IR 05000528/2007004: Difference between revisions

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{{Adams|number = ML073180736}}
{{Adams
| number = ML073180736
| issue date = 11/08/2007
| title = IR 05000528-07-004, 05000529-07-004, 05000530-07-004; 07/01/07 - 09/30/07; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Force-On-Force Exercise Eval., Follow-up of Events
| author name = Farnholtz T R
| author affiliation = NRC/RGN-IV/DRP/RPB-D
| addressee name = Edington R K
| addressee affiliation = Arizona Public Service Co
| docket = 05000528, 05000529, 05000530
| license number = NPF-041, NPF-051, NPF-074
| contact person =
| document report number = IR-07-004
| document type = Inspection Report, Inspection Report Correspondence
| page count = 36
}}


{{IR-Nav| site = 05000528 | year = 2007 | report number = 004 }}
{{IR-Nav| site = 05000528 | year = 2007 | report number = 004 }}
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===w/Attachment:===
===w/Attachment:===
Supplemental Informationcc w/enclosure:Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007Douglas K. Porter, Senior CounselSouthern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770ChairmanMaricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003Aubrey V. Godwin, DirectorArizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040Dwight Mims, Vice PresidentRegulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034Jeffrey T. WeikertAssistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901John W. SchumannLos Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Arizona Public Service Company-3-John TaylorPublic Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224Geoffrey M. CookSouthern California Edison Company 5000 Pacific Coast Hwy, Bldg. D21 San Clemente, CA 92672Robert HenrySalt River Project 6504 East Thomas Road Scottsdale, AZ 85251Brian AlmonPublic Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326Karen O' ReganEnvironmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Matthew BenacAssistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Arizona Public Service Company-4-Electronic distribution by RIV:Regional Administrator (EEC)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (GXW2)Branch Chief, DRP/D (TRF)Senior Project Engineer, DRP/D (RLN1)Senior Project Engineer, DRP/D (GEW)Team Leader, DRP/TSS (CJP)RITS Coordinator (MSH3)Only inspection reports to the following:DRS STA (DAP)V. Dricks, PAO (VLD)D. Pelton, OEDO RIV Coordinator (DLP)ROPreports PV Site Secretary (PRC)SUNSI Review Completed: _TRF_____ADAMS: YesG No Initials: TRF______ Publicly Available G Non-Publicly AvailableG Sensitive Non-SensitiveR:\_REACTORS\_PV\2007\PV2007-004RP-GGW.wpdRIV:RI:DRP/DRI:DRP/DSRI:DRP/DSRA:DRSC:DRS/EB2JFMelfiMCattsGGWarnickMFRunyanLJSmithE-TRFT-TRFT-TRF/RA//RA/10/29/0710/29/0710/29/0711/06/0711/01/07 C:DRS/PSBC:DRS/OBC:DRS/EB1C:DRP/DMPShannonATGodyWBJonesTRFarnholtz/RA//RA/KClayton for/RA//RA/11/01/0711/01/0711/05/0710/08/07OFFICIAL RECORD COPYT=Telephone E=E-mail F=Fax Enclosure-1-U.S. NUCLEAR REGULATORY COMMISSION REGION IVDockets:50-528, 50-529, 50-530Licenses:NPF-41, NPF-51, NPF-74 Report:05000528/2007004, 05000529/2007004, 05000530/2007004 Licensee:Arizona Public Service Company Facility:Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location:5951 S. Wintersburg RoadTonopah, ArizonaDates:July 1 through September 30, 2007 Inspectors:J. Bartleman, Reactor Inspector, Region IIIJ. Bashore, Resident Inspector M. Bloodgood, Project Engineer M. Catts, Resident Inspector S. Makor, Reactor Inspector D. Melendez-Colon, Reactor Inspector, Region III J. Melfi, Resident Inspector J. Reynoso, Reactor Inspector A. Sanchez, Resident Inspector G. Warnick, Senior Resident InspectorApproved By:Thomas R. Farnholtz, Chief, Project Branch DDivision of Reactor Projects Enclosure-2-
Supplemental Informationcc w/enclosure:Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007Douglas K. Porter, Senior CounselSouthern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770ChairmanMaricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003Aubrey V. Godwin, DirectorArizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040Dwight Mims, Vice PresidentRegulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034Jeffrey T. WeikertAssistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901John W. SchumannLos Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Arizona Public Service Company-3-John TaylorPublic Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224Geoffrey M. CookSouthern California Edison Company 5000 Pacific Coast Hwy, Bldg. D21 San Clemente, CA 92672Robert HenrySalt River Project 6504 East Thomas Road Scottsdale, AZ 85251Brian AlmonPublic Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326Karen O' ReganEnvironmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Matthew BenacAssistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Arizona Public Service Company-4-Electronic distribution by RIV:Regional Administrator (EEC)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (GXW2)Branch Chief, DRP/D (TRF)Senior Project Engineer, DRP/D (RLN1)Senior Project Engineer, DRP/D (GEW)Team Leader, DRP/TSS (CJP)RITS Coordinator (MSH3)Only inspection reports to the following:DRS STA (DAP)V. Dricks, PAO (VLD)D. Pelton, OEDO RIV Coordinator (DLP)ROPreports PV Site Secretary (PRC)SUNSI Review Completed: _TRF_____ADAMS: Yes G No Initials: TRF______ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:\_REACTORS\_PV\2007\PV2007-004RP-GGW.wpdRIV:RI:DRP/DRI:DRP/DSRI:DRP/DSRA:DRSC:DRS/EB2JFMelfiMCattsGGWarnickMFRunyanLJSmithE-TRFT-TRFT-TRF/RA//RA/10/29/0710/29/0710/29/0711/06/0711/01/07 C:DRS/PSBC:DRS/OBC:DRS/EB1C:DRP/DMPShannonATGodyWBJonesTRFarnholtz/RA//RA/KClayton for/RA//RA/11/01/0711/01/0711/05/0710/08/07OFFICIAL RECORD COPYT=Telephone E=E-mail F=Fax Enclosure-1-U.S. NUCLEAR REGULATORY COMMISSION REGION IVDockets:50-528, 50-529, 50-530Licenses:NPF-41, NPF-51, NPF-74 Report:05000528/2007004, 05000529/2007004, 05000530/2007004 Licensee:Arizona Public Service Company Facility:Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location:5951 S. Wintersburg RoadTonopah, ArizonaDates:July 1 through September 30, 2007 Inspectors:J. Bartleman, Reactor Inspector, Region IIIJ. Bashore, Resident Inspector M. Bloodgood, Project Engineer M. Catts, Resident Inspector S. Makor, Reactor Inspector D. Melendez-Colon, Reactor Inspector, Region III J. Melfi, Resident Inspector J. Reynoso, Reactor Inspector A. Sanchez, Resident Inspector G. Warnick, Senior Resident InspectorApproved By:Thomas R. Farnholtz, Chief, Project Branch DDivision of Reactor Projects Enclosure-2-


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
....................................................3REACTOR SAFETY.........................................................51R01Adverse Weather Protection...................................... 51R04Equipment Alignment............................................ 61R05Fire Protection................................................. 71R06Flood Protection Measures....................................... 81R11Licensed Operator Requalification Program........................... 81R12Maintenance Effectiveness....................................... 91R13Maintenance Risk Assessments and Emergent Work Control..............91R15Operability Evaluations......................................... 101R19Post-Maintenance Testing........................................111R20Refueling and Other Outage Activities.............................. 121R22Surveillance Testing.............................................131EP6Drill Evaluation................................................ 141EP7Force-On-Force Exercise Evaluation............................... 14OTHER ACTIVITIES....................................................... 164OA1Performance Indicator Verification................................. 164OA2Identification and Resolution of Problems........................... 174OA3Followup of Events and Notices of Enforcement Discretion...............184OA6  Meetings, Including Exit..........................................21ATTACHMENT: SUPPLEMENTAL INFORMATION...............................A-1
IR 05000528/2007004, 05000529/2007004, 05000530/2007004; 07/01/07 - 09/30/07; PaloVerde Nuclear Generating Station, Units 1, 2, and 3; Force-On-Force Exercise Eval., Follow-up of Events.This report covered a 3-month period of inspection by resident inspectors. The inspectionidentified two findings. The significance of most findings is indicated by their color (Green,White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management's review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.


KEY POINTS OF CONTACT................................................A-1LIST OF DOCUMENTS REVIEWED..........................................A-2 LIST OF ACRONYMS.....................................................A-11 Enclosure-3-SUMMARY OF FINDINGSIR 05000528/2007004, 05000529/2007004, 05000530/2007004; 07/01/07 - 09/30/07; PaloVerde Nuclear Generating Station, Units 1, 2, and 3; Force-On-Force Exercise Eval., Follow-up of Events.This report covered a 3-month period of inspection by resident inspectors. The inspectionidentified two findings. The significance of most findings is indicated by their color (Green,White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process."  Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management's review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.NRC-Identified and Self-Revealing Findings
===NRC-Identified and Self-Revealing Findings===


===Cornerstone: Initiating Events===
===Cornerstone: Initiating Events===
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====a. Inspection Scope====
====a. Inspection Scope====
Partial WalkdownThe inspectors: (1) walked down portions of the two below listed risk important systemsand reviewed plant procedures and documents to verify that critical portions of the selected systems were correctly aligned; and (2) compared deficiencies identified during the walk down to the licensee's Updated Final Safety Analysis Report (UFSAR) and corrective action program (CAP) to ensure problems were being identified and corrected. *July 25, 2007, Unit 1, emergency diesel generator (EDG) Train B while EDGTrain A was out of service for preplanned maintenance*August 23, 2007, Unit 2, containment spray Train B while Train A was out ofservice for preplanned maintenanceDocuments reviewed by the inspectors are listed in the attachment.
Partial WalkdownThe inspectors:
: (1) walked down portions of the two below listed risk important systemsand reviewed plant procedures and documents to verify that critical portions of the selected systems were correctly aligned; and
: (2) compared deficiencies identified during the walk down to the licensee's Updated Final Safety Analysis Report (UFSAR) and corrective action program (CAP) to ensure problems were being identified and


The inspectors completed two samples.Complete WalkdownThe inspectors: (1) reviewed plant procedures, drawings, the UFSAR, technicalspecifications (TSs), and vendor manuals to determine the correct alignment of the essential and non-essential auxiliary feedwater (AFW) systems; (2) reviewed outstanding design issues, operator work arounds, and UFSAR documents to determine if open issues affected the functionality of the AFW systems; and (3) verified that the licensee was identifying and resolving equipment alignment problems.*July 16, 2007, Unit 2, essential AFW system Trains A and B
corrected. *July 25, 2007, Unit 1, emergency diesel generator (EDG) Train B while EDGTrain A was out of service for preplanned maintenance*August 23, 2007, Unit 2, containment spray Train B while Train A was out ofservice for preplanned maintenanceDocuments reviewed by the inspectors are listed in the attachment.
 
The inspectors completed two samples.Complete WalkdownThe inspectors:
: (1) reviewed plant procedures, drawings, the UFSAR, technicalspecifications (TSs), and vendor manuals to determine the correct alignment of the essential and non-essential auxiliary feedwater (AFW) systems;
: (2) reviewed outstanding design issues, operator work arounds, and UFSAR documents to determine if open issues affected the functionality of the AFW systems; and
: (3) verified that the licensee was identifying and resolving equipment alignment problems.*July 16, 2007, Unit 2, essential AFW system Trains A and B
*July 17, 2007, Unit 2, non-essential AFW system Train N Documents reviewed by the inspectors are listed in the attachment.
*July 17, 2007, Unit 2, non-essential AFW system Train N Documents reviewed by the inspectors are listed in the attachment.


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====a. Inspection Scope====
====a. Inspection Scope====
Quarterly InspectionThe inspectors walked down the seven below listed plant areas to assess the materialcondition of active and passive fire protection features and their operational lineup and readiness. The inspectors: (1) verified that transient combustibles and hot work activities were controlled in accordance with plant procedures; (2) observed the condition of fire detection devices to verify they remained functional; (3) observed fire suppression systems to verify they remained functional and that access to manual actuators was unobstructed; (4) verified that fire extinguishers and hose stations were provided at their designated locations and that they were in a satisfactory condition; (5) verified that passive fire protection features (electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration seals, and oil collection systems) were in a satisfactory material condition; (6) verified that adequate compensatory measures were established for degraded or inoperable fire protection features and that the compensatory measures were commensurate with the significance of the deficiency; and (7) reviewed the UFSAR to determine if the licensee identified and corrected fire protection problems. *July 12, 2007, Unit 3, fuel building 100 foot, 120 foot, and 140 foot elevations  
Quarterly InspectionThe inspectors walked down the seven below listed plant areas to assess the materialcondition of active and passive fire protection features and their operational lineup and readiness. The inspectors:
: (1) verified that transient combustibles and hot work activities were controlled in accordance with plant procedures;
: (2) observed the condition of fire detection devices to verify they remained functional;
: (3) observed fire suppression systems to verify they remained functional and that access to manual actuators was unobstructed;
: (4) verified that fire extinguishers and hose stations were provided at their designated locations and that they were in a satisfactory condition;
: (5) verified that passive fire protection features (electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration seals, and oil collection systems) were in a satisfactory material condition;
: (6) verified that adequate compensatory measures were established for degraded or inoperable fire protection features and that the compensatory measures were commensurate with the significance of the deficiency; and
: (7) reviewed the UFSAR to determine if the licensee identified and corrected fire protection problems. *July 12, 2007, Unit 3, fuel building 100 foot, 120 foot, and 140 foot elevations  
*July 27, 2007, Unit 2, spray pond pump house, 108 foot elevation
*July 27, 2007, Unit 2, spray pond pump house, 108 foot elevation
*July 30, 2007, diesel and electrical driven fire pump rooms
*July 30, 2007, diesel and electrical driven fire pump rooms
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors: (1) reviewed the UFSAR, the flooding analysis, and plant procedures toassess seasonal susceptibilities involving external flooding; (2) reviewed the UFSAR and CAP to determine if the licensee identified and corrected flooding problems; (3) inspected underground bunkers/manholes to verify the adequacy of (a) sump pumps, (b) level alarm circuits, (c) cable splices subject to submergence, and (d) drainage for bunkers/manholes; (4) verified that operator actions for coping with flooding can reasonably achieve the desired outcomes; and (5) walked down the two below listed areas to verify the adequacy of: (a) equipment seals located below the floodline, (b) floor and wall penetration seals, (c) watertight door seals, (d) common drain lines and sumps, (e) sump pumps, level alarms, and control circuits, and (f) temporary or removable flood barriers. *July 30, 2007, Unit 1, spray pond Pump B
The inspectors:
: (1) reviewed the UFSAR, the flooding analysis, and plant procedures toassess seasonal susceptibilities involving external flooding;
: (2) reviewed the UFSAR and CAP to determine if the licensee identified and corrected flooding problems;
: (3) inspected underground bunkers/manholes to verify the adequacy of
: (a) sump pumps,
: (b) level alarm circuits,
: (c) cable splices subject to submergence, and
: (d) drainage for bunkers/manholes;
: (4) verified that operator actions for coping with flooding can reasonably achieve the desired outcomes; and
: (5) walked down the two below listed areas to verify the adequacy of:
: (a) equipment seals located below the floodline,
: (b) floor and wall penetration seals,
: (c) watertight door seals,
: (d) common drain lines and sumps,
: (e) sump pumps, level alarms, and control circuits, and
: (f) temporary or removable flood barriers. *July 30, 2007, Unit 1, spray pond Pump B
*July 30, 2007, Units 1, 2, and 3, EDG fuel oil storage tank vaultsDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.
*July 30, 2007, Units 1, 2, and 3, EDG fuel oil storage tank vaultsDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.


