IR 05000528/2018001

NRC Integrated Inspection Report 05000528/2018001, 05000529/2018001, and 05000530/2018001

ML18127A004
Person / Time
Site:	Palo Verde
Issue date:	05/07/2018
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Bement R Arizona Public Service Co
Miller G
References
IR 2018001
Download: ML18127A004 (32)

Text

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2018001, 05000529/2018001, AND 05000530/2018001

Dear Mr. Bement:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On April 11, 2018, the NRC inspectors discussed the results of this inspection with Mr. Jack Cadogan and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Palo Verde Nuclear Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Geoffrey B. Miller, 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 05000528/2018001, 05000529/2018001, 05000530/2018001 w/ Attachment:

1. Supplemental Information 2. O

Inspection Report

Docket Numbers: 05000528, 05000529, 05000530 License Numbers: NPF-41, NPF-51, NPF-74 Report Numbers: 05000528/2018001, 05000529/2018001, and 05000530/2018001 Enterprise Identifier: I-2018-001-0013 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: 5801 South Wintersburg Road, Tonopah, AZ 85354 Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, PhD, Resident Inspector D. You, Resident Inspector L. Carson, Senior Health Physicist S. Hedger, Emergency Preparedness Inspector Approved By: Geoffrey B. Miller, Chief, Project Branch D, Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Palo Verde Nuclear Generating Station,

Units 1, 2, and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Inadequate Post Maintenance Test Instructions for Diesel Fuel Oil Transfer Pump Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green [H.12] - Human 71111.12 -

Systems NCV 05000528/2018001-01 Performance, Avoid Maintenance Closed Complacency Effectiveness The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to prescribe appropriate work instructions for maintenance on the Unit 1 diesel fuel oil transfer pump A.

Specifically, following power cable maintenance on November 9, 2017, the instructions for conducting a post-maintenance test for the transfer pump were inadequate to detect a high resistance connection in the associated motor control center.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On February 15, 2018, the unit automatically tripped from full power when a control system failure caused a loss of generator field excitation. The unit was restarted on February 19, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

Units 2 and 3 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 containment spray system B on January 4, 2018

(2) Unit 2 auxiliary feedwater system A on January 30, 2018

(3) Unit 3 control building heating ventilation and air conditioning B on March 16, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 3 containment spray system on January 18, 2018.

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 3 main turbine operating deck and bearings area, Fire Zones 9 and 10, on January 4, 2018

(2) Unit 2 control room, Fire Zone 17, on January 19, 2018

(3) Unit 2 containment spray pump A room and adjacent corridor, Fire Zones 30A and 88A, on January 23, 2018

(4) Unit 1 high pressure safety injection pump B room, Fire Zone 31B on February 2, 2018

(5) Unit 3 vital switchgear room A, Fire Zone 5A, on February 8, 2018

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated Unit 1 diesel generator A lube oil and jacket water heat exchanger performance on February 21, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated risk informed completion time program and 10 CFR 50.69 program classroom training on January 31, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance synchronizing the Unit 1 main generator to the grid following a reactor trip caused by a fault in the main generator excitation system on February 19, 2018.

The inspectors observed and evaluated operator response to Unit 3 loss of A channel indication for main steam and feedwater isolation valves, MSIV-170, 171, 180, 181, and FWIV-174, 177, on February 27, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Reach rod operator gear box maintenance on safety injection valves SI-184 and SI-185 in Units 2 and 3

(2) Diesel fuel oil transfer pump predictive engineering cable testing

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1 elevated risk due to failure of emergency core cooling system A combined minimum flow recirculation valve SIA-UV660 on January 4, 2018

(2) Unit 1 emergent risk due to diesel generator A unexpectedly shutdown during a surveillance run on January 5, 2018

(3) Unit 3 elevated risk due to planned maintenance on containment spray pump A atmospheric dump valves SG-179A and SG-184A, and low pressure safety injection valve SI-687 January 29, 2018 through February 4, 2018

(4) Unit 1 elevated risk due to diesel generator A super outage on February 26, 2018

(5) Unit 2 elevated risk due to diesel generator B super outage on March 19, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 abnormal trend for containment sump level transmitter, RDL-411, on January 3, 2018

(2) Unit 1 essential spray pond A pressure relief valves lifting during pump starts on January 25, 2018

