Repair
Radiation Worker Performance (IP Section 02.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during:
(1)
- Maintenance of CV217
- Steam Generator 1 & 2 Maintenance to include eddy current testing
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) April 27, 2018 through April 19, 2019
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) April 27, 2018 through April 19, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Evaluation to determine atmospheric discharge valve acoustic interference effects on Security Plan implementation
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for trends in human performance regarding questioning attitude that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Observation: Integrating Radiological Information during the Biennial Emergency Preparedness Exercise 71114.01 The inspectors observed that the emergency response organization could be more effective in integrating available radiological information about plant conditions during the March 5, 2019, exercise. Specifically, the emergency response organization was slow to recognize that a change in protective action recommendations was required when the wind shifted after the General Emergency declaration. Information was available that radiological conditions were worsening and that protective action guides were exceeded at 2 miles downwind. If that information had been used to evaluate the newly-affected downwind sector, the emergency response organization could have promptly recognized that a change in protective action recommendations was necessary, even if there was not enough information to completely define the change. A prompt recognition might have caused the dose assessment staff to take different actions and allowed the subsequent protective action recommendation to be developed more quickly. The inspectors observed that the dose assessment staff relied upon dose assessment reports as the sole indicator of the need to make protective action recommendations. The staff did not appear to apply all available radiological information to inform their understanding of the need for protective measures as the situation changed.
Observation: Emergency Response Organization Did not consider Manual Dose Assessments during an Exercise 71114.01 The inspectors observed that the emergency response organization did not consider performing a dose assessment using manual inputs when the wind shifted after the General Emergency declaration during the March 5, 2019, emergency preparedness exercise. The licensee has the capability to perform dose assessment with manual inputs and that method might have resulted in the subsequent protective action recommendation being developed more quickly. However, the inspectors observed there was no discussion in the dose assessment group about the possible benefits of the manual method, and there was no intentional decision made to wait for the next data update before performing a new dose assessment. The inspectors discussed the manual dose assessment method with licensee staff following the exercise and concluded that dose assessment staff had a bias against using the manual method and were unlikely to consider its use under other circumstances.
Observation: Repeat Performance Issues Observed during Second Emergency Response Drill 71114.06 The inspectors observed an Emergency Response Organization (ERO) Mini-Drill in the Emergency Operations Facility on June 11, 2019. The inspectors observed many of the weaknesses described as observations from the NRC graded evaluation that was performed in March 2019, but the teams observations appear above in this report. During this drill, the licensee was not able to completely and satisfactorily demonstrate the emergency classification and protective action recommendation skills.
The licensee did self-identify the missed opportunities during their critique and entered them into the corrective action program. The licensee also took immediate corrective actions to suspend qualifications and provide remedial training to ERO position players whose actions and decision making led to the unsatisfactory performance during the drill.
Furthermore, the licensee is continuing to evaluate the ongoing recent ERO drill performance issues at a high level and is taking action to provide additional training to ERO staff as well as scheduling additional drill opportunities in 2019-2020 to provide ERO staff an opportunity to improve proficiencies and verify their continuing capability to ensure adequate protection of public health and safety during an emergency.
Observation: Operator Human Performance Issue in Challenging the Unknown 71152 The inspectors have noted a trend amongst plant operators when confronted with a scenario with unknown conditions and/or uncertain consequences. The inspectors reviewed the licensees Standards and Expectations with respect to Questioning Attitude, and determined that the operators were not exhibiting fundamental human performance characteristics when it involved situations where the conditions were unknown. Their literature states that an attribute of a questioning attitude is challenging the unknown and individuals are expected to stop when faced with uncertain conditions. However, the inspectors have noted three instances where this was not demonstrated.
- On February 20, 2019, the Unit 3 operators discovered that the diesel fuel oil transfer pump B was inoperable which resulted in making the diesel generator B inoperable. In response, the control room was conducting a common cause test to verify that the diesel generator A was operable. The operators decided to make use of a procedure that would only test the operability of the diesel fuel oil transfer pump A. The inspectors questioned whether this would also cause diesel generator A to be inoperable. Despite this question, the control room proceeded to use the procedure to test the diesel fuel oil transfer pump A. An in-depth inspection found that the use of the procedure did cause a period where both trains of diesel generators were inoperable.