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No findings of significance were identified.
No findings of significance were identified.
{{a|1R11}}
{{a|1R11}}
==1R11 Licensed Operator Requalification Program (71111.11)==
==1R11 Licensed Operator Requalification Program==
{{IP sample|IP=IP 71111.11}}


====a. Inspection Scope====
====a. Inspection Scope====
On August 22, 2007, the inspectors observed testing and training of senior reactoroperators and reactor operators (ROs) to identify deficiencies and discrepancies in thetraining, to assess operator performance, and to assess the evaluator's critique. Thetraining scenario involved three events including: (1) failure of volume control tank levelinstrument; (2) EDG actuation on loss of Class 1E Bus; and (3) loss of offsite power.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.
On August 22, 2007, the inspectors observed testing and training of senior reactoroperators and reactor operators (ROs) to identify deficiencies and discrepancies in thetraining, to assess operator performance, and to assess the evaluator's critique. Thetraining scenario involved three events including:
: (1) failure of volume control tank levelinstrument;
: (2) EDG actuation on loss of Class 1E Bus; and
: (3) loss of offsite power.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the below listed maintenance activity to: (1) verify theappropriate handling of structure, system, and component (SSC) performance or condition problems; (2) verify the appropriate handling of degraded SSC functional performance; (3) evaluate the role of work practices and common cause problems; and (4) evaluate the handling of SSC issues reviewed under the requirements of the maintenance rule, 10 CFR Part 50 Appendix B, and the TSs. *August 20, 2007, Unit 1, EDG Train A voltage permissive relay failure, asdocumented in Corrective Maintenance Work Order (WO) 3043473Documents reviewed by the inspectors are listed in the attachment.
The inspectors reviewed the below listed maintenance activity to:
: (1) verify theappropriate handling of structure, system, and component (SSC) performance or condition problems;
: (2) verify the appropriate handling of degraded SSC functional performance;
: (3) evaluate the role of work practices and common cause problems; and
: (4) evaluate the handling of SSC issues reviewed under the requirements of the maintenance rule, 10 CFR Part 50 Appendix B, and the TSs. *August 20, 2007, Unit 1, EDG Train A voltage permissive relay failure, asdocumented in Corrective Maintenance Work Order (WO) 3043473Documents reviewed by the inspectors are listed in the attachment.


The inspectors completed one sample.
The inspectors completed one sample.
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No findings of significance were identified.
No findings of significance were identified.
{{a|1R13}}
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)==
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13}}


====a. Inspection Scope====
====a. Inspection Scope====
Risk Assessment and Management of RiskThe inspectors reviewed the two below listed assessment activities to verify: (1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) andlicensee procedures prior to changes in plant configuration for maintenance activitiesand plant operations; (2) the accuracy, adequacy, and completeness of the informationconsidered in the risk assessment; (3) that the licensee recognizes, and/or enters asapplicable, the appropriate licensee-established risk category according to the riskassessment results and licensee procedures; and (4) the licensee identified andcorrected problems related to maintenance risk assessments.
Risk Assessment and Management of RiskThe inspectors reviewed the two below listed assessment activities to verify:
: (1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) andlicensee procedures prior to changes in plant configuration for maintenance activitiesand plant operations;
: (2) the accuracy, adequacy, and completeness of the informationconsidered in the risk assessment;
: (3) that the licensee recognizes, and/or enters asapplicable, the appropriate licensee-established risk category according to the riskassessment results and licensee procedures; and
: (4) the licensee identified andcorrected problems related to maintenance risk assessments.


*August 1, 2007, Unit 2, risk assessment and management during scheduledEDG Train A outage*August 28, 2007, Units 1, 2 and 3, risk assessment and management duringscheduled station blackout Generator 1 outageDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed two samples.
*August 1, 2007, Unit 2, risk assessment and management during scheduledEDG Train A outage*August 28, 2007, Units 1, 2 and 3, risk assessment and management duringscheduled station blackout Generator 1 outageDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed two samples.


-10-Emergent Work ControlThe inspectors: (1) verified that the licensee performed actions to minimize theprobability of initiating events and maintained the functional capability of mitigating systems and barrier integrity systems; (2) verified that emergent work-related activities such as troubleshooting, work planning/scheduling, establishing plant conditions, aligning equipment, tagging, temporary modifications, and equipment restoration did not place the plant in an unacceptable configuration; and (3) reviewed the UFSAR to determine if the licensee identified and corrected risk assessment and emergent work control problems. *July 26 - 27, 2007, Unit 1, extended out of service time for essential chill watersystem Train A due to the discovery of a design issue with the Trico Oiler on the circulating pump bearing housing*July 30, 2007, Units 1, 2, and 3, elevated plant risk due to a severe thunderstormwarning*August 11, 2007, Unit 1, containment spray Train B piping system voids *August 30, 2007, Unit 2, troubleshooting effort to fix ground fault relay of motorgenerator Set B via WO 3055461*September 4, 2007, Unit 1, EDG Train B inoperable due to fuel oil transfer pumpcycling *September 13, 2007, Unit 2, replacement of EDG Train B lube oil filters viaWO 3061974*September 18 - 20, 2007, Unit 1, troubleshooting and repair efforts for steamGenerator 2 steam supply to AFA-P01 bypass Valve SGAUV0138ADocuments reviewed by the inspectors are listed in the attachment.The inspectors completed seven samples.
-10-Emergent Work ControlThe inspectors:
: (1) verified that the licensee performed actions to minimize theprobability of initiating events and maintained the functional capability of mitigating systems and barrier integrity systems;
: (2) verified that emergent work-related activities such as troubleshooting, work planning/scheduling, establishing plant conditions, aligning equipment, tagging, temporary modifications, and equipment restoration did not place the plant in an unacceptable configuration; and
: (3) reviewed the UFSAR to determine if the licensee identified and corrected risk assessment and emergent work control problems. *July 26 - 27, 2007, Unit 1, extended out of service time for essential chill watersystem Train A due to the discovery of a design issue with the Trico Oiler on the circulating pump bearing housing*July 30, 2007, Units 1, 2, and 3, elevated plant risk due to a severe thunderstormwarning*August 11, 2007, Unit 1, containment spray Train B piping system voids  
*August 30, 2007, Unit 2, troubleshooting effort to fix ground fault relay of motorgenerator Set B via WO 3055461
*September 4, 2007, Unit 1, EDG Train B inoperable due to fuel oil transfer pumpcycling *September 13, 2007, Unit 2, replacement of EDG Train B lube oil filters viaWO 3061974*September 18 - 20, 2007, Unit 1, troubleshooting and repair efforts for steamGenerator 2 steam supply to AFA-P01 bypass Valve SGAUV0138ADocuments reviewed by the inspectors are listed in the attachment.The inspectors completed seven samples.


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R15}}
{{a|1R15}}
==1R15 Operability Evaluations (71111.15)==
==1R15 Operability Evaluations==
{{IP sample|IP=IP 71111.15}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors: (1) reviewed plant status documents such as operator shift logs,emergent work documentation, deferred modifications, and night orders to determine ifan operability evaluation was warranted for degraded components; (2) referred to the  
The inspectors:
-11-UFSAR and design basis documents to review the technical adequacy of licenseeoperability evaluations; (3) evaluated compensatory measures associated withoperability evaluations; (4) determined degraded component impact on any TSs; (5)used the Significance Determination Process to evaluate the risk significance ofdegraded or inoperable equipment; and (6) verified that the licensee has identified andimplemented appropriate corrective actions associated with degraded components.*July 19, 2007, Units 1, 2, and 3, operability determination associated withrequired minimum volume of trisodium phosphate contained in the storagebaskets inside containment*July 25, 2007, Unit 1, essential chiller Train A design issue associated with theTrico Oiler*August 9, 2007, Unit 2, Class 1E battery charger high voltage alarm dropout settoo high as described in Palo Verde Action Request (PVAR) 3048575*September 13, 2007, Unit 2, EDG Train B turbo lube oil filters degradingdischarge pressure trend*September 20, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testing due to foreign material and its potential transportabilityDocuments reviewed by the inspectors are listed in the attachment.
: (1) reviewed plant status documents such as operator shift logs,emergent work documentation, deferred modifications, and night orders to determine ifan operability evaluation was warranted for degraded components;
: (2) referred to the  
-11-UFSAR and design basis documents to review the technical adequacy of licenseeoperability evaluations;
: (3) evaluated compensatory measures associated withoperability evaluations;
: (4) determined degraded component impact on any TSs; (5)used the Significance Determination Process to evaluate the risk significance ofdegraded or inoperable equipment; and
: (6) verified that the licensee has identified andimplemented appropriate corrective actions associated with degraded components.
 
*July 19, 2007, Units 1, 2, and 3, operability determination associated withrequired minimum volume of trisodium phosphate contained in the storagebaskets inside containment
*July 25, 2007, Unit 1, essential chiller Train A design issue associated with theTrico Oiler
*August 9, 2007, Unit 2, Class 1E battery charger high voltage alarm dropout settoo high as described in Palo Verde Action Request (PVAR) 3048575*September 13, 2007, Unit 2, EDG Train B turbo lube oil filters degradingdischarge pressure trend*September 20, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testing due to foreign material and its potential transportabilityDocuments reviewed by the inspectors are listed in the attachment.


The inspectors completed five samples.
The inspectors completed five samples
.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors selected the six below listed post-maintenance test activities of risksignificant systems or components. For each item, the inspectors: (1) reviewed the applicable licensing basis and/or design-basis documents to determine the safety functions; (2) evaluated the safety functions that may have been affected by the maintenance activity; and (3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test  
The inspectors selected the six below listed post-maintenance test activities of risksignificant systems or components. For each item, the inspectors:
-12-equipment was removed, the system was properly re-aligned, and deficiencies duringtesting were documented. The inspectors also reviewed the UFSAR to determine if the licensee identified and corrected problems related to post maintenance testing. *May 15 - 24, 2007, Unit 1, testing associated with detector replacement forstartup Channels 1 and 2 detectors*July 25 - 26, 2007, Unit 1, EDG Train A per Procedure 40ST-9DG01,"Diesel Generator A Test," Revision 30*July 30, 2007, Unit 1, high pressure safety injection Valve 1JSIAUV0666 perWOs 2946259, 2855494, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 3, 2007, Unit 3, low pressure safety injection Valve 3-JSIAUV0645 perWOs 2855772, 2948743, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 08, 2007, Unit 3, Procedure 77ST-9SB07, "CPC Channel A FunctionalTest," Revision 9, following maintenance*August 27, 2007, overspeed test of station blackout Generator 1 followingmaintenanceDocuments reviewed by the inspectors are listed in the attachment.
: (1) reviewed the applicable licensing basis and/or design-basis documents to determine the safety functions;
: (2) evaluated the safety functions that may have been affected by the maintenance activity; and
: (3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test  
-12-equipment was removed, the system was properly re-aligned, and deficiencies duringtesting were documented. The inspectors also reviewed the UFSAR to determine if the licensee identified and corrected problems related to post maintenance testing.
 
*May 15 - 24, 2007, Unit 1, testing associated with detector replacement forstartup Channels 1 and 2 detectors
*July 25 - 26, 2007, Unit 1, EDG Train A per Procedure 40ST-9DG01,"Diesel Generator A Test," Revision 30*July 30, 2007, Unit 1, high pressure safety injection Valve 1JSIAUV0666 perWOs 2946259, 2855494, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 3, 2007, Unit 3, low pressure safety injection Valve 3-JSIAUV0645 perWOs 2855772, 2948743, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 08, 2007, Unit 3, Procedure 77ST-9SB07, "CPC Channel A FunctionalTest," Revision 9, following maintenance*August 27, 2007, overspeed test of station blackout Generator 1 followingmaintenanceDocuments reviewed by the inspectors are listed in the attachment.


The inspectors completed six samples.
The inspectors completed six samples.
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====a. Inspection Scope====
====a. Inspection Scope====
Unit 1 Refueling Outage 13The inspectors reviewed the following risk significant refueling items or outage activitiesto verify defense in depth commensurate with the outage risk control plan, compliance with the TSs, and adherence to commitments in response to Generic Letter 88-17,
Unit 1 Refueling Outage 13The inspectors reviewed the following risk significant refueling items or outage activitiesto verify defense in depth commensurate with the outage risk control plan, compliance with the TSs, and adherence to commitments in response to Generic Letter 88-17, "Loss of Decay Heat Removal:"
"Loss of Decay Heat Removal:" (1) the risk control plan; (2) tagging/clearance activities; (3) reactor coolant system (RCS) instrumentation; (4) electrical power; (5) decay heat removal; (6) spent fuel pool cooling; (7) inventory control; (8) reactivity control; (9) containment closure; (10) reduced inventory or mid-loop conditions; (11) refueling  
: (1) the risk control plan;
-13-activities; and (12) licensee identification and implementation of appropriate correctiveactions associated with refueling and outage activities. The containment inspections included observations of the containment sump for damage and debris; and supports, braces, and snubbers for evidence of excessive stress, water hammer, or aging.Documents reviewed by the inspectors are listed in the attachment.
: (2) tagging/clearance activities;
: (3) reactor coolant system (RCS) instrumentation;
: (4) electrical power;
: (5) decay heat removal;
: (6) spent fuel pool cooling;
: (7) inventory control;
: (8) reactivity control;
: (9) containment closure;
: (10) reduced inventory or mid-loop conditions;
: (11) refueling  
-13-activities; and
: (12) licensee identification and implementation of appropriate correctiveactions associated with refueling and outage activities. The containment inspections included observations of the containment sump for damage and debris; and supports, braces, and snubbers for evidence of excessive stress, water hammer, or aging.Documents reviewed by the inspectors are listed in the attachment.


The inspectors completed one sample.
The inspectors completed one sample.
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the UFSAR, procedure requirements, and TSs to ensure thatthe four below listed surveillance activities demonstrated that the SSCs tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate: (1) preconditioning; (2) evaluation of testing impact on the plant; (3) acceptance criteria; (4) test equipment; (5) procedures; (6) jumper/lifted lead controls; (7) test data; (8) testing frequency and method to demonstrate TS operability; (9) test equipment removal; (10) restoration of plant systems; (11) fulfillment of ASME Code requirements; (12) updating of performance indicator data; (13) engineering evaluations, root causes, and bases for returning tested SSCs not meeting the test acceptance criteria were correct; (14) reference setting data; and (15) annunciators and alarms setpoints. The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing. *June 16 - 17, 2007  Unit 1, shiftly surveillances per Procedure 40ST-9ZZM6,"Operations Mode 6 Surveillance Logs," Revision 15 *July 24, 2007, Unit 3, Procedures 73ST-9AF02, "AFA-P01 Inservice Test,"Revision 39, and 73ST-9XI38, "AF Pumps Discharge Check Valves - Inservice Test," Revision 14  *August 28, 2007, Unit 2, Procedure 40ST-9RC02, "ERFDADS (Preferred)Calculation of RCS Water Inventory," Revision 43 *August 29, 2007, Unit 2, Procedure 74ST-9RC02, "RCS Specific ActivitySurveillance Test," Revision 11 Documents reviewed by the inspectors are listed in the attachment.
The inspectors reviewed the UFSAR, procedure requirements, and TSs to ensure thatthe four below listed surveillance activities demonstrated that the SSCs tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate:
: (1) preconditioning;
: (2) evaluation of testing impact on the plant;
: (3) acceptance criteria;
: (4) test equipment;
: (5) procedures;
: (6) jumper/lifted lead controls;
: (7) test data;
: (8) testing frequency and method to demonstrate TS operability;
: (9) test equipment removal;
: (10) restoration of plant systems;
: (11) fulfillment of ASME Code requirements;
: (12) updating of performance indicator data;
: (13) engineering evaluations, root causes, and bases for returning tested SSCs not meeting the test acceptance criteria were correct;
: (14) reference setting data; and
: (15) annunciators and alarms setpoints. The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing. *June 16 - 17, 2007  Unit 1, shiftly surveillances per Procedure 40ST-9ZZM6,"Operations Mode 6 Surveillance Logs," Revision 15 *July 24, 2007, Unit 3, Procedures 73ST-9AF02, "AFA-P01 Inservice Test,"Revision 39, and 73ST-9XI38, "AF Pumps Discharge Check Valves - Inservice Test," Revision 14  *August 28, 2007, Unit 2, Procedure 40ST-9RC02, "ERFDADS (Preferred)Calculation of RCS Water Inventory," Revision 43 *August 29, 2007, Unit 2, Procedure 74ST-9RC02, "RCS Specific ActivitySurveillance Test," Revision 11 Documents reviewed by the inspectors are listed in the attachment.