(3) Unit 3 containment spray discharge to shutdown cooling heat exchanger valve, SI-685, failed to re-open during breaker maintenance on January 31, 2018

(4) Unit 1 diesel generator B fuel oil leak from cylinder 8L fuel oil jerk pump on February 13, 2018

(5) Unit 1 calculated qualified life of safety injection combined header isolation valves, SI-660 and SI-659, on February 23, 2018

(6) Unit 3 loss of indication of the train A main steam isolation valves and feedwater isolation valves (MSIV-170, 171, 180, 181 and FWIV-174, 177) on February 27, 2018

(7) Unit 1 auxiliary feedwater bypass motor operated valves SG-138A and SG-139A T-drains on March 6, 2018

(8) Unit 1 essential cooling water pump A oil samples appear to contain metal or debris on March 7, 2018

(9) Unit 2 steam generator sodium concentration increase on March 12, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 480V electrical breaker for containment spray to low pressure safety cross-connect valve, SI-696, replacement with General Electrical model Spectra breaker per Design Equivalent Change 01035 on March 15, 2018

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 emergency core cooling system A combined minimum flow recirculation valve SIA-UV660 following limit switch adjustment on January 4, 2018

(2) Unit 1 diesel generator A cooldown relay, power supply, and test hand switch replacement following an unplanned cooldown during a monthly surveillance run on January 9, 2018

(3) Unit 3 containment spray pump A test following breaker maintenance on February 6, 2018

(4) Unit 3 30-volt power supply replacement for lost indication to main steam isolation valves on February 28, 2018

(5) Unit 2 essential cooling water pump A test and flow balance following planned maintenance to calibrate motor overcurrent relays and replace a high discharge pressure switch on March 20, 2018

(6) Unit 2 diesel generator A emergency mode simulated engineered safeguards features fast start test following online maintenance outage on March 23, 2018

71111.20 - Refueling and Other Outage Activities

The inspectors evaluated activities from February 15 - 19, 2018, for the Unit 1 forced outage due to an unplanned reactor trip caused by a fault in the main generator excitation circuitry.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) Unit 1 diesel fuel oil transfer pump A inservice test on January 24, 2018

(2) Unit 1 atmospheric dump valve 178 stroke time testing on February 9, 2018

(3) Unit 2 containment leakage type B and C testing, SR 3.0.3 entry for missed surveillance on February 28, 2018

(4) Unit 3 diesel fuel oil transfer pump A inservice test on March 7, 2018

(5) Unit 3, essential chiller A vibration analysis on March 8, 2018

(6) Unit 1 containment spray pump B inservice test on March 22, 2018

In-service (1 Sample)

(1) Unit 2 containment spray pump A inservice test on March 1, 2018

71114.02 - Alert and Notification System Testing

The inspectors evaluated the maintenance and testing of the alert and notification system between May 1, 2016 - February 20, 2018.

71114.03 - Emergency Response Organization Staffing and Augmentation System

The inspectors evaluated the readiness of the Emergency Response Organization between May 1, 2016 - February 20, 2018. Inspectors also evaluated the licensees ability to staff their emergency response facilities in accordance with emergency plan commitments.

71114.04 - Emergency Action Level and Emergency Plan Changes

The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between May 1, 2016 - February 20, 2018. The evaluation reviewed screenings and evaluations documenting the implementation of this process. The review of the change process documentation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

The inspectors evaluated the maintenance of the emergency preparedness program between May 1, 2016 - February 20, 2018. The evaluation reviewed activations of the emergency plan, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.

71114.06 - Drill Evaluation Emergency Planning Drill

The inspectors evaluated a full-scale emergency preparedness drill on February 13,

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning

The inspectors evaluated the licensees radiological work planning by reviewing the following activities:

(1) RWP 2017-9-1016, RMC Operations and Routine Tasks

(2) RWP 2018-1-1523, Temporary Mat Insulation Fiber Inspection

(3) RWP 2017-3002, Reactor Destack/Restack

(4) RWP 2017-3015, Cavity Decontamination

(5) RWP 2017-3039, 10-Year In-Service Inspection Vessel Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

71124.04 - Occupational Dose Assessment Source Term Characterization

===The inspectors evaluated the licensees source term characterization.