- On February 20, 2019, the Unit 3 diesel generator B was declared inoperable when the diesel fuel oil transfer pump B tripped shortly after starting (planned diesel fuel oil transfer pump B test). The licensee discovered a significant amount of water intrusion into the diesel fuel oil vault. This had the effect of causing excessive condensation in the fuel oil transfer pump junction box grounding the internal terminal board. Prior to this date, routine entries into diesel fuel oil vault B noted water leakage into the vault as evidenced by the presence of standing water. These were documented in condition reports (CR) 18-02885, 08-08777, and 18-18808. Additionally, two of these condition reports were classified as Not a Condition Adverse to Quality (NCAQ).
- On February 13, 2019, Unit 3 control room identified that the keying of a hand-held radio used by plant operators would affect the temperature controller for the train B control room emergency air temperature control system. The decision was made to keep the train inoperable (system was made inoperable for control valve corrective maintenance the day before). A prompt operability determination on February 14, 2019, (with input from the engineering department) determined that the system was operable/degraded. The total time between discovering this condition to when it was evaluated to be operable/degraded was approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. During this time, two shifts of control room operators did not question whether the continued use of handheld radios should be a concern to other equipment, nor did they check to see if this affected the train A controller as instructed in Procedure 40DP-9OP26, Operations Condition Reporting Process and Operability Determination/Functional Assessment, step 4.1.1.J.
The licensee has taken corrective action to address each of these three instances. The inspectors have communicated this trend to the licensee and will continue to monitor plant performance for any further trends.
Failure to Develop Testing Program for Fuel Transfer Tubes Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000528, 05000529,05000530/2019002-01 Open/Closed None 71111.08P The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. Specifically, the licensee did not establish testing requirements and acceptance limits to detect degradation of the fuel transfer tubes as required by 10 CFR Part 50, Appendix B, Criterion XI. Failure to detect degradation of the fuel transfer tube could result in the fuel transfer tube being rendered inoperable and unable to meet its safety-related functions. The licensee entered this issue into their corrective action program as Condition Report 19-06854.
Description:
During a review of the boric acid corrosion control program, the inspectors noted that a boric acid leak had been identified on the expansion joints for the fuel transfer tube outer housing, by design, the space between the fuel transfer tube and the expansion bellows is dry. The inspectors questioned the source of the boric acid. Procedure 70TI-9ZC01, Revision 21, Section 1.3, requires that the source of a boric acid leak be identified. Contrary to this requirement, the inspectors noted that the source of the boric acid leak from the fuel transfer tube bellows had never been identified. The inspectors asked for the latest test results on the fuel transfer tube to verify pressure boundary integrity. The licensee stated that no testing had been performed on the fuel transfer tube since initial construction.
Based upon a review of the Combustion Engineering Standard Safety Analysis Report and the Update Final Safety Analysis Report, the Fuel Transfer Tube Assembly has four Safety Related, Quality Related (Q) functions, including decay heat removal for the spent fuel pool and the reactor during the Fuel Transition Mode of Refueling Operations under a scenario where a loss of off-site power is assumed in conjunction with a single mechanical failure.
During this mode of operation when the core is being off loaded or re-loaded, the spent fuel pool cooling system may be augmented by one train of shutdown cooling (using either the low pressure spray injection (LPSI) or containment spray (CS) Pump) and associated auxiliaries. The shutdown cooling train in service is aligned such that it would provide cooling to both the reactor core and the spent fuel pool. Flow through the Fuel Transfer Tube PCE-M01 is credited for heat removal purposes in this case. This function was part of DMWO 00793132, Fuel Transfer Tube Assembly Subcomponent Reclassification, which was implemented in 1997. When the design and licensing basis of the Fuel Transfer Tube PCE-M01 was changed to credit it as a decay heat removal pathway, the Fuel Transfer Tube PCE-M01 and the associated Fuel Transfer Tube Assembly subcomponents were not reclassified as required by the guidance established in Regulatory Guide 1.26, Revision 1 to which the licensee is committed.