The inspectors completed four samples.
The inspectors completed four samples.
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====a. Inspection Scope====
====a. Inspection Scope====
For the below listed drill contributing to Drill/Exercise Performance (DEP) andEmergency Response Organization (ERO) Performance Indicators, the inspectors:  
For the below listed drill contributing to Drill/Exercise Performance (DEP) andEmergency Response Organization (ERO) Performance Indicators, the inspectors:
(1) observed the training evolution to identify any weaknesses and deficiencies in classification, notification, and Protective Action Requirements (PAR) development activities; (2) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying failures; and (3) determined  whether licensee performance is in accordance with the guidance of the NEI 99-02, "Voluntary Submission of Performance Indicator Data," acceptance criteria. *August 16, 2007, ERO exercise scenario Guide 07-D-FAC-08008 Documents reviewed by the inspectors are listed in the attachment.
: (1) observed the training evolution to identify any weaknesses and deficiencies in classification, notification, and Protective Action Requirements (PAR) development activities;
: (2) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying failures; and
: (3) determined  whether licensee performance is in accordance with the guidance of the NEI 99-02, "Voluntary Submission of Performance Indicator Data," acceptance criteria. *August 16, 2007, ERO exercise scenario Guide 07-D-FAC-08008 Documents reviewed by the inspectors are listed in the attachment.


The inspectors completed one sample.
The inspectors completed one sample.
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====a. Inspection Scope====
====a. Inspection Scope====
For the drill listed below, inspectors: (1) reviewed any Emergency Preparedness (EP)corrective actions identified during previous Force-On-Force (FOF) exercises that would be demonstrated during the current FOF exercise; (2) observed the EP portion of the FOF exercise to identify any weaknesses and deficiencies in classification, notification, and PAR activities; and (3) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying and correcting failures.*August 22, 2007, EP portion of the FOF exercise Documents reviewed by the inspectors are listed in the attachment.
For the drill listed below, inspectors:
: (1) reviewed any Emergency Preparedness (EP)corrective actions identified during previous Force-On-Force (FOF) exercises that would be demonstrated during the current FOF exercise;
: (2) observed the EP portion of the FOF exercise to identify any weaknesses and deficiencies in classification, notification, and PAR activities; and
: (3) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying and correcting failures.*August 22, 2007, EP portion of the FOF exercise Documents reviewed by the inspectors are listed in the attachment.


The inspectors completed one sample.
The inspectors completed one sample.
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=====Description.=====
=====Description.=====
During the August 22, 2007, EP portion of the FOF exercise, the inspectorsobserved that the shift manager (SM) failed to declare a Notice of Unusual Event(NOUE) even though the Emergency Action Level (EAL) conditions existed. The SMentered Procedure EPIP-09, "E-Plan Implementation for Security Events," Revision 10,when conditions existed that posed a credible threat to the facility. This proceduredirected the SM to enter Procedure 40AO-9ZZ24, "Deliberate Acts Against PVNGS,"Revision 17, and to classify the event per Procedure EPIP-99, "Emergency ActionsLevels," Appendix A, Revision 15. Procedure EPIP-99, Appendix A, EAL 7-1, states todeclare a NOUE when a credible Site-Security Threat Notification condition exists. TheSM failed to make this declaration. The subsequent critique conducted by the licensee'sorganization failed to identify the missed classification by the SM for correction, resultingin the performance deficiency. In addition, the licensee's exercise evaluators did notadequately prepare evaluation objectives before the start of the exercise whichcontributed to the failure to recognize the opportunity to declare the NOUE.Analysis. The performance deficiency associated with this finding involved the failure ofthe licensee's critique process to identify for correction an emergency plan weakness associated with a risk significant planning standard. This finding is more than minor because it is associated with the Emergency Response Organization Performance attribute of the Emergency Preparedness Cornerstone and affects the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Inaccordance with Manual Chapter 0609, "Significance Determination Process,"Appendix B, Emergency Preparedness Significance Determination Process, this findingis determined to have very low safety significance because, although it was a failure tocomply with NRC requirements, it did not involve the risk significant aspects of aplanning standard as defined in Manual Chapter 0609, Appendix B, Section 2.0; andwas not a planning standard functional failure because the critique failure occurred in asmall scale drill with limited ERO participation and evaluation. This finding has acrosscutting aspect in the area of problem identification and resolution associated withcorrective action program because the threshold for identifying issues was not sufficiently low. Specifically, the emergency planning evaluator did not recognize the SM's failure to make the NOUE classification during the FOF exercise. Therefore, the exercise critique did not identify and correct the event classification deficiency as required by 10 CFR 50, Appendix E, IV(F)(2)(g) (P.1(a)).
During the August 22, 2007, EP portion of the FOF exercise, the inspectorsobserved that the shift manager (SM) failed to declare a Notice of Unusual Event(NOUE) even though the Emergency Action Level (EAL) conditions existed. The SMentered Procedure EPIP-09, "E-Plan Implementation for Security Events," Revision 10,when conditions existed that posed a credible threat to the facility. This proceduredirected the SM to enter Procedure 40AO-9ZZ24, "Deliberate Acts Against PVNGS,"Revision 17, and to classify the event per Procedure EPIP-99, "Emergency ActionsLevels," Appendix A, Revision 15. Procedure EPIP-99, Appendix A, EAL 7-1, states todeclare a NOUE when a credible Site-Security Threat Notification condition exists. TheSM failed to make this declaration. The subsequent critique conducted by the licensee'sorganization failed to identify the missed classification by the SM for correction, resultingin the performance deficiency. In addition, the licensee's exercise evaluators did notadequately prepare evaluation objectives before the start of the exercise whichcontributed to the failure to recognize the opportunity to declare the NOUE.Analysis. The performance deficiency associated with this finding involved the failure ofthe licensee's critique process to identify for correction an emergency plan weakness associated with a risk significant planning standard. This finding is more than minor because it is associated with the Emergency Response Organization Performance attribute of the Emergency Preparedness Cornerstone and affects the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.
 
Inaccordance with Manual Chapter 0609, "Significance Determination Process,"Appendix B, Emergency Preparedness Significance Determination Process, this findingis determined to have very low safety significance because, although it was a failure tocomply with NRC requirements, it did not involve the risk significant aspects of aplanning standard as defined in Manual Chapter 0609, Appendix B, Section 2.0; andwas not a planning standard functional failure because the critique failure occurred in asmall scale drill with limited ERO participation and evaluation. This finding has acrosscutting aspect in the area of problem identification and resolution associated withcorrective action program because the threshold for identifying issues was not sufficiently low. Specifically, the emergency planning evaluator did not recognize the SM's failure to make the NOUE classification during the FOF exercise. Therefore, the exercise critique did not identify and correct the event classification deficiency as required by 10 CFR 50, Appendix E, IV(F)(2)(g) (P.1(a)).


=====Enforcement.=====
=====Enforcement.=====
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====a. Inspection Scope====
====a. Inspection Scope====
Cornerstone:  Barrier IntegrityThe inspectors sampled licensee submittals for the two performance indicators listedbelow for the period September 1, 2006, to July 31, 2007, for Units 1, 2, and 3. The definitions and guidance of Nuclear Energy Institute 99-02,"Regulatory Assessment Indicator Guideline," Revision 2, were used to verify the licensee's basis for reporting each data element in order to verify the accuracy of PI data reported during the assessment period. The inspectors: (1) reviewed RCS chemistry sample analyses for dose equivalent Iodine-131 and compared the results to the TS limit; (2) observed a chemistry technician obtain and analyze a RCS sample; (3) reviewed operating logs and surveillance results for measurements of RCS identified leakage; and (4) observed a surveillance test that determined RCS identified leakage. Licensee performanceindicator data were also reviewed against the requirements of Procedures 93DP-0LC09,"Data Collection and Submittal Using INPO's Consolidated Data Entry System,"Revision 6, 73DP-9PP01, "Thermal Performance Monitoring and Evaluation Process," Revision 4, and 70DP-0PI01, "Performance Indicator Data Mitigating Systems Cornerstone," Revision 3.*RCS Specific Activity  
Cornerstone:  Barrier IntegrityThe inspectors sampled licensee submittals for the two performance indicators listedbelow for the period September 1, 2006, to July 31, 2007, for Units 1, 2, and 3. The definitions and guidance of Nuclear Energy Institute 99-02,"Regulatory Assessment Indicator Guideline," Revision 2, were used to verify the licensee's basis for reporting each data element in order to verify the accuracy of PI data reported during the assessment period. The inspectors:
: (1) reviewed RCS chemistry sample analyses for dose equivalent Iodine-131 and compared the results to the TS limit;
: (2) observed a chemistry technician obtain and analyze a RCS sample;
: (3) reviewed operating logs and surveillance results for measurements of RCS identified leakage; and
: (4) observed a surveillance test that determined RCS identified leakage. Licensee performanceindicator data were also reviewed against the requirements of Procedures 93DP-0LC09,"Data Collection and Submittal Using INPO's Consolidated Data Entry System,"Revision 6, 73DP-9PP01, "Thermal Performance Monitoring and Evaluation Process," Revision 4, and 70DP-0PI01, "Performance Indicator Data Mitigating Systems Cornerstone," Revision 3.*RCS Specific Activity  
-17-*RCS LeakageThe inspectors completed six samples.Documents reviewed by the inspectors are listed in the attachment.
-17-*RCS LeakageThe inspectors completed six samples.Documents reviewed by the inspectors are listed in the attachment.


====b. Findings====
====b. Findings====
No findings of significance were identified.4OA2Identification and Resolution of Problems (71152).1Routine Review of Identification and Resolution of ProblemsThe inspectors performed a daily screening of items entered into the licensee's CAP. This assessment was accomplished by reviewing daily summary reports for PVARs and CRDRs, and attending corrective action review and work control meetings. The inspectors: (1) verified that equipment, human performance, and program issues were being identified by the licensee at an appropriate threshold and that the issues were entered into the CAP; (2) verified that corrective actions were commensurate with the significance of the issue; and (3) identified conditions that might warrant additional follow-up through other baseline inspection procedures.
No findings of significance were identified.4OA2Identification and Resolution of Problems (71152).1Routine Review of Identification and Resolution of ProblemsThe inspectors performed a daily screening of items entered into the licensee's CAP. This assessment was accomplished by reviewing daily summary reports for PVARs and CRDRs, and attending corrective action review and work control meetings. The inspectors:
: (1) verified that equipment, human performance, and program issues were being identified by the licensee at an appropriate threshold and that the issues were entered into the CAP;
: (2) verified that corrective actions were commensurate with the significance of the issue; and
: (3) identified conditions that might warrant additional follow-up through other baseline inspection procedures.


===.2 Multiple/Repetitive Degraded Cornerstone Column and Crosscutting Issues Follow-upActivitiesIn the NRC's Annual Assessment Letter of Palo Verde dated March 2, 2007, the NRCindicated that improvement efforts in addressing the substantive crosscutting issuesthrough baseline inspections would be monitored, including a detailed assessment===
===.2 Multiple/Repetitive Degraded Cornerstone Column and Crosscutting Issues Follow-upActivitiesIn the NRC's Annual Assessment Letter of Palo Verde dated March 2, 2007, the NRCindicated that improvement efforts in addressing the substantive crosscutting issuesthrough baseline inspections would be monitored, including a detailed assessment===
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====a. Inspection Scope====
====a. Inspection Scope====
Event Follow-UpThe inspectors reviewed the below listed degraded condition for plant status andmitigating actions to: (1) provide input in determining the appropriate agency response in accordance with Management Directive 8.3, "NRC Incident Investigation Program;"
Event Follow-UpThe inspectors reviewed the below listed degraded condition for plant status andmitigating actions to:
(2) evaluate performance of mitigating systems and licensee actions; and (3) confirm that the licensee properly classified the event in accordance with emergency action level procedures and made timely notifications to NRC and state/governments, as required.*September 20 - 28, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testingDocuments reviewed by the inspectors are listed in the attachment.
: (1) provide input in determining the appropriate agency response in accordance with Management Directive 8.3, "NRC Incident Investigation Program;"
: (2) evaluate performance of mitigating systems and licensee actions; and
: (3) confirm that the licensee properly classified the event in accordance with emergency action level procedures and made timely notifications to NRC and state/governments, as required.*September 20 - 28, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testingDocuments reviewed by the inspectors are listed in the attachment.


The inspectors completed one sample.Personnel Performance   The inspectors: (1) reviewed operator logs, plant computer data, and/or strip charts forthe below listed evolution to evaluate operator performance in coping with non-routineevents and transients; (2) verified that operator actions were in accordance with theresponse required by plant procedures and training; and (3) verified that the licenseehas identified and implemented appropriate corrective actions associated with personnelperformance problems that occurred during the non-routine evolutions sampled. *On July 7, 2007, Unit 1, the RCS was taken below atmospheric pressure whilelowering pressurizer level. A pressurizer cooldown, purge, and level reduction had been performed to support pressurizer manway removal and RCS drain to  
The inspectors completed one sample.Personnel Performance The inspectors:
: (1) reviewed operator logs, plant computer data, and/or strip charts forthe below listed evolution to evaluate operator performance in coping with non-routineevents and transients;
: (2) verified that operator actions were in accordance with theresponse required by plant procedures and training; and
: (3) verified that the licenseehas identified and implemented appropriate corrective actions associated with personnelperformance problems that occurred during the non-routine evolutions sampled. *On July 7, 2007, Unit 1, the RCS was taken below atmospheric pressure whilelowering pressurizer level. A pressurizer cooldown, purge, and level reduction had been performed to support pressurizer manway removal and RCS drain to  
-19-establish conditions for emergent check valve maintenance. During turnover,the oncoming operations shift recognized that RCS pressure was less than atmospheric and took action to increase RCS pressure to atmospheric conditions and recover pressurizer level. Pressurizer level stabilized to a partial drain condition of 6 percent once atmospheric conditions were restored. This event was documented in CRDR 3038774.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.
-19-establish conditions for emergent check valve maintenance. During turnover,the oncoming operations shift recognized that RCS pressure was less than atmospheric and took action to increase RCS pressure to atmospheric conditions and recover pressurizer level. Pressurizer level stabilized to a partial drain condition of 6 percent once atmospheric conditions were restored. This event was documented in CRDR 3038774.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.


