IR 05000528/2011006

on 03/23/11 - 04/29/11 Temporary Instruction 2515/183 Inspection Report 05000528/2011006, 05000529/2011006, and 05000530/2011006

ML11133A328
Person / Time
Site:	Palo Verde
Issue date:	05/13/2011
From:	Ryan Lantz NRC/RGN-IV/DRP/RPB-D
To:	Edington R Arizona Public Service Co
References
IR-11-006
Download: ML11133A328 (19)

Text

UNIT ED STAT ES NU C LE AR RE G UL AT O RY C O M M I S S I O N May 13, 2011

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000528/2011006, 05000529/2011006, and 05000530/2011006

Dear Mr. Edington:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station using Temporary Instruction 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on May 5, 2011, with Mr. R. Barnes, Director, Regulatory Affairs, and other members of your staff.

The objective of this inspection was to assess the adequacy of actions taken at Palo Verde Nuclear Generating Station in response to the Fukushima Daiichi Nuclear Station fuel damage event. The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the United States nuclear industrys readiness to respond to a similar event. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Arizona Public Service Company -2-

Sincerely,

/RA/

Ryan Lantz, Chief Project Branch D Division of Reactor Projects Docket Nos.: 50-528 50-529 50-530 License Nos.: NPF-41 NPF-51 NPF-74

Enclosure:

Inspection Report 05000528/2011006, 05000529/2011006, and 05000530/2011006 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000528, 05000529, 05000530 License: NPF-41, NPF-51, NPF-74 Report: 05000528/2011006, 05000529/2011006, and 05000530/2011006 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location: 5951 S. Wintersburg Road Tonopah, Arizona Dates: March 23 through April 29, 2011 Inspectors: M. Brown, Senior Resident Inspector J. Bashore, Resident Inspector M. Baquera, Resident Inspector Approved By: Ryan Lantz, Chief, Project Branch D Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000528/2011006, 05000529/2011006, and 05000530/2011006, 03/23/2011 - 04/29/2011;

Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Temporary Instruction 2515/183 -

Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced temporary instruction inspection. The inspection was conducted by resident and Region IV inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the temporary instruction is to be a high-level look at the industrys preparedness for events that may exceed the design basis for a plant. The focus of the temporary instruction was on

(1) assessing the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats;

(2) assessing the licensees capability to mitigate station blackout conditions;

(3) assessing the licensees capability to mitigate internal and external flooding events required by station design; and

(4) assessing the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific followup inspection will be performed at a later date.

INSPECTION RESULTS

The following table documents the NRC inspection at Palo Verde Nuclear Generating Station performed in accordance with Temporary Instruction 2515/183. The numbering system in the table corresponds to the inspection items in the temporary instruction.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 CFR 50.54(hh). Use Inspection Procedure 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. If Inspection Procedure 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or The licensee cross-referenced applicable equipment utilized in Procedure 79IS-9ZZ05, "PVNGS inspection that Severe Accident Mitigation Guidelines," to applicable procedures and verified through test and/or equipment is available inspection that the equipment was available and functional. The licensee tested active equipment and functional. Active and walked down and inspected passive equipment.

equipment shall be tested and passive Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed equipment shall be test results, discussed actions, reviewed records, etc.).

walked down and inspected. It is not expected that The inspectors walked down several of the strategies implemented in Procedure 79IS-9ZZ05 with permanently installed fire department and operations department personnel. The inspectors verified that equipment was equipment that is available to implement the procedures. The inspectors examined the B.5.b equipment trailer and tested under an hose trailer and verified equipment identified in the procedures was present in the trailers and existing regulatory properly labeled. The inspectors discussed the results of the walkdowns and inspections with the testing program be licensee and reviewed the records of the teams verification activities.

retested.

This review should be Discuss general results including corrective actions by licensee.

done for a reasonable sample of mitigating strategies/equipment.