Regulatory Guidance 1.26, Quality Group Classifications And Standards For Water-, Steam-,
And Radioactive-Waste-Containing Components Of Nuclear Power Plants, Revision 1, Section C.1.b, states in part that systems or portions of systems important to safety that are designed for reactor shutdown or residual heat removal should be classified as Quality Group B. Implementation of Work order DMWO 00793132, which credited the fuel transfer tube with decay heat removal function, should have resulted in the fuel transfer tube being designated as a Quality Group B component.
Corrective Actions: The licensee has entered the issue into their corrective action program and requested Sargent & Lundy to develop this study to document the bases for the classification of the subcomponents that make up the Fuel Transfer Tube Assembly. The licensee is developing plan to locate the source of the boric acid leak and make necessary repairs, as well as determine a testing program for the fuel transfer tube.
Corrective Action References:
Condition Report 19-06854
Performance Assessment:
Performance Deficiency: Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, the licensee failed to develop a testing program for the fuel transfer tubes to ensure it remained capable of performing its functions under design conditions.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The failure to perform the required testing of the fuel transfer tubes is a performance deficiency. The performance deficiency is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems Cornerstone, and affects the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequence.
Specifically, the licensee failed to perform examinations/testing required to provide reasonable assurance that the fuel transfer tube could perform its intended function during design basis events, and therefore, maintain the ability to provide cooling to the irradiated fuel assemblies. Using NRC Inspection Manual Chapter 0609, Appendix G, Attachment 1, Exhibit 3, Mitigating Systems, the inspectors determined the finding is of very low safety significance (Green) because the finding did not involve the loss of operability or functionality of the component.
Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. Using NRC Inspection Manual Chapter 0609, Appendix G, 1, Exhibit 3, Mitigating Systems, the inspectors determined the finding is of very low safety significance (Green) because the finding was related to the qualification of the component and the component remained operable or functional.
Cross-Cutting Aspect: None The finding was not assigned a cross cutting aspect because of the age of the issue and it is not indicative of current plant performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that systems, structures, and components will perform satisfactorily in service is identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, from initial commercial operations until May 2019, the licensee failed to establish a test program to assure that all testing, required to demonstrate that the fuel transfer tubes will perform satisfactorily in service, was identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, the licensee did not establish examinations and testing required by 10 CFR Part 50 Appendix B, Criterion XI, Test Control, to detect degradation of the fuel transfer tube. Since the violation is of very low safety significance and is documented in the licensees corrective action program as Condition Report 19-06854, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Design and Testing of the Fuel Oil Transfer System 05000528, 05000529,05000530/2019002-02 71111.20
Description:
While observing excavation efforts for repairs to leaking domestic water piping the inspectors noted that there were three pipes uncovered, but that the workers had only expected two pipes to be in the location. A review of site drawings identified the third line as non-safety related piping that connected the safety related diesel fuel oil systems to each other as well as the bulk fuel oil system and associated loads in the water treatment facility.
The emergency Diesel Generator fuel oil transfer system was designed to Section III, Subsection ND of the ASME Code. The Updated Final Safety Analysis Report, Section 1.8 states that the licensee is committed to Regulatory Guide 1.137, Fuel-Oil Systems For Standby Diesel Generators, Revision 1. Section B, item e of Regulatory Guide states in part, e. Section 7.3 of ANSI N195-1976, Fuel-Oil Systems For Standby Diesel Generators, states that the arrangement of the fuel-oil system shall provide for inservice inspection and testing in accordance with ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. For those portions of the fuel-oil systems for standby diesel generators that are designed to Section III, Subsection ND of the Code, an acceptable method of meeting the requirements of Section 7.3 is to ensure that the system arrangement would allow:
- (1) Pressure testing of the fuel-oil system to a pressure 1.10 times the system design pressure at 10-year intervals. In the case of storage tanks, recommendations of the tank vendor should be taken into account when establishing the test pressure.
- (2) A visual examination to be conducted during the pressure test for evidence of component leakages, structural distress, or corrosion. In the case of buried components, a loss of system pressure during the test constitutes evidence of component leakage.