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=====Introduction.=====
=====Introduction.=====
A Green self-revealing NCV of TS 5.4.1.a was identified for the failure ofoperations personnel to follow procedures to establish appropriate conditions prior to lowering pressurizer level, resulting in a partial vacuum condition in the RCS.Description. On July 5, 2007, during refueling Outage 1R13, safety injection systemcheck Valve SIE-V123 failed a surveillance test while the unit was in Mode 3. The unit had to be returned to Mode 5 with the RCS partially drained to establish plant conditions needed to conduct repairs. On July 7, 2007, operations personnel performed a cooldown and purge of the pressurizer in accordance with Procedure 40OP-9ZZ06,
A Green self-revealing NCV of TS 5.4.1.a was identified for the failure ofoperations personnel to follow procedures to establish appropriate conditions prior to lowering pressurizer level, resulting in a partial vacuum condition in the RCS.Description. On July 5, 2007, during refueling Outage 1R13, safety injection systemcheck Valve SIE-V123 failed a surveillance test while the unit was in Mode 3. The unit had to be returned to Mode 5 with the RCS partially drained to establish plant conditions needed to conduct repairs. On July 7, 2007, operations personnel performed a cooldown and purge of the pressurizer in accordance with Procedure 40OP-9ZZ06, "Mode 5 Operations," Revision 15, prior to lowering pressurizer level to support pressurizer manway removal and partial drain of the RCS.The RO implementing the procedure had conducted two cycles of purging thepressurizer gas space to the gaseous radwaste system. During this phase of the evolution, nitrogen is added to raise pressure in the RCS to 100 psia and the pressure is then bled to the gaseous radwaste system. The purging evolution is conducted with pressurizer level between 93 to 98 percent. RCS pressure ends up at approximately 20 psia after a purging evolution.Following the final purging evolution, Procedure 40OP-9ZZ06, Step 5.3.16.9, directedthe addition of nitrogen to raise pressure in the RCS to 100 psia prior to lowering pressurizer level to 25 percent. The RO performing this evolution incorrectly signed off that Step 5.3.16.9 was complete following the final purging evolution, even though RCS pressure was at 20 psia. The RO believed that since he had previously performed the step during earlier purging evolutions, it could be signed off as complete. Consequently, draining was commenced with RCS pressure still at approximately 20 psia, resulting in RCS pressure lowering to below atmospheric pressure (less than 15 psia) as the pressurizer was drained. Actual RCS pressure was stabilized at 9 psia when pressurizer level reached the required 25 percent. The evolution was suspended at this point for turnover to the oncoming operations crew. The oncoming crew noted the partial vacuum condition in the RCS and initiated actions to raise RCS pressure to a normal, positive value and add inventory to recover level. Indicated pressurizer level stabilized at approximately 6 percent after pressure was restored to atmospheric conditions.
"Mode 5 Operations," Revision 15, prior to lowering pressurizer level to support pressurizer manway removal and partial drain of the RCS.The RO implementing the procedure had conducted two cycles of purging thepressurizer gas space to the gaseous radwaste system. During this phase of the evolution, nitrogen is added to raise pressure in the RCS to 100 psia and the pressure is then bled to the gaseous radwaste system. The purging evolution is conducted with pressurizer level between 93 to 98 percent. RCS pressure ends up at approximately 20 psia after a purging evolution.Following the final purging evolution, Procedure 40OP-9ZZ06, Step 5.3.16.9, directedthe addition of nitrogen to raise pressure in the RCS to 100 psia prior to lowering pressurizer level to 25 percent. The RO performing this evolution incorrectly signed off that Step 5.3.16.9 was complete following the final purging evolution, even though RCS pressure was at 20 psia. The RO believed that since he had previously performed the step during earlier purging evolutions, it could be signed off as complete. Consequently, draining was commenced with RCS pressure still at approximately 20 psia, resulting in RCS pressure lowering to below atmospheric pressure (less than 15 psia) as the pressurizer was drained. Actual RCS pressure was stabilized at 9 psia when pressurizer level reached the required 25 percent. The evolution was suspended at this point for turnover to the oncoming operations crew. The oncoming crew noted the partial vacuum condition in the RCS and initiated actions to raise RCS pressure to a normal, positive value and add inventory to recover level. Indicated pressurizer level stabilized at approximately 6 percent after pressure was restored to atmospheric conditions.


-20-The RO performing the evolution was also performing other duties, including monitoringRCS pressure and temperature in accordance with Procedure 40ST-9RC01, "RCS and Pressurizer Heatup and Cooldown Rates," Revision 15. The RO did not recognize the partial vacuum condition in the RCS, in part, because he did not make the mental connection that indicated pressure was in absolute units (psia) versus gauge units (psig). With RCS pressure at 15 psia, gauge pressure would be 0 psig, or atmospheric.
-20-The RO performing the evolution was also performing other duties, including monitoringRCS pressure and temperature in accordance with Procedure 40ST-9RC01, "RCS and Pressurizer Heatup and Cooldown Rates," Revision 15. The RO did not recognize the partial vacuum condition in the RCS, in part, because he did not make the mental connection that indicated pressure was in absolute units (psia) versus gauge units (psig). With RCS pressure at 15 psia, gauge pressure would be 0 psig, or atmospheric.


Additionally, the RO failed to recognize that the change in pressurizer drain rate due to the changing pressure conditions was indication that the adverse condition was developing.The licensee's event evaluation determined that: (1) there was inadequate jobpreparation for the evolution, including an inadequate pre-job briefing; (2) the RO was not proficient at performing this evolution since the individual was a control room supervisor filling in due to departmental manning issues; (3) at least two ROs involved in the evolution failed to realize they were below atmospheric pressure when indicated pressure dropped below 15 psia; and (4) procedure guidance for the evolution was inadequate in that it did not allow for proper use of the place keeper standard.Analysis. The performance deficiency associated with this finding involved the failure ofoperations personnel to adequately implement procedures to maintain configuration control of the plant. The finding is greater than minor because it is associated with the human performance attribute of the initiating events cornerstone and affects the associated cornerstone objectives to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Manual Chapter 0609, "Significance Determination Process,"
Additionally, the RO failed to recognize that the change in pressurizer drain rate due to the changing pressure conditions was indication that the adverse condition was developing.The licensee's event evaluation determined that:
: (1) there was inadequate jobpreparation for the evolution, including an inadequate pre-job briefing;
: (2) the RO was not proficient at performing this evolution since the individual was a control room supervisor filling in due to departmental manning issues;
: (3) at least two ROs involved in the evolution failed to realize they were below atmospheric pressure when indicated pressure dropped below 15 psia; and
: (4) procedure guidance for the evolution was inadequate in that it did not allow for proper use of the place keeper standard.Analysis. The performance deficiency associated with this finding involved the failure ofoperations personnel to adequately implement procedures to maintain configuration control of the plant. The finding is greater than minor because it is associated with the human performance attribute of the initiating events cornerstone and affects the associated cornerstone objectives to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Manual Chapter 0609, "Significance Determination Process,"
Appendix G, "Shutdown Operations Significance Determination Process," Checklist 4, a phase 2 analysis is required since the finding increased the likelihood of a loss of RCS inventory and could have impacted the operability of RCS level instrumentation. Manual Chapter 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria," was used since the Significance Determination Process methods and tools were not adequate to determine the significance of the finding. The finding is determined to have very low safety significance through management review because the finding does not degrade the licensee's ability to terminate a leak path, add RCS inventory, recover decay heat removal once it is lost, or establish an alternate core cooling path. Given the RCS drain rate, it would have taken over 15 hours to drain the RCS to midloop conditions, and due to the low decay heat load, the time to boil was greater than 2 hours. This finding has a crosscutting aspect in the area of humanperformance, associated with work practices, since the pre-job brief and self/peer checking for the evolution were inadequate (H.4(a)).Enforcement. TS 5.4.1.a requires that written procedures be established, implemented,and maintained covering the activities specified in Regulatory Guide 1.33, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Item 3(a), requires procedures for venting and draining the RCS. Procedure 40OP-9ZZ06 "Mode 5 Operations,"
Appendix G, "Shutdown Operations Significance Determination Process," Checklist 4, a phase 2 analysis is required since the finding increased the likelihood of a loss of RCS inventory and could have impacted the operability of RCS level instrumentation. Manual Chapter 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria," was used since the Significance Determination Process methods and tools were not adequate to determine the significance of the finding. The finding is determined to have very low safety significance through management review because the finding does not degrade the licensee's ability to terminate a leak path, add RCS inventory, recover decay heat removal once it is lost, or establish an alternate core cooling path. Given the RCS drain rate, it would have taken over 15 hours to drain the RCS to midloop conditions, and due to the low decay heat load, the time to boil was greater than 2 hours. This finding has a crosscutting aspect in the area of humanperformance, associated with work practices, since the pre-job brief and self/peer checking for the evolution were inadequate (H.4(a)).Enforcement. TS 5.4.1.a requires that written procedures be established, implemented,and maintained covering the activities specified in Regulatory Guide 1.33, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Item 3(a), requires procedures for venting and draining the RCS. Procedure 40OP-9ZZ06 "Mode 5 Operations,"
Revision 15, Step  5.3.16.9, provided instructions to establish appropriate plant conditions to ensure that RCS pressure would be above atmospheric pressure when pressurizer level was lowered to 25 percent. Contrary to the above, on July 7, 2007,  
Revision 15, Step  5.3.16.9, provided instructions to establish appropriate plant conditions to ensure that RCS pressure would be above atmospheric pressure when pressurizer level was lowered to 25 percent. Contrary to the above, on July 7, 2007,  
Line 296: Line 422:
: 05000529;
: 05000529;
: [[Closes finding::05000530/FIN-2007004-01]]NCVFailure to Identify and Critique an Event ClassificationWeakness (Section 1EP7)
: [[Closes finding::05000530/FIN-2007004-01]]NCVFailure to Identify and Critique an Event ClassificationWeakness (Section 1EP7)
: [[Closes finding::05000528/FIN-2007004-02]]NCVFailure to Follow Procedure Results in Partial Vacuum ofthe RCS (Section 4OA3)DiscussedNone
: [[Closes finding::05000528/FIN-2007004-02]]NCVFailure to Follow Procedure Results in Partial Vacuum ofthe RCS (Section 4OA3)
 
===Discussed===
None
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
In addition to the documents called out in the inspection report, the following documents wereselected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings:
In addition to the documents called out in the inspection report, the following documents wereselected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings:


==Section 1R01: Adverse Weather ProtectionProceduresNumberTitleRevision40AO-9ZZ21Acts of Nature24PVARs3046041CRDRs29690832965623Section 1R04: Equpiment AlignmentProceduresNumberTitleRevision40OP-9DG02Emergency Diesel Generator B49==
==Section 1R01: Adverse Weather ProtectionProceduresNumberTitleRevision40AO-9ZZ21Acts of Nature24==
: PVARs
: 3046041 CRDRs29690832965623
 
==Section 1R04: Equpiment AlignmentProceduresNumberTitleRevision40OP-9DG02Emergency Diesel Generator B49==
: 40OP-9DF01Diesel Fuel Oil Storage and Transfer35
: 40OP-9DF01Diesel Fuel Oil Storage and Transfer35
: 40OP-9AF01 Essential Auxiliary Feedwater System37  
: 40OP-9AF01 Essential Auxiliary Feedwater System37  
Line 306: Line 439:
: 2-M-SGP-002Main Steam System25
: 2-M-SGP-002Main Steam System25


==Section 1R05: Fire ProtectionPVARs3045878MiscellaneousPVNGS Pre-Fire Strategies Manual, Revision 17Updated Final Safety Analysis Report, Appendix 9B, Fire Protection Evaluation ReportPVNGS Pre-Fire Strategies Manual, Revision 18==
==Section 1R05: Fire Protection==
: PVARs 3045878MiscellaneousPVNGS Pre-Fire Strategies Manual, Revision 17Updated Final Safety Analysis Report, Appendix 9B, Fire Protection Evaluation ReportPVNGS Pre-Fire Strategies Manual, Revision 18
: FSAR Sections 9B.2.3.4, 9B.2.1.5,
: FSAR Sections 9B.2.3.4, 9B.2.1.5,
: 9B.2.1.6, 9B.2.1.7, 9B.2.1.8,
: 9B.2.1.6, 9B.2.1.7, 9B.2.1.8,
: 9B.2.1.9, 9B.2.1.10,9B.2.1.11Arizona Public Service History Report (Aug 2006-July 2007)
: 9B.2.1.9, 9B.2.1.10,9B.2.1.11Arizona Public Service History Report (Aug 2006-July 2007)


==Section 1R06: Flood Protection MeasuresCRDRs276165728802832882166CRAIs28060212807648280765828125152965641MiscellaneousActive Standing Orders for all units, as of July 30, 2007PM Basis Document 2590671==
==Section 1R06: Flood Protection Measures==
: CRDRs
: 2761657
: 2880283 2882166CRAIs
: 2806021
: 2807648
: 2807658
: 2812515 2965641MiscellaneousActive Standing Orders for all units, as of July 30, 2007PM Basis Document
: 2590671  
: AttachmentA-4
: AttachmentA-4


==Section 1R12: Maintenance EffectivenessProceduresNumberTitleRevision70DP-0MR01 Maintenance Rule15CRDRs3045717Work Orders3043473290342925418502739469254571927895462686628262395127958642739473254572026866442648775246463527895452623950PVARs3043465MiscellaneousPB==
==Section 1R12: Maintenance EffectivenessProceduresNumberTitleRevision70DP-0MR01 Maintenance Rule15==
: STM / Volume 28A, Class IE 4.16 kV Power System (PB), Revision 1
: CRDRs 3045717Work Orders3043473290342925418502739469254571927895462686628262395127958642739473254572026866442648775246463527895452623950
: PVARs 3043465MiscellaneousPB STM / Volume 28A, Class IE 4.16 kV Power System (PB), Revision 1


==Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresNumberTitleRevision70DP-0RA05 Assessment and Management of Risk When PerformingMaintenance in Modes 1 and 2 655DP-0GT01Gas Turbine Generator Test Record 1955OP-0GT01Station Blackout Generator #1 - Operating Instructions4840DP-9OP19 88Locked Valve, Breaker, and Component Tracking8840OP-9SI02 Recovery from Shutdown Cooling to Normal OperatingLineup7540OP-9DG02Emergency Diesel Generator B4940ST-9DG02Diesel Generator B Test3451DP-9OM03Site Scheduling17==
==Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresNumberTitleRevision70DP-0RA05 Assessment and Management of Risk When PerformingMaintenance in Modes 1 and 2==
: AttachmentA-5DrawingsNumberTitleRevisionA0-M-GTP-0001Station Blackout P & I Diagram201-M-SIP-001Safety Injection and Shutdown Cooling System Diagram4001-M-SIP-002Safety Injection and Shutdown Cooling System Diagram3201-M-SIP-003Safety Injection and Shutdown Cooling System Diagram901-M-DFP-001P & I Diagram - Diesel Fuel Oil and Transfer System1101-M-DGP-001P & I Diagram - Diesel Generator System, Sheet 148CRDRs281915630509262898645CRAIs28993452899348Work Orders2898442291053929210033049550PVARs3046807305844130495463054660MiscellaneousTroubleshooting Game Plan for 2JSGEUV0181 "A" Train, August 1, 2007Permit 139473
: 655DP-0GT01Gas Turbine Generator Test Record 1955OP-0GT01Station Blackout Generator #1 - Operating Instructions4840DP-9OP19 88Locked Valve, Breaker, and Component Tracking8840OP-9SI02 Recovery from Shutdown Cooling to Normal Operating Lineup 7540OP-9DG02Emergency Diesel Generator B4940ST-9DG02Diesel Generator B Test3451DP-9OM03Site Scheduling
: AttachmentA-5DrawingsNumberTitleRevisionA0-M-GTP-0001Station Blackout P & I Diagram201-M-SIP-001Safety Injection and Shutdown Cooling System Diagram4001-M-SIP-002Safety Injection and Shutdown Cooling System Diagram3201-M-SIP-003Safety Injection and Shutdown Cooling System Diagram901-M-DFP-001P & I Diagram - Diesel Fuel Oil and Transfer System1101-M-DGP-001P & I Diagram - Diesel Generator System, Sheet 148
: CRDRs
: 2819156
: 3050926 2898645CRAIs
: 2899345 2899348Work Orders289844229105392921003
: 3049550 PVARs
: 3046807 305844130495463054660MiscellaneousTroubleshooting Game Plan for 2JSGEUV0181 "A" Train, August 1, 2007Permit 139473
: Permit 143691Schedule Tracker for PV Units 1-3, Week of 8/27/07Unit 1 Shift Logs, 8/28/07 & 8/30/07ERFDADS Plots of Unit 1-3 CS Header Level vs. Containment Pressure, 7/26/07-8/11/07Isometric 13PSIF308 - Containment Spray 'B' HeaderMaintenance Rule Functional Failure Review of
: Permit 143691Schedule Tracker for PV Units 1-3, Week of 8/27/07Unit 1 Shift Logs, 8/28/07 & 8/30/07ERFDADS Plots of Unit 1-3 CS Header Level vs. Containment Pressure, 7/26/07-8/11/07Isometric 13PSIF308 - Containment Spray 'B' HeaderMaintenance Rule Functional Failure Review of
: CRDR 2819156, 9/6/05Schedule Tracker for PV Unit 1, Week of 8/6/07Schedule Tracker for PV Unit 1, Revised 8/12/07Technical Specifications 3.6.6, Containment Spray SystemUFSAR Section 6.5.2, Containment Spray SystemsUnit 1 Shift Logs, 8/12/07Schedule Tracker for PV Unit 1, Week of 9/3/07Schedule Tracker for PV Unit 1, Revised 9/3/07Technical Specifications 3.8.1, AC Sources - OperatingTechnical Specifications 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air AttachmentA-6UFSAR Section 68.3.1, AC Power SystemsUnit 1 Shift Logs, 9/4/07
: CRDR 2819156, 9/6/05Schedule Tracker for PV Unit 1, Week of 8/6/07Schedule Tracker for PV Unit 1, Revised 8/12/07Technical Specifications 3.6.6, Containment Spray SystemUFSAR Section 6.5.2, Containment Spray SystemsUnit 1 Shift Logs, 8/12/07Schedule Tracker for PV Unit 1, Week of 9/3/07Schedule Tracker for PV Unit 1, Revised 9/3/07Technical Specifications 3.8.1, AC Sources - OperatingTechnical Specifications 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air AttachmentA-6UFSAR Section 68.3.1, AC Power SystemsUnit 1 Shift Logs, 9/4/07
Line 324: Line 474:
==Section 1R15: Operability EvaluationsProceduresNumberTitleRevision74ST-9SI03==
==Section 1R15: Operability EvaluationsProceduresNumberTitleRevision74ST-9SI03==
: ECCS Trisodium Phosphate Surveillance Test13
: ECCS Trisodium Phosphate Surveillance Test13
: 40AL-9DG92Diesel Generator B Alarm Panel Responses2232MT-9ZZ52Preventative Maintenance Procedure Battery Charger2242AL-2RK1AAlarm Response - 125V IE CC M41 CHGR A/AC PNL D21TRBL38PVARs30413373020196304388330619323048575CRDRs2936461CRAIs29378772945178Work Orders2868917MiscellaneousTurbo lube oil filter pressure trendsInformation Notice 2007-27, "Recurring Events Involving Emergency Diesel GeneratorOperability."Unit 2 Shift logs2007-00163, Engineering Document Change - Change High Voltage Alarm Setpoint for the Safety Related Class 1E Battery Chargers, 4/26/07Standing Order, ERFDADS Battery Charger High Voltage Alarm, 8/10/07Technical Specifications 3.8.4 - DC Sources - Operating AttachmentA-7UFSAR Section 8.3.2 - DC Power SystemsVTD-P319-00002, Power Conversion Products INC., Operation and Maintenance Instructionsfor 130 VDC Battery Chargers (PUB. # 13600A), Revision 5Calculations13-MC-SI-0016 13-MC-SI-0230Section 1R19: Post-Maintenance TestingProceduresNumberTitleRevision01DP-9ZZ01 Systematic Troubleshooting0
: 40AL-9DG92Diesel Generator B Alarm Panel Responses2232MT-9ZZ52Preventative Maintenance Procedure Battery Charger
: 242AL-2RK1AAlarm Response - 125V IE CC M41 CHGR A/AC PNL D21TRBL 38 PVARs3041337302019630438833061932
: 3048575 CRDRs 2936461CRAIs
: 2937877 2945178Work Orders
: 2868917MiscellaneousTurbo lube oil filter pressure trendsInformation Notice 2007-27, "Recurring Events Involving Emergency Diesel GeneratorOperability."Unit 2 Shift logs2007-00163, Engineering Document Change - Change High Voltage Alarm Setpoint for the Safety Related Class 1E Battery Chargers, 4/26/07Standing Order, ERFDADS Battery Charger High Voltage Alarm, 8/10/07Technical Specifications 3.8.4 - DC Sources - Operating AttachmentA-7UFSAR Section 8.3.2 - DC Power SystemsVTD-P319-00002, Power Conversion Products INC., Operation and Maintenance Instructionsfor 130 VDC Battery Chargers (PUB. # 13600A), Revision 5Calculations13-MC-SI-0016 13-MC-SI-0230Section 1R19: Post-Maintenance TestingProceduresNumberTitleRevision01DP-9ZZ01 Systematic Troubleshooting0
: 30DP-9WP04Post-Maintenance Testing Development14
: 30DP-9WP04Post-Maintenance Testing Development14
: 30DP-9MP09Preventive Maintenance Processes and Activities
: 30DP-9MP09Preventive Maintenance Processes and Activities
: 55OP-0GT01 Station Blackout Generator #1 Operating Instructions4881DP-0DC13Deficiency (DF) Work Order2036MT-9SE02Startup Channel Detector Replacement336MT-9SE06Excore Startup Channel Detector Pre-InstallationAcceptance Test3CRDRs2963482Work Orders3048084291486229148802910539292100328944972894516289435929832032983206303065829906562992474 2990655Section 1R20: Refueling and Other Outage ActivitiesProceduresNumberTitleRevision40OP-9ZZ02Initial Reactor Startup Following Refueling39
: 55OP-0GT01 Station Blackout Generator #1 Operating Instructions4881DP-0DC13Deficiency (DF) Work Order
: 2036MT-9SE02Startup Channel Detector Replacement336MT-9SE06Excore Startup Channel Detector Pre-InstallationAcceptance Test
: CRDRs 2963482Work Orders3048084291486229148802910539292100328944972894516289435929832032983206303065829906562992474 2990655Section 1R20: Refueling and Other Outage ActivitiesProceduresNumberTitleRevision40OP-9ZZ02Initial Reactor Startup Following Refueling39
: 40OP-9ZZ03Reactor Startup44  
: 40OP-9ZZ03Reactor Startup44  
: NumberTitleRevisionAttachmentA-840ST-9ZZM6Operations Mode 6 Surveillance Logs1540ST-9ZZ09Containment Cleanliness Inspection15
: NumberTitleRevisionAttachmentA-840ST-9ZZM6Operations Mode 6 Surveillance Logs1540ST-9ZZ09Containment Cleanliness Inspection15
Line 335: Line 491:
: 78OP-9FX03Spent Fuel Handling Machine43DrawingsNumberTitleRevision01-M-AFP-001P & I Diagram Auxiliary Feedwater System34
: 78OP-9FX03Spent Fuel Handling Machine43DrawingsNumberTitleRevision01-M-AFP-001P & I Diagram Auxiliary Feedwater System34
: 01-M-SIP-001P & I Diagram Safety Injection & Shutdown Cooling System35
: 01-M-SIP-001P & I Diagram Safety Injection & Shutdown Cooling System35
: 01-M-SIP-002P & I Diagram Safety Injection & Shutdown Cooling System29Permits138570137707137717137708134833134837PVARs3018138302261530208883029781MiscellaneousTechnical Specification Component Condition Record ReportComponent Data Sheet, 1JEWBPSV0080**VALVEX, ECWS HX B PRESS RELIEFVLV
: 01-M-SIP-002P & I Diagram Safety Injection & Shutdown Cooling System29Permits138570137707137717137708134833134837
: PVARs3018138302261530208883029781MiscellaneousTechnical Specification Component Condition Record ReportComponent Data Sheet, 1JEWBPSV0080**VALVEX, ECWS HX B PRESS RELIEFVLV
: Local Leak Rate Test Schedule
: Local Leak Rate Test Schedule


Line 341: Line 498:
: ERFDADS (Preferred) Calculation of RCS Water Inventory43
: ERFDADS (Preferred) Calculation of RCS Water Inventory43
: 74ST-9RC02 RCS Specific Activity Surveillance Test11
: 74ST-9RC02 RCS Specific Activity Surveillance Test11
: 36MT-9SE06Excore Startup Channel Detector Acceptance Test BeforeInstallation3
: 36MT-9SE06Excore Startup Channel Detector Acceptance Test BeforeInstallation
: AttachmentA-9Work Orders3010402MiscellaneousTechnical Specifications 3.4, "RCS"
: AttachmentA-9Work Orders
: 3010402MiscellaneousTechnical Specifications 3.4, "RCS"


==Section 1EP6: Drill Evaluation (71114.06)CRDRs3051925
==Section 1EP6: Drill Evaluation (71114.06)==
: 3057921 3053990MiscellaneousNEI 90-922007==
: CRDRs3051925
: ERO Team Exercise 07-D-FAC-08008
: 3057921 3053990MiscellaneousNEI 90-922007 ERO Team Exercise 07-D-FAC-08008
: CFR 50.47(b)
: CFR 50.47(b)
: CFR 50 Section
: CFR 50 Section
Line 354: Line 512:
: EPIP-09E-Plan Implementation for Security Events10
: EPIP-09E-Plan Implementation for Security Events10
: EPIP-99EPIP Standard Appendices15
: EPIP-99EPIP Standard Appendices15
: 40AO-9ZZ24Deliberate Acts Against PVNGS17CRDRs3056153PVARs3054460Miscellaneous10
: 40AO-9ZZ24Deliberate Acts Against PVNGS17
: CRDRs
: 3056153 PVARs 3054460Miscellaneous10
: CFR 50, Appendix E, Emergency Planning and Preparedness for Production and UtilizationFacilities 10
: CFR 50, Appendix E, Emergency Planning and Preparedness for Production and UtilizationFacilities 10
: CFR 50.47, Emergency Plans AttachmentA-10NRC Regulatory Information Summary 2006-02, Good Practices for Licensee PerformanceDuring the Emergency Preparedness Component of Force-On-Force Exercises, February 23, 20064OA1 Performance Indicator Verification (71151)ProceduresNumberTitleRevision74OP-9SS01 Primary Sampling Instructions3174ST-9RC02 RCS Specific Activity Surveillance Test1174CH-9ZZ15 RCS Gross Activity and Dose Equivalent I-131Determination474DP-1LC01 RCS Activity Performance Indicator440ST-9RC02 ERFDADS (Preferred) Calculation of RCS Water Inventory43MiscellaneousTechnical Specification 3.4, "RCS"
: CFR 50.47, Emergency Plans AttachmentA-10NRC Regulatory Information Summary 2006-02, Good Practices for Licensee PerformanceDuring the Emergency Preparedness Component of Force-On-Force Exercises, February 23, 20064OA1 Performance Indicator Verification (71151)ProceduresNumberTitleRevision74OP-9SS01 Primary Sampling Instructions3174ST-9RC02 RCS Specific Activity Surveillance Test1174CH-9ZZ15 RCS Gross Activity and Dose Equivalent I-131Determination
: 474DP-1LC01 RCS Activity Performance Indicator440ST-9RC02 ERFDADS (Preferred) Calculation of RCS Water Inventory43MiscellaneousTechnical Specification 3.4, "RCS"
: NEI 99-02, "Regulatory Assessment Performance Guideline"ProceduresNumberTitleRevision40OP-9ZZ16RCS Drain Operations57DrawringsNumberTitleRevision01-M-RCP-001P & I Diagram - RCS2613-J-03D-109Containment Building Isometric
: NEI 99-02, "Regulatory Assessment Performance Guideline"ProceduresNumberTitleRevision40OP-9ZZ16RCS Drain Operations57DrawringsNumberTitleRevision01-M-RCP-001P & I Diagram - RCS2613-J-03D-109Containment Building Isometric
: RCN-LT-103 Sensing Line313-J-01D-116Containment Building Isometric
: RCN-LT-103 Sensing Line313-J-01D-116Containment Building Isometric
Line 362: Line 523:
: PT-101A,PT-102A,
: PT-101A,PT-102A,
: PT-103 and
: PT-103 and
: LT-110X Sensing Lines513-J-01D-133Containment Building Isometric
: LT-110X Sensing Lines
: RCN-PT-104, 102B, 101B,LT-110Y Sensing Line 413-J-01D-139Containment Building Isometric
: 513-J-01D-133Containment Building Isometric
: RCN-PT-104, 102B, 101B,LT-110Y Sensing Line  
: 413-J-01D-139Containment Building Isometric
: RCN-PT-100X and
: RCN-PT-100X and
: PT-100YPanel
: PT-100YPanel
: RCN-A03 Sensing Line513-JS-ZZS-197Fabrication Detail Condensate Pot Assembly Pressurizer1  
: RCN-A03 Sensing Line
: 513-JS-ZZS-197Fabrication Detail Condensate Pot Assembly Pressurizer1  
: AttachmentA-11
: AttachmentA-11
==LIST OF ACRONYMS==
==LIST OF ACRONYMS==
AFWauxiliary feedwaterASMEAmerican Society of Mechanical Engineers
AFWauxiliary feedwaterASMEAmerican Society of Mechanical Engineers
: [[CAP]] [[correction action program]]
CAPcorrection action program
: [[CR]] [[]]
CRDRcondition report/disposition request
: [[DR]] [[condition report/disposition request]]
 
: [[CFRC]] [[ode of Federal Regulations]]
CFRCode of Federal RegulationsDEPdrill exercise performance
DEPdrill exercise performance
EALemergency action level
EALemergency action level
EPemergency preparedness
EPemergency preparedness
EROemergency response organization
EROemergency response organization
EDGemergency diesel generator
EDGemergency diesel generator
: [[FOF]] [[force-on-force]]
FOFforce-on-force
: [[NCV]] [[noncited violation]]
NCVnoncited violationNOUEnotice of unusual event
: [[NOUE]] [[notice of unusual event]]
NRCNuclear Regulatory Commission
: [[NR]] [[]]
CNuclear Regulatory Commission
PARprotection action requirements
PARprotection action requirements
: [[PI]] [[performance indicator]]
PIperformance indicator
: [[PVA]] [[]]
PVARPalo Verde action request
: [[RP]] [[alo Verde action request]]
PVNGSPalo Verde Nuclear Generating Station
: [[PVNG]] [[]]
SPalo Verde Nuclear Generating Station
RCSreactor coolant system
RCSreactor coolant system
ROreactor operator
ROreactor operator
: [[SM]] [[shift manager]]
SMshift manager
: [[TS]] [[technical specifications]]
TStechnical specificationsSSCstructure, systems and component
: [[SSC]] [[structure, systems and component]]
USFARupdated final safety analysis report
: [[USF]] [[]]
ARupdated final safety analysis report
: [[WO]] [[work order]]
: [[WO]] [[work order]]
}}
}}

Revision as of 20:14, 21 October 2018

IR 05000528-07-004, 05000529-07-004, 05000530-07-004; 07/01/07 - 09/30/07; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Force-On-Force Exercise Eval., Follow-up of Events
ML073180736
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 11/08/2007
From: Thomas Farnholtz
NRC/RGN-IV/DRP/RPB-D
To: Edington R K
Arizona Public Service Co
References
IR-07-004
Download: ML073180736 (36)


Text

November 08, 2007

Randall K. Edington, Executive Vice President, Nuclear Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATEDINSPECTION REPORT 05000528/2007004, 05000529/2007004, AND 05000530/2007004

Dear Mr. Edington:

On September 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility. The enclosed integrated report documents the inspection findings, which were discussed on October 3, 2007, with you and other members of your staff.The inspection examined activities conducted under your licenses as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.The report documents one NRC identified finding and one self-revealing finding which involvedviolations of NRC requirements. One of these findings was evaluated under the risk significance determination process as having very low safety significance (Green). One finding was not suitable for evaluation under the significance determination process; however, it was determined to be of very low safety significance by NRC management review. Because of the very low safety significance of these violations and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations consistent with Section VI.A of the NRC Enforcement Policy. If you contest these noncited violations, 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, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-

4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, facility.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be made available electronically for public inspection Arizona Public Service Company-2-in the NRC Public Document Room or from the Publicly Available Records (PARS) componentof NRC's document 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/

Thomas R. Farnholtz, ChiefProject Branch D Division of Reactor ProjectsDockets: 50-528 50-529 50-530Licenses: NPF-41 NPF-51 NPF-74

Enclosure:

NRC Inspection Report 05000528/2007004, 05000529/2007004, and 05000530/2007004

w/Attachment:

Supplemental Informationcc w/enclosure:Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007Douglas K. Porter, Senior CounselSouthern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770ChairmanMaricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003Aubrey V. Godwin, DirectorArizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040Dwight Mims, Vice PresidentRegulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034Jeffrey T. WeikertAssistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901John W. SchumannLos Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Arizona Public Service Company-3-John TaylorPublic Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224Geoffrey M. CookSouthern California Edison Company 5000 Pacific Coast Hwy, Bldg. D21 San Clemente, CA 92672Robert HenrySalt River Project 6504 East Thomas Road Scottsdale, AZ 85251Brian AlmonPublic Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326Karen O' ReganEnvironmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Matthew BenacAssistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Arizona Public Service Company-4-Electronic distribution by RIV:Regional Administrator (EEC)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (GXW2)Branch Chief, DRP/D (TRF)Senior Project Engineer, DRP/D (RLN1)Senior Project Engineer, DRP/D (GEW)Team Leader, DRP/TSS (CJP)RITS Coordinator (MSH3)Only inspection reports to the following:DRS STA (DAP)V. Dricks, PAO (VLD)D. Pelton, OEDO RIV Coordinator (DLP)ROPreports PV Site Secretary (PRC)SUNSI Review Completed: _TRF_____ADAMS: Yes G No Initials: TRF______ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:\_REACTORS\_PV\2007\PV2007-004RP-GGW.wpdRIV:RI:DRP/DRI:DRP/DSRI:DRP/DSRA:DRSC:DRS/EB2JFMelfiMCattsGGWarnickMFRunyanLJSmithE-TRFT-TRFT-TRF/RA//RA/10/29/0710/29/0710/29/0711/06/0711/01/07 C:DRS/PSBC:DRS/OBC:DRS/EB1C:DRP/DMPShannonATGodyWBJonesTRFarnholtz/RA//RA/KClayton for/RA//RA/11/01/0711/01/0711/05/0710/08/07OFFICIAL RECORD COPYT=Telephone E=E-mail F=Fax Enclosure-1-U.S. NUCLEAR REGULATORY COMMISSION REGION IVDockets:50-528, 50-529, 50-530Licenses:NPF-41, NPF-51, NPF-74 Report:05000528/2007004, 05000529/2007004, 05000530/2007004 Licensee:Arizona Public Service Company Facility:Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location:5951 S. Wintersburg RoadTonopah, ArizonaDates:July 1 through September 30, 2007 Inspectors:J. Bartleman, Reactor Inspector, Region IIIJ. Bashore, Resident Inspector M. Bloodgood, Project Engineer M. Catts, Resident Inspector S. Makor, Reactor Inspector D. Melendez-Colon, Reactor Inspector, Region III J. Melfi, Resident Inspector J. Reynoso, Reactor Inspector A. Sanchez, Resident Inspector G. Warnick, Senior Resident InspectorApproved By:Thomas R. Farnholtz, Chief, Project Branch DDivision of Reactor Projects Enclosure-2-

SUMMARY OF FINDINGS

IR 05000528/2007004, 05000529/2007004, 05000530/2007004; 07/01/07 - 09/30/07; PaloVerde Nuclear Generating Station, Units 1, 2, and 3; Force-On-Force Exercise Eval., Follow-up of Events.This report covered a 3-month period of inspection by resident inspectors. The inspectionidentified two findings. The significance of most findings is indicated by their color (Green,White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management's review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.

NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

Green.

A self-revealing noncited violation of Technical Specification 5.4.1.a wasidentified for the failure of operations personnel to follow procedures to establish appropriate conditions prior to lowering pressurizer level, resulting in a partial vacuum condition in the reactor coolant system. Specifically, on July 7, 2007, operations personnel failed to perform Procedure 40OP-9ZZ06, "Mode 5 Operations," Revision 15,

Step 5.3.16.9, prior to lowering pressurizer level to 25 percent resulting in a partial vacuum condition in the reactor coolant system as the pressurizer was drained. This issue was entered into the licensee's corrective action program as Condition Report/Disposition Request 3038774.The finding is greater than minor because it is associated with the human performanceattribute of the initiating events cornerstone and affects the associated cornerstone objectives to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Manual Chapter 0609, "Significance Determination Process," Appendix G, "Shutdown Operations Significance Determination Process," Checklist 4, a phase 2 analysis is required since the finding increased the likelihood of a loss of reactor coolant system inventory and could have impacted the operability of reactor coolant system level instrumentation. Manual Chapter 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria," was used since the Significance Determination Process methods and tools were not adequate to determine the significance of the finding. The finding is determined to have very low safety significance through management review because the finding does not degrade the licensee's ability to terminate a leak path, add reactor coolant system inventory, recover decay heat removal once it is lost, or establish an alternate core cooling path. Given the reactor coolant system drain rate, it would have taken over 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to drain the reactor coolant system Enclosure-4-to midloop conditions, and due to the low decay heat load, the time to boil was greaterthan 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This finding has a crosscutting aspect in the area of human performance,associated with work practices, since the pre-job brief and self/peer checking for the evolution were inadequate (H.4(a)). (Section 4OA3)

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a noncited violation of 10 CFR 50.54(q) for failure ofthe emergency planning organization's emergency exercise critique process to identifyfor correction an emergency plan weakness associated with a risk significant planning standard. Specifically, during the critique of the Emergency Preparedness portion of theAugust 22, 2007, Force-On-Force exercise, the licensee failed to identify for correctionan event classification weakness. The weakness occurred during the exercise when theshift manager did not recognize a credible security threat notification was made to thefacility. As a result, the shift manager did not declare a Notice of Unusual Event asrequired by EPIP-99, Appendix A, "Emergency Actions Levels - EAL 7-1." This issue was entered into the licensee's corrective action program as Condition Report/Disposition Request 3056153.This finding is greater than minor because it is associated with the EmergencyResponse Organization Performance attribute of the Emergency Preparedness Cornerstone and affects the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with Manual Chapter 0609,"Significance Determination Process," Appendix B, Emergency PreparednessSignificance Determination Process, this finding is determined to have very low safetysignificance because, although it was a failure to comply with NRC requirements, it didnot involve the risk-significant aspects of a planning standard as defined in ManualChapter 0609, Appendix B, Section 2.0; and was not a planning standard functionalfailure because the critique failure occurred in a small scale drill with limited emergencyresponse organization participation and evaluation. This finding has a crosscuttingaspect in the area of problem identification and resolution associated with corrective action program because the threshold for identifying issues was not sufficiently low.

Specifically, the emergency planning evaluator did not recognize the shift manager's failure to make the Notice of Unusual Event classification during the Force-On-Forceexercise. Therefore, the exercise critique did not identify and correct the event classification deficiency as required (P.1(a)). (Section 1EP7)

Enclosure-5-

REPORT DETAILS

Summary of Plant StatusUnit 1 began the inspection period shutdown for refueling Outage 1R13. The unit was restartedon July 14, 2007, achieved essentially full power on July 23, and remained there for the duration of the inspection period.Unit 2 operated at essentially full power until July 26, 2007, when power was reduced to40 percent to repair a main condenser tube leak. On July 28, following repairs to the main condenser, the unit returned to essentially full power and remained there for the duration of the inspection period.Unit 3 operated at essentially full power until July 21, 2007, when power was reduced to80 percent to repair a bearing oil leak on heater drain Pump A. Following pump replacement, the unit was returned to essentially full power on July 23. On September 27, power was reduced to 40 percent to repair a main condenser tube leak. On September 29, the unit was shutdown for refueling Outage 3R13. At the end of the inspection period, the unit was in Mode

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R01Adverse Weather Protection (71111.01)

a. Inspection Scope

Readiness For Impending Adverse Weather Conditions On July 30, 2007, the inspectors completed a review of the licensee's readiness forimpending adverse weather involving severe thunderstorm and high wind warnings.

The inspectors reviewed the licensee's actual performance for the emergent developing weather conditions. Following the observation of severe weather approaching the site, the inspectors proceeded to the Unit 3 control room. Inspectors verified operations personnel appropriately entered the abnormal operating procedure for severe weather.

The inspectors also verified that all maintenance activities were reviewed for emergent plant risk (see Section 1R13) and restoration, and appropriate protected area announcements were made to advise site personnel to take shelter.Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

-6-1R04Equipment Alignment (71111.04)

a. Inspection Scope

Partial WalkdownThe inspectors:

(1) walked down portions of the two below listed risk important systemsand reviewed plant procedures and documents to verify that critical portions of the selected systems were correctly aligned; and
(2) compared deficiencies identified during the walk down to the licensee's Updated Final Safety Analysis Report (UFSAR) and corrective action program (CAP) to ensure problems were being identified and

corrected. *July 25, 2007, Unit 1, emergency diesel generator (EDG) Train B while EDGTrain A was out of service for preplanned maintenance*August 23, 2007, Unit 2, containment spray Train B while Train A was out ofservice for preplanned maintenanceDocuments reviewed by the inspectors are listed in the attachment.

The inspectors completed two samples.Complete WalkdownThe inspectors:

(1) reviewed plant procedures, drawings, the UFSAR, technicalspecifications (TSs), and vendor manuals to determine the correct alignment of the essential and non-essential auxiliary feedwater (AFW) systems;
(2) reviewed outstanding design issues, operator work arounds, and UFSAR documents to determine if open issues affected the functionality of the AFW systems; and
(3) verified that the licensee was identifying and resolving equipment alignment problems.*July 16, 2007, Unit 2, essential AFW system Trains A and B
  • July 17, 2007, Unit 2, non-essential AFW system Train N Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed two samples.

b. Findings

No findings of significance were identified.

-7-1R05Fire Protection (71111.05)

a. Inspection Scope

Quarterly InspectionThe inspectors walked down the seven below listed plant areas to assess the materialcondition of active and passive fire protection features and their operational lineup and readiness. The inspectors:

(1) verified that transient combustibles and hot work activities were controlled in accordance with plant procedures;
(2) observed the condition of fire detection devices to verify they remained functional;
(3) observed fire suppression systems to verify they remained functional and that access to manual actuators was unobstructed;
(4) verified that fire extinguishers and hose stations were provided at their designated locations and that they were in a satisfactory condition;
(5) verified that passive fire protection features (electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration seals, and oil collection systems) were in a satisfactory material condition;
(6) verified that adequate compensatory measures were established for degraded or inoperable fire protection features and that the compensatory measures were commensurate with the significance of the deficiency; and
(7) reviewed the UFSAR to determine if the licensee identified and corrected fire protection problems. *July 12, 2007, Unit 3, fuel building 100 foot, 120 foot, and 140 foot elevations
  • July 27, 2007, Unit 2, spray pond pump house, 108 foot elevation
  • July 30, 2007, diesel and electrical driven fire pump rooms
  • August 10, 2007, Unit 3, auxiliary building, 40 foot, 52 foot, 70 foot, and 88 footelevations*August 14, 2007, Unit 3, spray pond pump house, 108 foot elevation
  • September 6, 2007, Unit 2, control building, 74 foot, 100 foot, 120 foot, 140 foot,and 160 elevations*September 6, 2007, Unit 3, main steam support structure, 80 foot, 100 foot,120 foot, and 140 foot elevationsDocuments reviewed by the inspectors are listed in the attachment.

The inspectors completed seven samples.

b. Findings

No findings of significance were identified.

-8-1R06Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors:

(1) reviewed the UFSAR, the flooding analysis, and plant procedures toassess seasonal susceptibilities involving external flooding;
(2) reviewed the UFSAR and CAP to determine if the licensee identified and corrected flooding problems;
(3) inspected underground bunkers/manholes to verify the adequacy of
(a) sump pumps,
(b) level alarm circuits,
(c) cable splices subject to submergence, and
(d) drainage for bunkers/manholes;
(4) verified that operator actions for coping with flooding can reasonably achieve the desired outcomes; and
(5) walked down the two below listed areas to verify the adequacy of:
(a) equipment seals located below the floodline,
(b) floor and wall penetration seals,
(c) watertight door seals,
(d) common drain lines and sumps,
(e) sump pumps, level alarms, and control circuits, and
(f) temporary or removable flood barriers. *July 30, 2007, Unit 1, spray pond Pump B
  • July 30, 2007, Units 1, 2, and 3, EDG fuel oil storage tank vaultsDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

On August 22, 2007, the inspectors observed testing and training of senior reactoroperators and reactor operators (ROs) to identify deficiencies and discrepancies in thetraining, to assess operator performance, and to assess the evaluator's critique. Thetraining scenario involved three events including:

(1) failure of volume control tank levelinstrument;
(2) EDG actuation on loss of Class 1E Bus; and
(3) loss of offsite power.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.

b. Findings

No findings of significance were identified.

-9-1R12Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed the below listed maintenance activity to:

(1) verify theappropriate handling of structure, system, and component (SSC) performance or condition problems;
(2) verify the appropriate handling of degraded SSC functional performance;
(3) evaluate the role of work practices and common cause problems; and
(4) evaluate the handling of SSC issues reviewed under the requirements of the maintenance rule, 10 CFR Part 50 Appendix B, and the TSs. *August 20, 2007, Unit 1, EDG Train A voltage permissive relay failure, asdocumented in Corrective Maintenance Work Order (WO) 3043473Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

Risk Assessment and Management of RiskThe inspectors reviewed the two below listed assessment activities to verify:

(1) performance of risk assessments when required by 10 CFR 50.65 (a)(4) andlicensee procedures prior to changes in plant configuration for maintenance activitiesand plant operations;
(2) the accuracy, adequacy, and completeness of the informationconsidered in the risk assessment;
(3) that the licensee recognizes, and/or enters asapplicable, the appropriate licensee-established risk category according to the riskassessment results and licensee procedures; and
(4) the licensee identified andcorrected problems related to maintenance risk assessments.
  • August 1, 2007, Unit 2, risk assessment and management during scheduledEDG Train A outage*August 28, 2007, Units 1, 2 and 3, risk assessment and management duringscheduled station blackout Generator 1 outageDocuments reviewed by the inspectors are listed in the attachment.The inspectors completed two samples.

-10-Emergent Work ControlThe inspectors:

(1) verified that the licensee performed actions to minimize theprobability of initiating events and maintained the functional capability of mitigating systems and barrier integrity systems;
(2) verified that emergent work-related activities such as troubleshooting, work planning/scheduling, establishing plant conditions, aligning equipment, tagging, temporary modifications, and equipment restoration did not place the plant in an unacceptable configuration; and
(3) reviewed the UFSAR to determine if the licensee identified and corrected risk assessment and emergent work control problems. *July 26 - 27, 2007, Unit 1, extended out of service time for essential chill watersystem Train A due to the discovery of a design issue with the Trico Oiler on the circulating pump bearing housing*July 30, 2007, Units 1, 2, and 3, elevated plant risk due to a severe thunderstormwarning*August 11, 2007, Unit 1, containment spray Train B piping system voids
  • August 30, 2007, Unit 2, troubleshooting effort to fix ground fault relay of motorgenerator Set B via WO 3055461
  • September 4, 2007, Unit 1, EDG Train B inoperable due to fuel oil transfer pumpcycling *September 13, 2007, Unit 2, replacement of EDG Train B lube oil filters viaWO 3061974*September 18 - 20, 2007, Unit 1, troubleshooting and repair efforts for steamGenerator 2 steam supply to AFA-P01 bypass Valve SGAUV0138ADocuments reviewed by the inspectors are listed in the attachment.The inspectors completed seven samples.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors:

(1) reviewed plant status documents such as operator shift logs,emergent work documentation, deferred modifications, and night orders to determine ifan operability evaluation was warranted for degraded components;
(2) referred to the

-11-UFSAR and design basis documents to review the technical adequacy of licenseeoperability evaluations;

(3) evaluated compensatory measures associated withoperability evaluations;
(4) determined degraded component impact on any TSs; (5)used the Significance Determination Process to evaluate the risk significance ofdegraded or inoperable equipment; and
(6) verified that the licensee has identified andimplemented appropriate corrective actions associated with degraded components.
  • July 19, 2007, Units 1, 2, and 3, operability determination associated withrequired minimum volume of trisodium phosphate contained in the storagebaskets inside containment
  • July 25, 2007, Unit 1, essential chiller Train A design issue associated with theTrico Oiler
  • August 9, 2007, Unit 2, Class 1E battery charger high voltage alarm dropout settoo high as described in Palo Verde Action Request (PVAR) 3048575*September 13, 2007, Unit 2, EDG Train B turbo lube oil filters degradingdischarge pressure trend*September 20, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testing due to foreign material and its potential transportabilityDocuments reviewed by the inspectors are listed in the attachment.

The inspectors completed five samples

.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors selected the six below listed post-maintenance test activities of risksignificant systems or components. For each item, the inspectors:

(1) reviewed the applicable licensing basis and/or design-basis documents to determine the safety functions;
(2) evaluated the safety functions that may have been affected by the maintenance activity; and
(3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test

-12-equipment was removed, the system was properly re-aligned, and deficiencies duringtesting were documented. The inspectors also reviewed the UFSAR to determine if the licensee identified and corrected problems related to post maintenance testing.