The licensee identified that the severe accident management guidelines do not specify vehicle size to transport the B.5.b trailer. The licensee also identified that some equipment available to perform required actions, such as fire ladders, were not dedicated or labeled for B.5.b purposes. The licensee entered these issues into the corrective action program.

The inspectors concluded that the licensee adequately incorporated B.5.b requirements into station procedures and adequately staged and maintained the equipment necessary to implement the strategies. Specific equipment is clearly labeled, inventoried, and inspected on a regular basis to ensure the availability and reliability of the equipment if needed.

Licensee Action Describe the licensees actions to verify that procedures are in place and can be executed (e.g.,

walkdowns, demonstrations, tests, etc.)

b. Verify through The licensee verified through walkdowns that procedures required to implement B.5.b strategies walkdowns or are in place and are executable. The licensee validated Severe Accident Management Guidelines, demonstration that Appendices 1-7 (non-B.5.b strategies), by tabletop exercises while Appendices 8-17 (B.5.b procedures to strategies) were validated by plant walkdowns and equipment verification. Additionally, the implement the licensee validated procedures associated with the actions of the technical support center, strategies associated emergency operations facility, and backup emergency operations facility.

with B.5.b and 10 CFR 50.54(hh) are in place and are Describe inspector actions and the sample strategies reviewed. Assess whether procedures were executable. Licensees in place and could be used as intended.

may choose not to connect or operate permanently installed The inspectors walked down several B.5.b strategy procedures with representatives of the fire equipment during this department and operations department. Specific strategies included alternate methods of spent verification.

fuel pool cooling, manual operation of the turbine-driven auxiliary feedwater pump, and utilization of fire protection equipment to provide feedwater injection to the steam generators as an alternate This review should be core cooling method. The inspectors discussed the results of the walkdowns and inspections with done for a reasonable the licensee and reviewed the records of the licensees verification activities.

sample of mitigating strategies/equipment.

Discuss general results including corrective actions by licensee.

The licensee identified that severe accident management guidelines not directly related to B.5.b response (Appendices 1-7) were difficult to use and entered this issue into the corrective action program.

The inspectors concluded that procedures designed to implement the strategies associated with B.5.b could be executed by the licensee.

Licensee Action Describe the licensees actions and conclusions regarding training and qualifications of operators and support staff.

c. Verify the training and The licensee verified that the qualifications of personnel needed to implement the procedures and qualifications of work instructions are current. The licensee verified that personnel qualifications, as required by operators and the department policies, are in accordance with procedures. The licensee reviewed qualifications for support staff needed to all plant operators, fire department personnel, security personnel, and emergency response implement the organization personnel.

procedures and work instructions are current for activities related to Describe inspector actions and the sample strategies reviewed to assess training and qualifications B.5.b and severe of operators and support staff.

accident management guidelines as required by 10 CFR 50.54(hh).

The inspectors reviewed training records for fire department personnel and training schedules for operations department personnel. The inspectors interviewed operators regarding B.5.b training.

Additionally, the inspectors walked down several strategies with fire department personnel and plant operators to verify their ability to identify required equipment and successfully implement the procedures. The inspectors reviewed the records of activities performed by the licensee to verify that necessary plant personnel are properly qualified to implement the emergency plan and severe accident management guidelines and that all required qualifications are current.

Discuss general results including corrective actions by licensee.

The licensee identified that nonlicensed operators, reactor operators, senior reactor operators, and shift technical advisors do not have specific task qualifications on specific actions required by various severe accident management guidelines. The licensee initiated corrective actions to add these tasks to initial and continuous training requirements. The licensee identified that severe accident management guideline training is not included for specific emergency response organization positions. The licensee entered these issues into the corrective action program.

The inspectors concluded plant personnel are capable of implementing the procedures related to B.5.b and severe accident management guidelines, however, training program weaknesses could challenge operators if not corrected.