External Dosimetry===

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017 -

December 31, 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017 -

December 31, 2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017 -

December 31, 2017)

(4) MS05: Safety System Functional Failures (SSFFs) Sample (April 1, 2017 -

December 31, 2017)

(5) EP01: Drill/Exercise Performance (DEP) Sample (January 1, 2017 - December 31, 2017)

(6) EP02: Emergency Response Organization (ERO) Drill Participation Sample (January 1, 2017 - December 31, 2017)

(7) EP03: Alert and Notification System (ANS) Reliability Sample (January 1, 2017 -

December 31, 2017)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Multiple failures of diesel generator underfrequency protective relay on March 26, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

The inspectors evaluated the Unit 1 reactor trip following a loss of main generator excitation and licensees response on February 15 - 16,

INSPECTION RESULTS

Inadequate Post Maintenance Test Instructions for Diesel Fuel Oil Transfer Pump Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.12] -

==71111.12 - Systems NCV 05000528/2018001-01 Human Maintenance

==

Closed Performance, Effectiveness Avoid Complacency The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to prescribe appropriate work instructions for maintenance on the Unit 1 diesel fuel oil transfer pump A.

Specifically, following power cable maintenance on November 9, 2017, the instructions for conducting a post-maintenance test for the transfer pump were inadequate to detect a high resistance connection in the associated motor control center.

Description:

On November 12, 2017, the licensee was conducting a 24-hour surveillance test run of Unit 1 diesel generator (EDG) A. The EDG was fully loaded at 10:19 a.m. which began the 24-hour test period. At 10:53 a.m., control room operators received a fuel oil transfer pump A inoperable equipment status alarm. The diesel fuel oil transfer pump A did not start on a diesel fuel oil day tank low level signal. Operators manually unloaded and stopped the EDG a few minutes later and declared the Unit 1 EDG A inoperable due to its inability to run for its design basis mission time and began troubleshooting the failed fuel oil transfer pump.

Licensee electricians took electrical resistance readings across the connections in the motor control center for the fuel oil transfer pump breaker. The electricians identified that the direct cause of the transfer pump failure was a high variable resistance secondary stab connection in the motor control center cubicle. The electricians removed the breaker and cleaned and adjusted the connection. Electricians reinstalled the breaker and confirmed an acceptable as left connection resistance of less than 0.2 ohms. The diesel fuel oil transfer pump was successfully retested with a 20 minute functional run and the Unit 1 EDG A was declared operable following the successful completion of the 24-hour surveillance run on November 14, 2017.

The licensees apparent cause investigation determined that the diesel fuel oil transfer pump breaker had been removed from service for periodic predictive maintenance on November 9, 2017, under work order 4685719. During this maintenance activity licensee engineers disconnected the diesel fuel oil transfer pump motor power and control cables for megger testing. Cable lug screw connections attach each of these cables to the secondary stab connections on the movable motor breaker and the stationary motor control center chassis.

Cable connections on the secondary stab connections are removed for testing, and then following testing, the cables are re-landed onto the secondary stabs of the breaker and motor control center chassis. The licensees work planners had not recognized the possibility that removing and re-landing the cables on the lug screw connections had the potential to disturb the motor control center secondary stab connections.

The post-maintenance test associated with the cable testing was a momentary start of the diesel fuel oil transfer pump. The transfer pumps control switch was held in the start position for only a few seconds. The licensees apparent cause investigation identified that nonintrusive as-left quantitative resistance checks could have been used to assess the integrity of the secondary stab connections. The licensee performs similar checks when performing individual breaker cubicle preventative maintenance tasks that actively remove and re-test the individual motor control center bucket. Such a check was the method used by the electricians to initially diagnose the breaker failure. However, no such quantitative resistance check was specified in the cable testing work order.

The post-maintenance test was not written in accordance with station procedure 30DP-9WP04, Post-Maintenance Testing Development, Revision 19, Step 4.1.1, which states, in part, that the post-maintenance test shall ensure that equipment performs its intended function when returned to service following maintenance, that a new deficiency has not been created, and that the equipment will function as designed for safe and reliable plant operation.

The act of de-terminating and re-terminating the diesel fuel oil transfer pump cable for testing created new failure deficiency by disturbing electrical continuity and creating a high resistance condition at the secondary stab connection that impacted EDG operability. The post-maintenance test following the cable testing maintenance was not adequate to ensure that a new deficiency had not been created.