  • May 15 - 24, 2007, Unit 1, testing associated with detector replacement forstartup Channels 1 and 2 detectors
  • July 25 - 26, 2007, Unit 1, EDG Train A per Procedure 40ST-9DG01,"Diesel Generator A Test," Revision 30*July 30, 2007, Unit 1, high pressure safety injection Valve 1JSIAUV0666 perWOs 2946259, 2855494, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 3, 2007, Unit 3, low pressure safety injection Valve 3-JSIAUV0645 perWOs 2855772, 2948743, and Procedure 39MT-9ZZ02, "PM or EQ Inspection of the GL-89-10 Limitorque SMB/SB Motor Operated Valve Actuators," Revision 21*August 08, 2007, Unit 3, Procedure 77ST-9SB07, "CPC Channel A FunctionalTest," Revision 9, following maintenance*August 27, 2007, overspeed test of station blackout Generator 1 followingmaintenanceDocuments reviewed by the inspectors are listed in the attachment.

The inspectors completed six samples.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope

Unit 1 Refueling Outage 13The inspectors reviewed the following risk significant refueling items or outage activitiesto verify defense in depth commensurate with the outage risk control plan, compliance with the TSs, and adherence to commitments in response to Generic Letter 88-17, "Loss of Decay Heat Removal:"

(1) the risk control plan;
(2) tagging/clearance activities;
(3) reactor coolant system (RCS) instrumentation;
(4) electrical power;
(5) decay heat removal;
(6) spent fuel pool cooling;
(7) inventory control;
(8) reactivity control;
(9) containment closure;
(10) reduced inventory or mid-loop conditions;
(11) refueling

-13-activities; and

(12) licensee identification and implementation of appropriate correctiveactions associated with refueling and outage activities. The containment inspections included observations of the containment sump for damage and debris; and supports, braces, and snubbers for evidence of excessive stress, water hammer, or aging.Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

(71111.22)

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and TSs to ensure thatthe four below listed surveillance activities demonstrated that the SSCs tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate:

(1) preconditioning;
(2) evaluation of testing impact on the plant;
(3) acceptance criteria;
(4) test equipment;
(5) procedures;
(6) jumper/lifted lead controls;
(7) test data;
(8) testing frequency and method to demonstrate TS operability;
(9) test equipment removal;
(10) restoration of plant systems;
(11) fulfillment of ASME Code requirements;
(12) updating of performance indicator data;
(13) engineering evaluations, root causes, and bases for returning tested SSCs not meeting the test acceptance criteria were correct;
(14) reference setting data; and
(15) annunciators and alarms setpoints. The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing. *June 16 - 17, 2007 Unit 1, shiftly surveillances per Procedure 40ST-9ZZM6,"Operations Mode 6 Surveillance Logs," Revision 15 *July 24, 2007, Unit 3, Procedures 73ST-9AF02, "AFA-P01 Inservice Test,"Revision 39, and 73ST-9XI38, "AF Pumps Discharge Check Valves - Inservice Test," Revision 14 *August 28, 2007, Unit 2, Procedure 40ST-9RC02, "ERFDADS (Preferred)Calculation of RCS Water Inventory," Revision 43 *August 29, 2007, Unit 2, Procedure 74ST-9RC02, "RCS Specific ActivitySurveillance Test," Revision 11 Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed four samples.

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b. Findings

No findings of significance were identified.Cornerstone: Emergency Preparedness1EP6Drill Evaluation (71114.06)

a. Inspection Scope

For the below listed drill contributing to Drill/Exercise Performance (DEP) andEmergency Response Organization (ERO) Performance Indicators, the inspectors:

(1) observed the training evolution to identify any weaknesses and deficiencies in classification, notification, and Protective Action Requirements (PAR) development activities;
(2) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying failures; and
(3) determined whether licensee performance is in accordance with the guidance of the NEI 99-02, "Voluntary Submission of Performance Indicator Data," acceptance criteria. *August 16, 2007, ERO exercise scenario Guide 07-D-FAC-08008 Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.1EP7Force-On-Force Exercise Evaluation (71114.07)

a. Inspection Scope

For the drill listed below, inspectors:

(1) reviewed any Emergency Preparedness (EP)corrective actions identified during previous Force-On-Force (FOF) exercises that would be demonstrated during the current FOF exercise;
(2) observed the EP portion of the FOF exercise to identify any weaknesses and deficiencies in classification, notification, and PAR activities; and
(3) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee is properly identifying and correcting failures.*August 22, 2007, EP portion of the FOF exercise Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

-15-

b. Findings

Introduction.

The inspectors identified a Green noncited violation (NCV) associated with10 CFR 50.54(q) for the failure of the emergency planning organization's critiqueprocess to identify an emergency plan weakness associated with a risk significantplanning standard during the EP portion of the August 22, 2007, FOF exercise.

Description.

During the August 22, 2007, EP portion of the FOF exercise, the inspectorsobserved that the shift manager (SM) failed to declare a Notice of Unusual Event(NOUE) even though the Emergency Action Level (EAL) conditions existed. The SMentered Procedure EPIP-09, "E-Plan Implementation for Security Events," Revision 10,when conditions existed that posed a credible threat to the facility. This proceduredirected the SM to enter Procedure 40AO-9ZZ24, "Deliberate Acts Against PVNGS,"Revision 17, and to classify the event per Procedure EPIP-99, "Emergency ActionsLevels," Appendix A, Revision 15. Procedure EPIP-99, Appendix A, EAL 7-1, states todeclare a NOUE when a credible Site-Security Threat Notification condition exists. TheSM failed to make this declaration. The subsequent critique conducted by the licensee'sorganization failed to identify the missed classification by the SM for correction, resultingin the performance deficiency. In addition, the licensee's exercise evaluators did notadequately prepare evaluation objectives before the start of the exercise whichcontributed to the failure to recognize the opportunity to declare the NOUE.Analysis. The performance deficiency associated with this finding involved the failure ofthe licensee's critique process to identify for correction an emergency plan weakness associated with a risk significant planning standard. This finding is more than minor because it is associated with the Emergency Response Organization Performance attribute of the Emergency Preparedness Cornerstone and affects the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

Inaccordance with Manual Chapter 0609, "Significance Determination Process,"Appendix B, Emergency Preparedness Significance Determination Process, this findingis determined to have very low safety significance because, although it was a failure tocomply with NRC requirements, it did not involve the risk significant aspects of aplanning standard as defined in Manual Chapter 0609, Appendix B, Section 2.0; andwas not a planning standard functional failure because the critique failure occurred in asmall scale drill with limited ERO participation and evaluation. This finding has acrosscutting aspect in the area of problem identification and resolution associated withcorrective action program because the threshold for identifying issues was not sufficiently low. Specifically, the emergency planning evaluator did not recognize the SM's failure to make the NOUE classification during the FOF exercise. Therefore, the exercise critique did not identify and correct the event classification deficiency as required by 10 CFR 50, Appendix E, IV(F)(2)(g) (P.1(a)).

Enforcement.

10 CFR 50.54(q) states in part, "A licensee authorized to possess andoperate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements of Appendix E of this part-" 10 CFR 50.47(b)(4) states in part, "A standard emergency classification and

-16-action level scheme, -, is (will be) in use by the nuclear facility licensee-" 10 CFRPart 50, Appendix E, IV(B), states in part, "The means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of Local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are used for determining when and what type of protective measures shall be considered within and outside the site boundary-" 10 CFR 50.47(b)(14) states in part,

"-deficiencies identified as a result of exercises or drills are (will be) corrected."

10 CFR 50, Appendix E, IV(F)(2)(g), states in part, "All training, including exercises, shall provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified shall be corrected."

Contrary to the above, during the critique of the EP portion of the August 22, 2007, FOF exercise, the licensee failed to identify for correction an event classification weakness.

The weakness occurred during the exercise when the SM did not recognize and declare a NOUE emergency classification required by EAL 7-1, when the conditions existed.

Because this finding is of very low safety significance, and because it was entered into the licensee's CAP as Condition Report/Disposition Request (CRDR) 3056153, this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000528; 05000529;05000530/2007004-01, "Failure to Identify and Critique an Event Classification Weakness."4.OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

Cornerstone: Barrier IntegrityThe inspectors sampled licensee submittals for the two performance indicators listedbelow for the period September 1, 2006, to July 31, 2007, for Units 1, 2, and 3. The definitions and guidance of Nuclear Energy Institute 99-02,"Regulatory Assessment Indicator Guideline," Revision 2, were used to verify the licensee's basis for reporting each data element in order to verify the accuracy of PI data reported during the assessment period. The inspectors:

(1) reviewed RCS chemistry sample analyses for dose equivalent Iodine-131 and compared the results to the TS limit;
(2) observed a chemistry technician obtain and analyze a RCS sample;
(3) reviewed operating logs and surveillance results for measurements of RCS identified leakage; and
(4) observed a surveillance test that determined RCS identified leakage. Licensee performanceindicator data were also reviewed against the requirements of Procedures 93DP-0LC09,"Data Collection and Submittal Using INPO's Consolidated Data Entry System,"Revision 6, 73DP-9PP01, "Thermal Performance Monitoring and Evaluation Process," Revision 4, and 70DP-0PI01, "Performance Indicator Data Mitigating Systems Cornerstone," Revision 3.*RCS Specific Activity

-17-*RCS LeakageThe inspectors completed six samples.Documents reviewed by the inspectors are listed in the attachment.

b. Findings

No findings of significance were identified.4OA2Identification and Resolution of Problems (71152).1Routine Review of Identification and Resolution of ProblemsThe inspectors performed a daily screening of items entered into the licensee's CAP. This assessment was accomplished by reviewing daily summary reports for PVARs and CRDRs, and attending corrective action review and work control meetings. The inspectors:

(1) verified that equipment, human performance, and program issues were being identified by the licensee at an appropriate threshold and that the issues were entered into the CAP;
(2) verified that corrective actions were commensurate with the significance of the issue; and
(3) identified conditions that might warrant additional follow-up through other baseline inspection procedures.

.2 Multiple/Repetitive Degraded Cornerstone Column and Crosscutting Issues Follow-upActivitiesIn the NRC's Annual Assessment Letter of Palo Verde dated March 2, 2007, the NRCindicated that improvement efforts in addressing the substantive crosscutting issuesthrough baseline inspections would be monitored, including a detailed assessment

following the licensee's notification of readiness for closure verification. In a Confirmatory Action Letter dated June 21, 2007, the NRC revised this to indicate the intent to address the substantive crosscutting issues within the Inspection Procedure95003 supplemental inspection and followup process, since the issues are integral to the performance deficiencies being addressed by your staff.The inspectors and Region IV personnel conducted weekly teleconferences andconducted periodic discussions with licensee management to monitor their progress in addressing their performance deficiencies and substantive crosscutting issues.A public meeting was conducted during this inspection period. On September 6, 2007,a public meeting was held with PVNGS to discuss the status of their assessment and improvement efforts to address plant performance issues that contributed to entering Column 4 of the NRC Action Matrix. The meeting summary can be found in ADAMS under ML072550193.During the week of August 27, 2007, in preparation for the upcoming inspections perInspection Procedure 95003, scheduled for October 1 through October 12 and

-18-October 29 through November 2, the team leader and six members of the inspectionteam conducted an information gathering trip to PVNGS. In addition, from September 10 through 21, 2007, the entire team began reviewing documentation and preparing for the upcoming inspection in the Region IV office. The inspection is still ongoing, and the results of the inspection will be documented in NRC Inspection Report 05000528; 05000529; 05000530/2007012. No findings of significance were identified during this preliminary review..3Cross-References to Problem Identification and Resolution Findings DocumentedElsewhereSection 1EP7 describes a finding where emergency planning personnel failed to identifya drill weakness at a low enough threshold and in a complete, accurate, and timely manner.4OA3Follow-up of Events and Notices of Enforcement Discretion (71153)

a. Inspection Scope

Event Follow-UpThe inspectors reviewed the below listed degraded condition for plant status andmitigating actions to:

(1) provide input in determining the appropriate agency response in accordance with Management Directive 8.3, "NRC Incident Investigation Program;"
(2) evaluate performance of mitigating systems and licensee actions; and
(3) confirm that the licensee properly classified the event in accordance with emergency action level procedures and made timely notifications to NRC and state/governments, as required.*September 20 - 28, 2007, Unit 1, steam Generator 2 steam supply to AFA-P01bypass Valve SGAUV0138A failure to open during surveillance testingDocuments reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.Personnel Performance The inspectors:

(1) reviewed operator logs, plant computer data, and/or strip charts forthe below listed evolution to evaluate operator performance in coping with non-routineevents and transients;
(2) verified that operator actions were in accordance with theresponse required by plant procedures and training; and
(3) verified that the licenseehas identified and implemented appropriate corrective actions associated with personnelperformance problems that occurred during the non-routine evolutions sampled. *On July 7, 2007, Unit 1, the RCS was taken below atmospheric pressure whilelowering pressurizer level. A pressurizer cooldown, purge, and level reduction had been performed to support pressurizer manway removal and RCS drain to

-19-establish conditions for emergent check valve maintenance. During turnover,the oncoming operations shift recognized that RCS pressure was less than atmospheric and took action to increase RCS pressure to atmospheric conditions and recover pressurizer level. Pressurizer level stabilized to a partial drain condition of 6 percent once atmospheric conditions were restored. This event was documented in CRDR 3038774.Documents reviewed by the inspectors are listed in the attachment.The inspectors completed one sample.

b. Findings

Introduction.

A Green self-revealing NCV of TS 5.4.1.a was identified for the failure ofoperations personnel to follow procedures to establish appropriate conditions prior to lowering pressurizer level, resulting in a partial vacuum condition in the RCS.Description. On July 5, 2007, during refueling Outage 1R13, safety injection systemcheck Valve SIE-V123 failed a surveillance test while the unit was in Mode 3. The unit had to be returned to Mode 5 with the RCS partially drained to establish plant conditions needed to conduct repairs. On July 7, 2007, operations personnel performed a cooldown and purge of the pressurizer in accordance with Procedure 40OP-9ZZ06, "Mode 5 Operations," Revision 15, prior to lowering pressurizer level to support pressurizer manway removal and partial drain of the RCS.The RO implementing the procedure had conducted two cycles of purging thepressurizer gas space to the gaseous radwaste system. During this phase of the evolution, nitrogen is added to raise pressure in the RCS to 100 psia and the pressure is then bled to the gaseous radwaste system. The purging evolution is conducted with pressurizer level between 93 to 98 percent. RCS pressure ends up at approximately 20 psia after a purging evolution.Following the final purging evolution, Procedure 40OP-9ZZ06, Step 5.3.16.9, directedthe addition of nitrogen to raise pressure in the RCS to 100 psia prior to lowering pressurizer level to 25 percent. The RO performing this evolution incorrectly signed off that Step 5.3.16.9 was complete following the final purging evolution, even though RCS pressure was at 20 psia. The RO believed that since he had previously performed the step during earlier purging evolutions, it could be signed off as complete. Consequently, draining was commenced with RCS pressure still at approximately 20 psia, resulting in RCS pressure lowering to below atmospheric pressure (less than 15 psia) as the pressurizer was drained. Actual RCS pressure was stabilized at 9 psia when pressurizer level reached the required 25 percent. The evolution was suspended at this point for turnover to the oncoming operations crew. The oncoming crew noted the partial vacuum condition in the RCS and initiated actions to raise RCS pressure to a normal, positive value and add inventory to recover level. Indicated pressurizer level stabilized at approximately 6 percent after pressure was restored to atmospheric conditions.

-20-The RO performing the evolution was also performing other duties, including monitoringRCS pressure and temperature in accordance with Procedure 40ST-9RC01, "RCS and Pressurizer Heatup and Cooldown Rates," Revision 15. The RO did not recognize the partial vacuum condition in the RCS, in part, because he did not make the mental connection that indicated pressure was in absolute units (psia) versus gauge units (psig). With RCS pressure at 15 psia, gauge pressure would be 0 psig, or atmospheric.