Licensee Action Describe the licensees actions and conclusions regarding applicable agreements and contracts are in place.

d. Verify that any The licensee reviewed each memorandum of understanding for external support. Each applicable agreements memorandum of understanding was evaluated to verify they are current and that no gaps exist to and contracts are in execute the memorandum of understanding.

place and are capable of meeting the conditions needed to For a sample of mitigating strategies involving contracts or agreements with offsite entities, mitigate the describe inspector actions to confirm agreements and contracts are in place and current (e.g.,

consequences of these confirm that offsite fire assistance agreement is in place and current).

events.

This review should be The inspectors independently reviewed standing agreements and contracts that are in place with done for a reasonable offsite entities.

sample of mitigating strategies/equipment.

Discuss general results including corrective actions by licensee.

The licensee did not identify any issues associated with current agreements. The inspectors verified that the agreements and contracts were current.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open The licensee did not identify any problems that have significant potential to prevent the success of corrective action any existing mitigating strategy.

documents to assess The licensee initiated 22 Palo Verde Action Requests associated with this section. Condition problems with Report Action Item 3668452 tracks the list of issues.

mitigating strategy implementation Although the licensee identified some issues in the implementation of the severe accident identified by the management guideline actions and response personnel training, Palo Verde would be able to fulfill licensee. Assess the the necessary response. Most of the issues identified constituted minor discrepancies with impact of the problem procedures or enhancements to improve the sites capability to respond to events.

on the mitigating capability and the remaining capability that is not impacted.

03.02 Assess the licensees capability to mitigate station blackout (conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Temporary Instruction 2515/120, "Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22," as a guideline. It is not intended that Temporary Instruction 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensees actions to verify the adequacy of equipment needed to mitigate a station blackout event.

a. Verify through The licensee reviewed the emergency operating procedures designed to mitigate station blackout walkdowns and and identified the standard appendices that potentially contained operator actions outside the inspection that all control room (AO actions). For all applicable standard appendices, the licensee identified all required materials are necessary equipment and verified that the equipment was available, staged, and functional.

adequate and properly staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable.

The inspectors reviewed the station blackout procedures to verify availability of any required equipment. The inspectors observed a routine surveillance test of a station blackout generator and verified that operators were able to successfully start and load the station blackout generators. The inspectors also reviewed past surveillance test records for the two station blackout generators.

Discuss general results including corrective actions by licensee.

The licensee identified that some equipment necessary to implement station blackout procedures (such as door stops, breaker racking tools, and portable lanterns) are available but not designated for station blackout or specifically identified in procedures. The licensee entered this issue into the corrective action program.

The inspectors concluded that all required materials needed to mitigate a station blackout are adequate and properly staged, tested, and maintained.

Licensee Action Describe the licensees actions to verify the capability to mitigate a station blackout event.

b. Demonstrate through The licensee reviewed the emergency operating procedures designed to mitigate station blackout walkdowns that and identified the standard appendices that potentially contained operator actions outside the procedures for control room (AO actions). Those that contained actions outside the control room were verified by response to a station plant walkdowns. Additionally, the licensee conducted a training evolution with licensed operators blackout are in the simulator to verify the ability of control room operators to implement the procedures for executable.

station blackout.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The inspectors reviewed records of the walkdowns completed by the licensee to verify that station blackout procedures were executable. Additionally, the inspectors observed the station blackout scenario in the simulator with licensed operators. The inspectors verified operators were able to successfully implement the station blackout procedure from the control room.

Discuss general results including corrective actions by licensee.

The licensee identified that one appendix would be difficult to implement. It was associated with operation of the non-safety related auxiliary feedwater pump during station blackout and required local monitoring of instrument air pressure and emergency nitrogen supply. Additional issues identified during this review were entered into the Palo Verde corrective action program as enhancements to improve the sites response during a station blackout event. The licensee initiated 23 Palo Verde Action Requests associated with this section. Condition Report Action Item 3668452 tracks the list of issues.