Corrective Action: The licensee has taken corrective action to revise the work instructions for performing future cable testing to include quantitative resistance retests when re-terminating motor control center secondary stab connections. As an interim measure, the inspectors confirmed that all safety-related 480V electrical breakers that have been subject to this cable testing have performed satisfactorily during subsequent diesel generator surveillance testing.

Corrective Action Reference: Condition Report 17-16497

Performance Assessment:

Performance Deficiency: The licensees failure to prescribe appropriate retest activities following predictive maintenance on diesel fuel oil transfer pump cables is a performance deficiency.

Screening: The performance deficiency is more-than-minor and a finding because it is associated with the equipment performance attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on November 9, 2017, the licensee performed cable testing that disturbed the power cables for the Unit 1 diesel fuel oil transfer pump A. Without an appropriate post-maintenance test, this activity rendered the Unit 1 diesel generator A inoperable.

Significance: The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions and determined that the finding was of very low safety significance (Green) because the finding did not represent an actual loss of safety function of a single train for greater that its technical specification allowed outage time.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with the avoid complacency aspect. Specifically, licensee work planners did not consider potential undesired consequences associated with disturbing the power cables leads, instead relying on past successful tests [H.12].

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on November 9, 2017, the licensee performed maintenance on the Unit 1 diesel fuel oil transfer pump A, an activity affecting quality to which Appendix B applies, without documented instructions, procedures, or drawings of a type appropriate to the circumstances. Specifically, work order 4685719 did not include appropriate testing to ensure the maintenance was successful and the pump was returned to service, and as a result, the Unit 1 diesel generator A was rendered inoperable from November 9, 2017 to November 14, 2017.

Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 16, 2018, the inspector presented the radiation safety inspection results to Ms. M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the licensee staff.

On March 2, 2018, the inspector provided a debrief for the emergency preparedness program inspection to Mr. M. McLaughlin, Vice President, Operations Support, and other members of the licensee staff. On March 29, 2018, the inspector communicated the inspection results telephonically to Mr. T. Weber, Acting Director, Nuclear Regulatory Affairs, and other members of the licensee staff.

On April 11, 2018, the inspector presented the quarterly residents inspection results to Mr. J. Cadogan, Senior Vice President, Site Operations, and other members of the licensee staff.

SUPPLEMENTAL INFORMATION

DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

40ST-9AF07 Auxiliary Feedwater Pump AFA-P01 Monthly Valve 6

Alignment

40ST-9SI13 LPSI and CS System Alignment Verification 33

Condition Reports (CRs)

16-17321 17-03027

Drawings

Number Title Revision

03-M-HJP-001 P&I Diagram Control Building HVAC 14

03-M-HJP-002 P&I Diagram Control Building HVAC 14

03-M-SIP-001 P&I Diagram Safety Injection & Shutdown Cooling System 49

03-P-SIF-0207 Auxiliary Building Isometric Safety Injection System LPSI & 6

Cont. Spray Discharge

03-P-SIF-0201 Auxiliary Building Isometric Safety Injection System ESF 7

Pump Suction Lines

Miscellaneous

Number Title Revision

STM-30D System Training Manual Volume 30D: Control Building 6

HVAC System (HJ)

Section 1R05: Fire Protection

Procedures

Number Title Revision

14FT-9FP70 Appendix R & Former Tech Spec Penetration Seal Surveillance 13

Condition Reports (CRs)

17-03870 18-00999

Miscellaneous

Number Title Revision/Date

PVNGS Pre-Fire Strategies Manual 26

13-MM-0650 Fire Protection & Spray System Sub 007

13-MS-A083 NFPA Code Applicability and Conformance Review 007

4834415 Fire Safety Component Condition Record November 3, 2016

4834430 Fire Safety Component Condition Record November 3, 2016

4843902 Fire Safety Component Condition Record December 6, 2016

Unit 3 Tamper/Vital/Security Tour - Post 31 February 7, 2018

4971714 Open Door/Hatch/Floor Plug Permit January 29, 2018

4971687 Open Door/Hatch/Floor Plug Permit January 29, 2018

Section 1R07: Heat Sink Performance

Procedures

Number Title Revision

73DP-9ZZ21 Heat Exchanger Visual Inspection 6

73DP-9ZZ11 Heat Exchanger Program 15

Condition Reports (CRs)

18-03133 18-03138 18-03139

Work Orders (WOs)