Company Correspondence ID#: 450-00575 Date: 06/18/2018, indicates that the licensee shifted to an alternative pressure test for the buried portions of the diesel fuel oil transfer system. The licensee cited ASME Section XI paragraph IWA-2240 for the proposed ultrasonic examination to determine the fuel level in the fill line. The licensee stated as justification that, ASME Code Section XI, IWA-2240 ALTERNATIVE EXAMINATIONS states, Alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods specified in this Division, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method.
In addition, ANSI N195-1976, Fuel-Oil Systems For Standby Diesel Generators, section 5.3, Multiple Reactor Unit Nuclear Stations, states in part, Multiple reactor unit nuclear stations should be designed with completely independent fuel oil systems for each unit.
Inspectors had the following questions regarding the diesel fuel oil transfer systems associated with all three units.
a. The inspector requested the licensee demonstrate that the alternative method provided results that were equivalent or superior to the method specified in Section XI of the ASME Code.
b. The inspector had questions as to whether the use of isolation valves DFBV069, DFBV021, and DFAV015 was an adequate alternative to the requirement in ANSI N195-1976, Fuel-Oil Systems For Standby Diesel Generators, section 5.3, Multiple Reactor Unit Nuclear Stations, states in part, Multiple reactor unit nuclear stations should be designed with completely independent fuel oil systems for each unit, given that the licensee is treating these valves as Category B in their IST program and Design Calculation 13-MC-DF-0306, As Built Calculation for Sizing the Diesel Fuel Storage and Day Tanks, has zero leakage allowance from these valves.
Planned Closure Actions: Review documents provided by the licensee as they are available.
Licensee Actions: The inspectors did not perceive any immediate safety or security concerns. The licensee documented the unresolved item in Condition Reports 19-05734 and 19-05914.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 18, 2019, the inspectors presented the Inservice Inspection results to M. Lacal, Senior Vice President, Regulatory and Oversight and other members of the licensee staff.
- On April 19, 2019, the inspectors presented the Occupational Safety Cornerstone Inspection IP 71124.01/02 and PI IP 71151 ORS/PRS results to M. Lacal, Senior Vice President, Regulatory and Oversight and other members of the licensee staff.
- On May 1, 2019, the inspectors presented the Inservice inspection Re-Exit to M. Kura, Department Leader of Compliance and Environmental and other members of the licensee staff.
- On June 13, 2019, the inspectors presented the Re-Exit for the Biennial Emergency Preparedness Exercise Inspection (IP71114.01) to M. Lacal, Senior Vice President, Nuclear Regulatory and Oversight and other members of the licensee staff.
- On July 16, 2019, the inspectors presented the integrated inspection results to Mr. Todd Horton, Vice President, Site Operations and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Report
19-08707, 19-09298, 19-09299
Drawings
01-M-AFP-001
P&I Diagram: Auxiliary-Feedwater System
01-M-SPP-002
P&I Diagram: Essential Spray Pond System
2-M-SPP-001
P&I Diagram Essential Spray Pond System
03-M-ECP-001
P & I Diagram Essential Chilled Water System
Miscellaneous
System Health Report: Essential Spray Pond
06/11/2019
Procedures
Locked Valve, Breaker, and Component Tracking
139
Auxiliary Feedwater Pump AFA-P01 Monthly Valve
Alignment
Work Orders
3304346
71111.05Q Corrective Action
Documents