Additionally, the RO failed to recognize that the change in pressurizer drain rate due to the changing pressure conditions was indication that the adverse condition was developing.The licensee's event evaluation determined that:

(1) there was inadequate jobpreparation for the evolution, including an inadequate pre-job briefing;
(2) the RO was not proficient at performing this evolution since the individual was a control room supervisor filling in due to departmental manning issues;
(3) at least two ROs involved in the evolution failed to realize they were below atmospheric pressure when indicated pressure dropped below 15 psia; and
(4) procedure guidance for the evolution was inadequate in that it did not allow for proper use of the place keeper standard.Analysis. The performance deficiency associated with this finding involved the failure ofoperations personnel to adequately implement procedures to maintain configuration control of the plant. The finding is greater than minor because it is associated with the human performance attribute of the initiating events cornerstone and affects the associated cornerstone objectives to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Manual Chapter 0609, "Significance Determination Process,"

Appendix G, "Shutdown Operations Significance Determination Process," Checklist 4, a phase 2 analysis is required since the finding increased the likelihood of a loss of RCS inventory and could have impacted the operability of RCS level instrumentation. Manual Chapter 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria," was used since the Significance Determination Process methods and tools were not adequate to determine the significance of the finding. The finding is determined to have very low safety significance through management review because the finding does not degrade the licensee's ability to terminate a leak path, add RCS inventory, recover decay heat removal once it is lost, or establish an alternate core cooling path. Given the RCS drain rate, it would have taken over 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to drain the RCS to midloop conditions, and due to the low decay heat load, the time to boil was greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This finding has a crosscutting aspect in the area of humanperformance, associated with work practices, since the pre-job brief and self/peer checking for the evolution were inadequate (H.4(a)).Enforcement. TS 5.4.1.a requires that written procedures be established, implemented,and maintained covering the activities specified in Regulatory Guide 1.33, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Item 3(a), requires procedures for venting and draining the RCS. Procedure 40OP-9ZZ06 "Mode 5 Operations,"

Revision 15, Step 5.3.16.9, provided instructions to establish appropriate plant conditions to ensure that RCS pressure would be above atmospheric pressure when pressurizer level was lowered to 25 percent. Contrary to the above, on July 7, 2007,

-21-operations personnel failed to perform Procedure 40OP-9ZZ06, Step 5.3.16.9, prior tolowering pressurizer level to 25 percent resulting in a partial vacuum condition in the RCS as the pressurizer was drained. Because this violation is of very low safety significance and has been entered into the licensee's CAP as CRDR 3038774, this violation is being treated as an NCV consistent with Section VI.A of the Enforcement Policy: NCV 05000528/2007004-02, "Failure to Follow Procedure Results in Partial Vacuum of the RCS."4OA6Meetings, Including ExitOn October 3, 2007, the inspectors presented the inspection results to Mr. R. Bement,Vice President, Nuclear Operations, and other members of the licensee management staff. The licensee acknowledged the findings presented.The inspectors noted that while proprietary information was reviewed, none would beincluded in this report.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Andrews, Director, Performance Improvement
S. Bauer, Department Leader, Regulatory Affairs
R. Bement, Vice President, Nuclear Operations
P. Borchert, Director, Operations
P. Brandjes, Department Leader, Maintenance
R. Buzard, Senior Consultant, Regulatory Affairs
D. Carnes, Director, Nuclear Assurance
P. Carpenter, Department Leader, Operations
R. Cavalieri, Director, Outages
K. Chavet, Senior Consultant, Regulatory Affairs
D. Coxon, Unit Department Leader, Operations
R. Eddington, Executive Vice President, Chief Nuclear Officer
D. Elkington, Consultant, Regulatory Affairs
J. Gaffney, Director, Radiation Protection
T. Gray, Department Leader, Radiation Protection
K. Graham, Department Leader, Fuel Services
M. Grigsby, Unit Department Leader, Operations
R. Henry, Site Rep., SRP
J. Hesser, Vice President, Engineering
M. Karbasian, Director, Engineering
D. Marks, Section Leader, Regulatory Affairs
S. McKinney, Department Leader, Operations Support
E. O<Neil, Department leader, Emergency Preparedness
M. Perito, Plant Manager, Nuclear Operations
M. Radspinner, Section Leader, Systems Engineering
T. Radtke, General Manager, Emergency Services and Support
H. Ridenour, Director, Maintenance
F. Riedel, Director, Nuclear Training Department
J. Scott, Section Leader, Nuclear Assurance
M. Shea, Director, ImPACT Project
E. Shouse, Representative, EPE
M. Sontag, Department Leader, Performance Improvement
K. Sweeney, Department Leader, Systems Engineering
J. Taylor, Nuclear Project Manager, PNM
J. Taylor, Unit Department Leader, Operations

D Vogt, Section Leader, OPS STA

T. Weber, Section Leader, Regulatory Affairs
J. Wood, Department Leader, Nuclear Training Department

NRC Personnel

M. Runyan, Senior Reactor Analyst

AttachmentA-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and

Closed

05000528;
05000529;
05000530/FIN-2007004-01NCVFailure to Identify and Critique an Event ClassificationWeakness (Section 1EP7)
05000528/FIN-2007004-02NCVFailure to Follow Procedure Results in Partial Vacuum ofthe RCS (Section 4OA3)

Discussed

None

LIST OF DOCUMENTS REVIEWED

In addition to the documents called out in the inspection report, the following documents wereselected and reviewed by the inspectors to accomplish the objectives and scope of the inspection and to support any findings:

Section 1R01: Adverse Weather ProtectionProceduresNumberTitleRevision40AO-9ZZ21Acts of Nature24

PVARs
3046041 CRDRs29690832965623

Section 1R04: Equpiment AlignmentProceduresNumberTitleRevision40OP-9DG02Emergency Diesel Generator B49

40OP-9DF01Diesel Fuel Oil Storage and Transfer35
40OP-9AF01 Essential Auxiliary Feedwater System37
AttachmentA-340OP-9AF02Non-Essential Auxiliary Feedwater Pump Operation15DrawingsNumberTitleRevision02-M-AFP-001Auxiliary Feedwater System25
2-M-SGP-002Main Steam System25

Section 1R05: Fire Protection

PVARs 3045878MiscellaneousPVNGS Pre-Fire Strategies Manual, Revision 17Updated Final Safety Analysis Report, Appendix 9B, Fire Protection Evaluation ReportPVNGS Pre-Fire Strategies Manual, Revision 18
FSAR Sections 9B.2.3.4, 9B.2.1.5,
9B.2.1.6, 9B.2.1.7, 9B.2.1.8,
9B.2.1.9, 9B.2.1.10,9B.2.1.11Arizona Public Service History Report (Aug 2006-July 2007)

Section 1R06: Flood Protection Measures

CRDRs
2761657
2880283 2882166CRAIs
2806021
2807648
2807658
2812515 2965641MiscellaneousActive Standing Orders for all units, as of July 30, 2007PM Basis Document
2590671
AttachmentA-4

Section 1R12: Maintenance EffectivenessProceduresNumberTitleRevision70DP-0MR01 Maintenance Rule15

CRDRs 3045717Work Orders3043473290342925418502739469254571927895462686628262395127958642739473254572026866442648775246463527895452623950
PVARs 3043465MiscellaneousPB STM / Volume 28A, Class IE 4.16 kV Power System (PB), Revision 1

Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresNumberTitleRevision70DP-0RA05 Assessment and Management of Risk When PerformingMaintenance in Modes 1 and 2

655DP-0GT01Gas Turbine Generator Test Record 1955OP-0GT01Station Blackout Generator #1 - Operating Instructions4840DP-9OP19 88Locked Valve, Breaker, and Component Tracking8840OP-9SI02 Recovery from Shutdown Cooling to Normal Operating Lineup 7540OP-9DG02Emergency Diesel Generator B4940ST-9DG02Diesel Generator B Test3451DP-9OM03Site Scheduling
AttachmentA-5DrawingsNumberTitleRevisionA0-M-GTP-0001Station Blackout P & I Diagram201-M-SIP-001Safety Injection and Shutdown Cooling System Diagram4001-M-SIP-002Safety Injection and Shutdown Cooling System Diagram3201-M-SIP-003Safety Injection and Shutdown Cooling System Diagram901-M-DFP-001P & I Diagram - Diesel Fuel Oil and Transfer System1101-M-DGP-001P & I Diagram - Diesel Generator System, Sheet 148
CRDRs
2819156
3050926 2898645CRAIs
2899345 2899348Work Orders289844229105392921003
3049550 PVARs
3046807 305844130495463054660MiscellaneousTroubleshooting Game Plan for 2JSGEUV0181 "A" Train, August 1, 2007Permit 139473
Permit 143691Schedule Tracker for PV Units 1-3, Week of 8/27/07Unit 1 Shift Logs, 8/28/07 & 8/30/07ERFDADS Plots of Unit 1-3 CS Header Level vs. Containment Pressure, 7/26/07-8/11/07Isometric 13PSIF308 - Containment Spray 'B' HeaderMaintenance Rule Functional Failure Review of
CRDR 2819156, 9/6/05Schedule Tracker for PV Unit 1, Week of 8/6/07Schedule Tracker for PV Unit 1, Revised 8/12/07Technical Specifications 3.6.6, Containment Spray SystemUFSAR Section 6.5.2, Containment Spray SystemsUnit 1 Shift Logs, 8/12/07Schedule Tracker for PV Unit 1, Week of 9/3/07Schedule Tracker for PV Unit 1, Revised 9/3/07Technical Specifications 3.8.1, AC Sources - OperatingTechnical Specifications 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air AttachmentA-6UFSAR Section 68.3.1, AC Power SystemsUnit 1 Shift Logs, 9/4/07

Section 1R15: Operability EvaluationsProceduresNumberTitleRevision74ST-9SI03

ECCS Trisodium Phosphate Surveillance Test13
40AL-9DG92Diesel Generator B Alarm Panel Responses2232MT-9ZZ52Preventative Maintenance Procedure Battery Charger
242AL-2RK1AAlarm Response - 125V IE CC M41 CHGR A/AC PNL D21TRBL 38 PVARs3041337302019630438833061932
3048575 CRDRs 2936461CRAIs
2937877 2945178Work Orders
2868917MiscellaneousTurbo lube oil filter pressure trendsInformation Notice 2007-27, "Recurring Events Involving Emergency Diesel GeneratorOperability."Unit 2 Shift logs2007-00163, Engineering Document Change - Change High Voltage Alarm Setpoint for the Safety Related Class 1E Battery Chargers, 4/26/07Standing Order, ERFDADS Battery Charger High Voltage Alarm, 8/10/07Technical Specifications 3.8.4 - DC Sources - Operating AttachmentA-7UFSAR Section 8.3.2 - DC Power SystemsVTD-P319-00002, Power Conversion Products INC., Operation and Maintenance Instructionsfor 130 VDC Battery Chargers (PUB. # 13600A), Revision 5Calculations13-MC-SI-0016 13-MC-SI-0230Section 1R19: Post-Maintenance TestingProceduresNumberTitleRevision01DP-9ZZ01 Systematic Troubleshooting0
30DP-9WP04Post-Maintenance Testing Development14
30DP-9MP09Preventive Maintenance Processes and Activities
55OP-0GT01 Station Blackout Generator #1 Operating Instructions4881DP-0DC13Deficiency (DF) Work Order
2036MT-9SE02Startup Channel Detector Replacement336MT-9SE06Excore Startup Channel Detector Pre-InstallationAcceptance Test
CRDRs 2963482Work Orders3048084291486229148802910539292100328944972894516289435929832032983206303065829906562992474 2990655Section 1R20: Refueling and Other Outage ActivitiesProceduresNumberTitleRevision40OP-9ZZ02Initial Reactor Startup Following Refueling39
40OP-9ZZ03Reactor Startup44
NumberTitleRevisionAttachmentA-840ST-9ZZM6Operations Mode 6 Surveillance Logs1540ST-9ZZ09Containment Cleanliness Inspection15
70OP-9FX01Refueling Machine Operations32
2IC-9RX03Core Reloading30
2PY-9RX04Low Power Physics Tests Using RMAS12
78OP-9FX03Spent Fuel Handling Machine43DrawingsNumberTitleRevision01-M-AFP-001P & I Diagram Auxiliary Feedwater System34
01-M-SIP-001P & I Diagram Safety Injection & Shutdown Cooling System35
01-M-SIP-002P & I Diagram Safety Injection & Shutdown Cooling System29Permits138570137707137717137708134833134837
PVARs3018138302261530208883029781MiscellaneousTechnical Specification Component Condition Record ReportComponent Data Sheet, 1JEWBPSV0080**VALVEX, ECWS HX B PRESS RELIEFVLV
Local Leak Rate Test Schedule

Section 1R22: Surveillance TestingProceduresNumberTitleRevision40ST-9RC02

ERFDADS (Preferred) Calculation of RCS Water Inventory43
74ST-9RC02 RCS Specific Activity Surveillance Test11
36MT-9SE06Excore Startup Channel Detector Acceptance Test BeforeInstallation
AttachmentA-9Work Orders
3010402MiscellaneousTechnical Specifications 3.4, "RCS"

Section 1EP6: Drill Evaluation (71114.06)

CRDRs3051925
3057921 3053990MiscellaneousNEI 90-922007 ERO Team Exercise 07-D-FAC-08008
CFR 50.47(b)
CFR 50 Section
IV.F of Appendix E

Section 1EP7: Force-On-Force Exercise EvaluationProceduresNumberTitleRevisionEPIP-01Satellite Technical Support Center Actions21

EPIP-09E-Plan Implementation for Security Events10
EPIP-99EPIP Standard Appendices15
40AO-9ZZ24Deliberate Acts Against PVNGS17
CRDRs
3056153 PVARs 3054460Miscellaneous10
CFR 50, Appendix E, Emergency Planning and Preparedness for Production and UtilizationFacilities 10
CFR 50.47, Emergency Plans AttachmentA-10NRC Regulatory Information Summary 2006-02, Good Practices for Licensee PerformanceDuring the Emergency Preparedness Component of Force-On-Force Exercises, February 23, 20064OA1 Performance Indicator Verification (71151)ProceduresNumberTitleRevision74OP-9SS01 Primary Sampling Instructions3174ST-9RC02 RCS Specific Activity Surveillance Test1174CH-9ZZ15 RCS Gross Activity and Dose Equivalent I-131Determination
474DP-1LC01 RCS Activity Performance Indicator440ST-9RC02 ERFDADS (Preferred) Calculation of RCS Water Inventory43MiscellaneousTechnical Specification 3.4, "RCS"
NEI 99-02, "Regulatory Assessment Performance Guideline"ProceduresNumberTitleRevision40OP-9ZZ16RCS Drain Operations57DrawringsNumberTitleRevision01-M-RCP-001P & I Diagram - RCS2613-J-03D-109Containment Building Isometric
RCN-LT-103 Sensing Line313-J-01D-116Containment Building Isometric
RCN-PT-199A,
PT-101A,PT-102A,
PT-103 and
LT-110X Sensing Lines
513-J-01D-133Containment Building Isometric
RCN-PT-104, 102B, 101B,LT-110Y Sensing Line
413-J-01D-139Containment Building Isometric
RCN-PT-100X and
PT-100YPanel
RCN-A03 Sensing Line
513-JS-ZZS-197Fabrication Detail Condensate Pot Assembly Pressurizer1
AttachmentA-11

LIST OF ACRONYMS

AFWauxiliary feedwaterASMEAmerican Society of Mechanical Engineers

CAPcorrection action program

CRDRcondition report/disposition request

CFRCode of Federal RegulationsDEPdrill exercise performance

EALemergency action level

EPemergency preparedness

EROemergency response organization

EDGemergency diesel generator

FOFforce-on-force

NCVnoncited violationNOUEnotice of unusual event

NRCNuclear Regulatory Commission

PARprotection action requirements

PIperformance indicator

PVARPalo Verde action request

PVNGSPalo Verde Nuclear Generating Station

RCSreactor coolant system

ROreactor operator

SMshift manager

TStechnical specificationsSSCstructure, systems and component

USFARupdated final safety analysis report

WO work order