4591574 4591575 4667054 4667055 4667098

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

40OP-9MB01 Main Generation and Excitation 63

40DP-9OP02 Conduct of Operations 72

Procedures

Number Title Revision

40AL-9RK6A Panel B06A Alarm Responses 18

Condition Reports (CRs)

18-02797 18-02593 18-03215

Miscellaneous

Number Title Date

Current Alarm Status Report February 16, 2018

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

2MT-9ZZ74 Molded Case Circuit Breaker Test 48

30DP-9WP04 Post-Maintenance Testing Development 19

Condition Reports (CRs)

17-08025-005 17-08025 17-16497

Work Orders (WOs)

25959 4925966 4925967 4925969 4685719

4788985

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

40DP-9AP21 Protected Equipment 7

70DP-0RA05 Assessment and Management of Risk when Performing 23

Maintenance in Modes 1 and 2

40MT-9ZZ01 Operations Maintenance Activities 5

40DP-9RS01 Operations Department Online Nuclear Risk Management 4

Mode 1 and 2

Condition Reports (CRs)

18-00249 185-00136 18-00336 18-02544

Miscellaneous

Number Title Date

Schedulers Evaluation for PV Unit 1 January 4, 2018

Schedulers Evaluation for PV Unit 1 February 23, 2018

Schedulers Evaluation for PV Unit 3 February 1, 2018

Schedulers Evaluation for PV Unit 2 March 19, 2018

Unit 3 Archived Operator Logs January 29, 2018 -

February 4, 2018

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

40ST-9ZZm1 Operations Mode 1 Surveillance Logs 71

40AL-9RK6A Panel B06A Alarm Responses 18

74DP-9CY04 Systems Chemistry Specifications 94

Condition Reports (CRs)

17-18475 12-01397 17-17856 13-01198 18-03127

17-16393 18-03215 18-03291 18-02839 18-01610

18-02334 3127427 18-02468 18-03980

Miscellaneous

Number Title Revision/Date

03-E-SGF-023 Control Wiring Diagram Main Steam Isolation Valves 11

18-02334-003 Engineering Evaluation February 15, 2018

28056 Adverse CRDR July 19, 2013

EQ Program Manual 26

Section 1R18: Plant Modifications

Condition Reports (CRs)

18-04116

Work Orders (WOs)

4989102

Miscellaneous

Number Title Date

DEC-01035 Design Equivalent Change April 12, 2017

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

40OP-9CH12 Refueling Water Tank (RWT) Operations 41

2MT-9ZZ13 Testing and Calibration of 121FC66K01A Time Overcurrent 4

Relays

2MT-9ZZ17 Testing and Calibration of 12PJC11AV1A Instantaneous 4

Overcurrent Relays

40OP-9EW02 Essential Cooling Water System (EW) Train B 26

40ST-9DG01 Diesel Generator A Test 49

73ST-9DG08 Class 1E Diesel Generator Load Reject 24 Hour Rated Load 13

and Hot Start Test Train B

40ST-9DG02 Diesel Generator B Test 54

Condition Reports (CRs)

18-00136 18-00197 18-01931 18-00210 18-00290

18-00336 18-00377 18-00346 18-04731 18-04732

Work Orders (WOs)

4964492 4822983 4981967 4726747 4821113

4847651 4965079 4972486 4847637

Drawings

Number Title Revision

01-E-DGB-007 Elementary Diagram: Diesel Engine Control 15

01-E-DGF-007 Control Wiring Diagram: Diesel Engine 13

13-M018-00141 Control Schematic (Starting Sequence Control) 25

Miscellaneous

Number Title Revision/Date

18-00210-004 Engineering Evaluation: EDG 1A Unexpected Cooldown January 8, 2018

during Surveillance Run 1/5/2018

Section 1R20: Refueling and Other Outage Activities

Procedures

Number Title Revision

40OP-9MB01 Main Generation and Excitation 63

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

73DP-9CL02 Containment Leakage Rate Testing Program 33

73ST-9XI20 Atmospheric Dump Valves - Inservice Test 47

73ST-9SI06 Containment Spray Pumps and Check valves - Inservice 42

Test

73ST-9DF01 Diesel Fuel Oil Transfer Pumps - Inservice Test 34

40DP-9OP06 Operations Department Repetitive Task Program 130

73ST-9SI06 Containment Spray Pumps and Check Valves- Inservice 42

Test

Condition Reports (CRs)