Condition Report
19-05102, 19-05215, 19-05859, 19-05875, 19-07759,
19-08833, 19-08971, 19-10240
Drawings
01-M-DFP-001
Diesel Fuel Oil and Transfer System
01-M-DGP-001
Diesel Generator System
2-M-DFP-001
Diesel Fuel Oil and Transfer System
2-M-DGP-001
Diesel Generator System
Miscellaneous
PVNGS Pre-Fire Strategies Manual
5112780
Transient Combustible Control Permit Form
Procedures
Control of Transient Combustibles
7-Day Surveillance Test of Station Batteries
Control of Doors, Hatches, and Floor Plugs
Corrective Action
Documents
Condition Report
17-16162, 19-00979, 17-16162, 18-02532, 18-02531,
19-01692, 18-02809, 19-00666, 18-03447, 18-07850,
19-00253, 18-18823, 18-03060, 18-09495, 18-03582,
18-14146, 18-02812, 18-18821
Drawings
01-P-DFF-0701
Diesel Fuel ISO (Isometric) Markup Supply Line
03-M-DFP-001
Diesel Fuel Oil and Transfer System
DMWO 00793132
Provide Backup Air Supply to Spent Fuel Pool Transfer
Canal Gate Seal and Pump Discharge Pressure Indicator
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
APS Correspondence 476-00-575 buried portions of DF
transfer system Letter
Palo Verde Nuclear Generating Station, Unit 1 - Relief
Request No. 57 To Approve Alternate
Requirements For The Reactor Pressure Vessel Head
Nozzles To Perform A Bare Metal Examination Per ASME
2/16/2018
Safety Manual
13-MS-A166
Fuel Transfer Tube Assembly Subcomponent
Classification Evaluation
17-VT-1045
1R20 As-Found
17-VT-1103
As-Left Rx Head
40OP-9RC03, R6
RCS Leakage Source Determination
S-09-0039
50.59 Screen for permanent scaffolding
SWMS No. 17-
09564
Welding Program Self-Assessment
SWMS No. 4362861
Formal Self-Assessment of the Inservice Inspection
Program
08/16/2013
Procedures
01-C-ZAS-0623
Shutdown Heat Exchanger Room B - Excel Platform
13-CN-0380
Installation Specification for Seismic Cat IX and Non-
Seismic Scaffolding
Control of Transient Combustibles
Fire Protection Program Responsibilities, Authorities, and
Management Expectations
Day Cathodic Protection Surveillance Test of the
Diesel
Month Surveillance Test of The Diesel Fuel Storage
Tank
Fuel Oil Day Tank Accumulated Water Check
Diesel Generator A Test
Diesel Generator B Test
Boric Acid Walkdown Leak Detection
18, 19, 20,
Welding and Brazing Control
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Weld Filler Material Control
ASME Section XI Inservice Inspection
Boric Acid Corrosion Control Program
6, 7, 8
Dry Magnetic Examination
Liquid Penetrant Examination
Ultrasonic Examination of Welds in Ferritic Components
Visual Examination of Welds, Bolting, and Components
Visual Examination of Component Supports
Visual Examination of Pump and Valve Interval Surfaces
Visual Examination for Leakage
Ultrasonic Examination of Reactor Coolant Pump
Flywheels
Eddy Current Surface Examination
MN756-A00001
(PDI-UT-1_Rev_G)
PDI Generic Procedure for the Ultrasonic Examination of
Ferritic Pipe Welds
MN756-A00002
(PDI-UT-2_Rev_H)
PDI Generic Procedure for the Ultrasonic Examination of
Austenitic Pipe Welds
MN756-A00004
(PDI-UT-8_Rev H)
PDI Generic Procedure for the Ultrasonic Examination of
Weld Overlaid Similar and Dissimilar Metal Welds
MN756-A00005
(PDI-UT-10_Rev G)
PDI Generic Procedure for the Ultrasonic Examination of
Materials Reliability Program: Boric Acid Corrosion
Guidebook, Managing Boric Acid Corrosion Issues at
PWR Power Stations
PR-0904
Fire Protection Program Requirement Description
Radiation
Surveys
Visual Examination of Welds, Bolting, and Components
R14
71111.11Q Miscellaneous
Licensed Operator Continuing Training Simulator
Evaluation Scenario
04/09/2019
Technical Requirements Manual: App TA, Reactor