The inspectors concluded that procedures required for station blackout response are executable.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to Inspection Procedure 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding," as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensees actions to verify the capability to mitigate existing design basis flooding events.

a. Verify through Palo Verde is not susceptible to any external flooding events. The licensee reviewed the Updated walkdowns and Final Safety Analysis Report and reverified that no credible external flooding scenarios exist. For inspection that all internal flooding events, the licensee conducted walkdowns and inspections of the following required materials are locations to verify that flood barriers, penetration seals and doors were functional: auxiliary adequate and properly buildings, diesel buildings, main steam support structure buildings, control buildings, and essential staged, tested, and pipe and condensate storage tank tunnels. The licensee verified that credited drain and sump maintained.

valves were functional and preventive maintenance had been conducted as required.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the Updated Final Safety Analysis Report to verify that Palo Verde is not susceptible to external flooding events. The inspectors reviewed the licensees records associated with their walkdowns and inspections. In addition, the inspectors performed two internal flooding inspection samples in accordance with Inspection Procedure 71111.06 for the Unit 3 safety injection pump rooms and Unit 1 condensate storage tank tunnel and auxiliary feedwater pump rooms.

Discuss general results including corrective actions by licensee.

The licensee identified some barriers that did not meet the documented plant configuration during the walkdowns and entered the issues into the corrective action program. The licensee also identified some enhancements that were entered into the corrective action program. The licensee initiated 12 Palo Verde Action Requests associated with this section. Condition Report Action Item 3668452 tracks the list of issues.

The inspectors concluded that the issues did not affect the ability of structures, systems, and components to mitigate internal flooding threats and also concluded that procedures were in place and could be used as intended.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use Inspection Procedure 71111.21, "Component Design Basis Inspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Licensee Action Describe the licensees actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through The licensee conducted walkdowns and inspections of internal flooding barriers, as described in walkdowns that all Section 03.03, and fire protection equipment to assess the material condition of the equipment.

required materials are Additionally, the licensee convened a group of senior personnel to postulate impacts to mitigation adequate and properly of flood and fire following a safe shutdown earthquake. The licensee also conducted a review of staged, tested, and the severe accident management guidelines to verify that the required material would be available maintained.

following a safe shutdown earthquake.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the results of licensee plant walkdowns. The inspectors also walked down fire protection equipment with the Palo Verde fire marshal. In addition, the inspectors walked down internal flooding mitigation equipment as part of the internal flooding inspection. The inspectors discussed the results with the licensee.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee identified the following issues: some penetration seals, designed nonseismic, could fail during a seismic event, allowing water intrusion into rooms containing electrical safe shutdown equipment; three nonsafety-related tanks near each unit could rupture and cause water intrusion into the plant; and internal flooding calculations do not include water introduced by fire department personnel fighting fires within the plant following a seismic event. The licensee also identified potential flooding vulnerabilities in the diesel generator and electrical switchgear rooms based on revisions to the internal flooding probabilistic risk assessment. The licensee entered these issues into the corrective action program. The licensee initiated six Palo Verde Action Requests associated with this section. Condition Report Action Item 3668452 tracks the list of issues. The licensee did not identify any new mitigating strategies.

The inspectors concluded that equipment is available and useable and procedures are in place and can be used as intended.

EXIT MEETING SUMMARY The inspectors presented the inspection results to Mr. R. Barnes, Director, Regulatory Affairs, and other members of licensee management at the conclusion of the inspection on May 5, 2011. While some proprietary information was reviewed during this inspection, no proprietary information was included in this report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Barnes, Director, Regulatory Affairs

R. Bement, Senior Vice President, Site Operations

J. Cadogan, Director, Plant Engineering

D. Dailey, Control Room Supervisor, Unit 3 Operations

D. Hautala, Senior Engineer, Regulatory Affairs

M. Heider, Nuclear Engineering Department Leader

G. Hettel, Plant Manager

M. McGhee, Compliance Section Leader, Nuclear Regulatory Affairs

D. Mims, Senior Vice President, Regulatory and Oversight

M. Powell, Director, Nuclear Fuels Management

M. Webb, Compliance Section Leader, Nuclear Regulatory Affairs