16-15793 18-03304 18-01314 18-03825

Work Orders (WOs)

22921 4840032 4843076 4843390

Miscellaneous

Number Title Revision/Date

13-JC-SI-0215 Containment Spray Pump Discharge Flow Indication 18

Loops Uncertainty Calculation

18-01314-002 Engineering Evaluation: ADV 178 Fast Stroke Time January 26, 2018

18-03304-002 Engineering Evaluation: SR 3.0.3 Evaluation for March 2, 2018

SB-200, 202, and 205

Section 1EP2: Alert and Notification System Testing

Miscellaneous Documents

Number Title Date

ID/Letter Palo Verde Nuclear Generating Station Alert and May 26, 2017

Number: Notification System (ANS) FEMA 350 Report -

240-02802 May 2017

Palo Verde Nuclear Generating Station, Alert and May 2017

Notification System (ANS), FEMA 350 Report

Palo Verde Nuclear Generating Station Siren Operating November 2015

Manual January 4, 2018

Letter from FEMA Region IX to Director, Division of September 19,

Emergency Management, State of Arizona 2017

State of Arizona/Maricopa County Offsite Emergency November 2017

Response Plan, Palo Verde Nuclear Generating Station

The Maricopa County Sheriffs Office Emergency August 2016

Response to Palo Verde Nuclear Generating Station

Work Orders (WOs)

474965/0

Section 1EP3: Emergency Response Organization Staffing and Augmentation

Procedures

Number Title Revision

EP-0902 Notifications 10

EP-0901 Classifications 10

40AL-9RK7C Panel B07C Alarm Responses 15

40AO-9ZZ21 Acts of Nature 37

79IS-9SM01 Analysis of Seismic Event 27

Miscellaneous Documents

Number Title Date

240-02799 2017 1 Quarter - Emergency Preparedness

st

March 21, 2017

JF/MA Augmentation Drill Report

240-02803 2017 2nd Quarter - Emergency Preparedness June 6, 2017

CS/MA Augmentation Drill Report

240-02797 2017 3rd Quarter - Emergency Preparedness July 25, 2017

Augmentation Drill Report (After Hours)

240-02808 2017 3rd Quarter - Emergency Preparedness September 6, 2017

Augmentation Drill Report

240-02817 2017 4th Quarter - Emergency Preparedness December 13,

CS/ma Augmentation Drill Report 2017

240-02790 2016 2nd Quarter - Emergency Preparedness June 23, 2016

JF/MA Augmentation Drill Report

240-02791 2016 3rd Quarter - Emergency Preparedness August 3, 2016

JF/MA Augmentation Drill Report

240-02798 December 5, 2016, Alert Event Report January 17, 2017

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Procedure

Number Title Revision

16DP-0EP22 Emergency Plan Maintenance 11, 12

Miscellaneous Documents

Number Title Date

Evaluation Replace the Meteorological Instrumentation and Data August 8, 2017

Tracking Number Transmission System (MDTS)

2017-001E

Evaluation EP-0900, Rev. 16 August 17, 2017

Tracking Number

2017-003E

Evaluation EP-0901, Rev. 10 August 21, 2017

Tracking Number

2017-004E

Screening 74RM-9EF42, Radiation Monitor Alarm Setpoint April 16, 2017

Tracking Number Determination, Rev. 30

2017-002S

Screening Procedure EP-0901, Classifications, Added New EALs August 20, 2017

Tracking Number form EPLAN R60, Revise PV Proc Format

2017-022S

Miscellaneous Documents

Number Title Date

Screening EP-905, Revision 9, Protective Actions June 7, 2017

Tracking Number

2017-014S

Screening DMWO 3452940 Palo Verde Nuclear Generating September 8,

Tracking Number Station Radio Replacement Project 2017

2017-023S

Screening 40AO-9ZZ18 R018 Fire Outside Control Room September 26,

Tracking Number 2017

2017-029S

EPM Tracking DEC-00720 Allow Solar-Charged Offsite Sirens to February 18,

Number Replace AC-Charged Offsite Sirens 2015

2015-006S

Section 1EP5: Maintenance of Emergency Preparedness

Procedures

Number Title Revision

01DP-0AP12 Condition Reporting Process 28

01DP-0AP12-01 Condition Reporting Process Administrative Guide 4

EP-0905 Protective Actions 9

EP-0902 Notifications 8, 9, 10

16DP-0EP31 Emergency Preparedness Equipment Out-of-Service 9

16DP-0EP27 Emergency Preparedness Equipment Testing 10

16DP-0EP28 Emergency Facility/Kit Inventories and Inspections 5

Condition Reports (CRs)