Coolant System Pressure and Temperature Limits Report
Procedures
Standard Post Trip Actions
Loss of Offsite Power / Loss of Forced Circulation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RCS and Pressurizer Heatup and Cooldown Rates
Corrective Action
Documents
Condition Report
18-10879, 19-02330
Miscellaneous
Palo Verde Maintenance Rule Manager Database
13-JS-A058
Assessment of Electronic Compatibility (EMC) of the 800
MHz Radio System, Digital Equipment, and Cordless
Phone with Plant Equipment
Work Orders
5040131, 5025814, 5025815, 4982926, 4954803,
4977854, 4921776, 4961977, 493351
Corrective Action
Documents
Condition Report
19-06677, 19-06681, 19-08797
Miscellaneous
Unit One 21 Refueling Outage Shutdown Risk
Assessment Final Report
04/03/2019
Shutdown Safety Function Assessment RCS Head Off
04/28/2019
3:00PM
Shutdown Safety Function Assessment RCS at Below RV
04/28/2019
9:00PM
Shutdown Safety Function Assessment RCS at Below RV
04/29/2019
3:00AM
Shutdown Safety Function Assessment RCS at Below RV
04/29/2019
9:30AM
Unit 1 Archived Operator Logs
04/29/2019
Procedures
Online Integrated Risk
Operational Risk Management
Loss of Annunciators
Shutdown Risk Management
PVNGS Refueling Outage Shutdown Risk Manager Desk
Guide
Outage GOP
Shutdown Risk Assessments
Corrective Action
Documents
Condition Report
19-02133, 19-02330, 19-02364, 19-02567, 19-04079,
19-04080, 19-04391, 19-05808, 19-05321, 19-06277,
19-07626, 19-08125
Drawings
01-M-DGP-001
Diesel Generator System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Shutdown Safety Function Assessment RCS at Below RV
04/28/2019
11:00PM
04111121DEDCATD Flowserve Raleigh: 10CFR21 Dedication of Commercial
Grade Items
13-JS-A058
Assessment of Electronic Compatibility of the 800 MHz
Radio System, Digital Equipment, and Cordless Phone
with Plant Equipment
19-02908-001
Level 3 Evaluation Report
03/29/2019
EER 89-RC-050
Breathable FME Device
04/21/1989
EER 89-RC-061
Breathable FME Device
04/27/1989
IEEE Std C57.104
IEEE Guide for the Interpretation of Gases Generated in
Oil-Immersed Transformers
2/02/2008
VTD-A391-00010
Anchor/Darling Instruction Manual for Main Steam
Isolation Valves (MSIV) and Feedwater Isolation Valves
(FWIV)
Procedures
Project Management (Procurement Management)
Operations Condition Reporting Process and Operability
Determination/Functional Assessment
ECCS Trisodium Phosphate Surveillance Test
Work Orders
4965110, 5102351
Corrective Action
Documents
Condition Report
19-04444, 19-04503, 19-05550, 19-09265, 19-09375,
19-09492, 19-09531
Engineering
Evaluations
NA-01-C22-2019-
010
Unit 1 Cycle 22 Startup Test Predictions (LPPT & PAT)
Procedures
Charging Pump Stabilizer and Discharge Pulsation
Dampener Operation
Control Element Drive Mechanism Control System
(CEDMCS) Operation
Charging Pumps - Inservice Test
Work Orders
5115984, 3518597, 5144591
Corrective Action
Documents
Condition Report
19-07265, 19-07239, 19-07130, 19-07076, 19-06681,
19-06677, 19-06471, 19-06223, 19-05808, 19-04769,
18-07701
Miscellaneous
Unit ONE 21 Refueling Outage: Shutdown Risk
04/04/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Assessment Final Report
Initial Reactor Startup Following Refuelings
Specific Maneuver
Plan
Unit 1 Cycle 21 EOC Shutdown 100% to 26.67%
Procedures
Pressurizer Manway Removal and Installation
RCS Drain Operations
Containment Cleanliness Inspection
Corrective Action
Documents
Condition Report
19-00043, 19-04774, 19-04775, 19-05913, 19-07104,
19-07094
Drawings
01-M-SPP-001
Essential Spray Pond System
01-M-SPP-002
Essential Spray Pond System
2-M-SPP-001
Essential Spray Pond System
2-M-SPP-002
Essential Spray Pond System
03-M-DFP-001