16-08461 16-09213 16-11134 16-11930 16-12640 16-13501

16-14593 16-14934 16-16710 17-02188 17-03147 17-03149

17-03202 17-03605 17-03721 17-03736 17-03826 17-03828

17-03829 17-03884 17-04633 17-06893 17-08328 17-10906

17-10949 17-11437 17-13663 17-14927 17-15449 17-15797

17-15884 17-16771 17-17091 17-17218 17-17739 17-18443

18-03244

Miscellaneous Documents

Number Title Revision/Date

KLD TR-983 Palo Verde Nuclear Generating Station, December 7,

2017 Population Update Analysis 2017

KLD TR-895 Palo Verde Nuclear Generating Station, December 8,

2016 Population Update Analysis 2016

Updated Review of Palo Verde Nuclear Generating September 29,

Station Emergency Plan 2016 Letters of Agreement 2016

Letter # 240- 2017 Review of Palo Verde Nuclear Generating Station December 26,

2819 Emergency Plan Letters of Agreement 2017

NAD Audit 2016- Nuclear Assurance Department (NAD) Audit Plan and December 14,

010 Report, 2016-010, Emergency Preparedness 2016

Palo Verde Nuclear Generating Station After Action August 18,

Report/Improvement Plan, Exercise Date - June 1, 2017

2017, Radiological Emergency Preparedness Program

ID: 240-02806 2017 Onsite Contaminated Injury/Health Physics Drill June 23, 2017

Report (Revised)

ID: 240-02816 2017 Health Physics Drill Report (November 2017) December 12,

2017

ID: 240-02818 1709 ERO Mini Drill - ERO Blue Team December 21,

(December 2017) 2017

NAD Audit 2017- Nuclear Assurance Department (NAD) Audit Plan and January 25,

008 Report, 2017-008, Emergency Preparedness 2018

240-02812 1704 and 1705 ERO Mini Drills - ERO White Team and October 18,

CS/MA Green Team (June and July 2017) 2017

240-02813 1706 ERO Mini Drill - ERO Gold Team (July 2017) October 18,

CS/MA 2017

240-02814 1707 ERO Mini Drill - ERO Red Team (August 2017) October 18,

TW/MA Revision 1 2017

Emergency Response Facility Telephone Book, January 1,

1st Quarter Edition 2018 2018

240-02801 1702 IPZ Evaluated Exercise - ERO White Team April 6, 2017

JF/MA (March 2017)

240-02797 1608 ERO Mini Drill - ERO Red Team January 4,

JF/MA (December 2016) 2017

240-02792 1604 and 1605 ERO Drills September 14,

JF/MA 2016

240-02793 1606 ERO Mini Drill - ERO Green Team October 4,

JF/MA (September 2016) 2016

Miscellaneous Documents

Number Title Revision/Date

240-02795 1609 Off-Hours Drive-in Augmentation Drill - December 2,

JF/MA (November 2016) 2016

240-02796 2016 Health Physics Drill Report (November 2016) December 7,

2016

Evaluation Evaluate Adding STSC ENS Communicator Duties to September 7,

Report 16-11134 STSC Communicator 2016

17-11437-002 Actual Event Investigation, Unit 3 Ammonia Sight glass September 28,

Break 2017

17-13663-001 Actual Event Investigation, Unit 2 Loss of Annunciators October 11,

2017

Level 4 Default Values Used in Dose Assessment November 30,

Evaluation 2017

Report 17-

15797-001

Document No. Master Agreement Between Arizona Public Service 0

500599510 Company and Westinghouse Electric Company LLC for

Goods and Services (Effective January 29, 2016 to

December 31, 2018)

Palo Verde Nuclear Generating Station After Action May 26, 2017

Report/Improvement Plan, Exercise Dates - March 7-8,

2017, Radiological Emergency Preparedness Program

(REPP)