P&I Diagram Diesel Fuel Oil & Transfer System
03-M-SPP-001
Essential Spray Pond System
03-M-SPP-002
Essential Spray Pond System
Miscellaneous
Bypass Line/Margin Recovery
Procedures
Diesel Fuel Oil Transfer Pumps - Inservice Test
Class 1E Diesel Generator Load Rejection, 24 Hour Rated
Load and Hot Start Test Train B
Essential Spray Pond Pumps - Inservice Test
Train A HPSI Injection and Miscellaneous SI Valves -
Quarterly - Inservice Test
Main Steam and Pressurizer Safety Valve Set Pressure
Verification
Check Valve Non-Intrusive Testing or Examination -
Inservice Testing
Work Orders
4840248, 295973, 291105
Corrective Action
Documents
Condition Report
17-00231, 17-00502, 17-00747, 17-01447, 17-01689,
17-01961, 17-03147, 17-03149, 17-03628, 17-03632,
17-09847, 17-15409, 17-15499, 18-03367, 18-03439,
18-07564, 18-10460, 18-12940, 18-13485, 18-14077,
18-14491, 18-15127, 18-15933, 18-15954, 18-17934,
18-19004, 19-02103, 19-03288, 19-03304, 19-03306,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
19-03310, 19-03313, 19-03315, 19-03318, 19-03319,
19-03389, 19-03407-002, 19-03407-005, 19-03407-018,
19-03407-019, 19-03425, 19-03432, 19-03833, 19-03834,
19-03905, 19-03949, 19-03963, 19-03969, 19-03970,
19-03972, 19-03999, 19-04008
Miscellaneous
Summary Facts/Analysis: PVNGS Exercise-Identified
Relative to the PAR Development Process
04/08/2019
Procedures
Emergency Plan Maintenance
Emergency Preparedness Drill/Exercise Administration
Emergency Preparedness Training Program Description
Emergency Response Organization
Conduct of Operations
2A
Emergency Response Organization Position Checklists
Classifications
Notifications
Accident Assessment
ERO/ERF Activation and Operation
Protective Actions
Corrective Action
Documents
1-18-02621, 1-18-13026, A-18-14639, 1-19-02467,
1-19-05878, 1-19-04869, 18-05806 18-06005, 18-19995,
19-04951, 19-04935, 19-05818
Procedures
RP Program Overview
Radioactive Contamination Control
Managing Radiological Risk
Radiation Exposure and Access Control
Radiological Posting and Labeling
Control of High Radiation Areas, Locked High Radiation
Areas and Very High Radiation Areas
Radiation Work Permits
Radiological Surveys and Air Sampling
Conduct of R.P. Operations
Radioactive Source Control
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-
Assessments
2018-007
Audit Plan and Report Radiation Safety
218-04311
2017 Annual ALARA/Management Evaluation Report
June 21,
2018
ALARA Plans
2-3319 06
Reactor Coolant Pump Maintenance with Motor
Replacement
3-3319 07,08
Reactor Coolant Pump Maintenance with Motor
Replacement
3306
Primary Side Steam Generator Maintenance
3502 00
Valve, Flange and Pump Maintenance and Inspection
21 00
High Risk - Inboard Loop Discharge Check Valve Work
Corrective Action
Documents
Condition Report
18-17433, 19-02062, 19-05818
Procedures
ALARA Program Overview
ALARA Committee
Managing Radiological Risk
Radiation Work Permits
ALARA Reports
Radiation Work
Permits (RWPs)
1-3306
Primary Side Steam Generator Maintenance
1-3319
Reactor Coolant Pump Maintenance with Motor
Replacement
1-3502
Valve, Flange, and Pump Maintenance and Inspection
1-3521
High Risk - Inboard Loop Discharge Check Valve
Disassembly, Inspection and Repair
Corrective Action
Documents
A 19-01661, 4457080, 4457293, 4463978
Condition Report
18-18808, 18-08777, 18-02885, 19-02567, 19-02330,
19-07346, 19-02658, 19-03652, 19-09672
Miscellaneous
13-JS-A058
Assessment of Electronic Compatibility of the 800 MHz
Radio System, Digital Equipment, and Cordless Phone
with Plant Equipment
Procedures
Operations Condition Reporting Process and Operability
Determination/Functional Assessment
46