240-02789 2016 Health Physics Drill Report (Re-Demonstration) June 9, 2016

JF/TW

240-02788 2016 Contaminated Injury/Health Physics Drill Report April 22, 2016

JF/MA

Palo Verde Nuclear Generating Station After Action February 9,

Report/Improvement Plan, Exercise Date - 2017

November 16, 2016, Radiological Emergency

Preparedness Program (REPP)

240-02787 1602 IPZ Exercise - ERO Green Team (March 2016) March 25, 2016

JF/MA

Palo Verde Nuclear Generating Station After Action February 9,

Report/Improvement Plan, Exercise Date - 2017

November 16, 2016, Radiological Emergency

Preparedness Program (REPP)

Level 3 Evaluation Report 18-02668-002 March 22, 2018

Work Orders (WOs)

4782667 4783959/0 4787729/0 4787847/0 4836236

4836263/0 4860832/0 4862234/0 4862502/0 4885361/0

4889725/0 4896971/0 4901070 4916668/0 4918303/0

4918455/0 4937577/0 4947802/0

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision

EP-0900 Emergency Response Organization (ERO) Position 16

Checklists

EP-0901 Classifications 10

Condition Reports (CRs)

18-02352 18-02503 18-02655

Section 2RS2: Occupational ALARA Planning and Controls

Procedures

Number Title Revision

75DP-0RP03 ALARA Program Overview 06

75DP-0RP06 ALARA Committee 07

75DP-0RP08 Managing Radiological Risk 02

75RP-9RP02 Radiation Work Permits 31

75RP-9RP25 Temporary Shielding 14

75TD-9RP02 ALARA Work Planning 11

Audits and Self-Assessments

Title Date

PVGS Integrated Performance Assessment Report Radiation September 14, 2017

Protection 2nd Quarter 2017

2016 Annual ALARA/Management Evaluation Report June 23, 2017

2016 Annual Radiation Protection Program Summary Report July 27, 2017

Condition Reports (CRs)

17-15502 17-15529 17-15802 17-16741 17-17944

17-18180 18-01890

Radiation Work Permits/ALARA Reviews

Number Title

RWP 2017-9-1016 RMC Operations and Routine Tasks

RWP 2018-1-1523 Temporary Mat Insulation Fiber Inspection

RWP 2017-3002 Reactor Destack/Restack

RWP 2017-3015 Cavity Decontamination

RWP 2017-3039 10-Year In-Service Inspection Vessel

Miscellaneous

Title Date

ALARA 5-Year Plan 2015 - 2019 November 2015

1R20 Radiological Safety Summary In Perspective November 7, 2017

2R20 Radiological Safety Summary In Perspective May 9, 2017

3R19 Radiological Safety Summary In Perspective November 10, 2016

Section 2RS4 : Occupational Dose Assessment

Procedures

Number Title Revision

75DP-0RP01 RP Program Overview 11

75DP-0RP06 Managing Radiological Risk 2

75RP-9ME23 Exposure Evaluation for Lost, Damaged, or Suspect 12

Dosimetry, and Anticipated EPD Dose Rate Alarm

75RP-9ME24 Dosimetry Processing, Evaluation, and Documentation 5

75RP-9ME25 TLD Reader Calibration and Response Check 6

75RP-9RP03 Bioassay Analysis 10

75RP-9RP05 Contamination Dose Evaluation 7

75RP-9RP16 Special Dosimetry 24

75RP-9QE21 Calibration of Self-Indicating Dosimeters 13

Procedures

Number Title Revision

75RP-9QE26 Operation and Verification of the Merlin Gerin Model CDM- 10

Calibrator

Audits and Self-Assessments

Title Date

2016 Annual ALARA/Management Evaluation Report June 23, 2017

2016 Annual Radiation Protection Program Summary Report July 27, 2017

Condition Reports (CRs)

17-14033 17-14127 17-14527 17-15700 18-01423

Self-Reading Dosimeter Calibration Records

Number Title Date

837097 Self-Reading Dosimeter September 8, 2017

836204 Self-Reading Dosimeter September 9, 2017

833059 Self-Reading Dosimeter September 30, 2017

810641 Self-Reading Dosimeter gamma/neutron December 12, 2017

810633 Self-Reading Dosimeter gamma/neutron December 12, 2017

810552 Self-Reading Dosimeter gamma/neutron December 13, 2017

Miscellaneous

Number Title Date

2017 Multi-Pack TLD Results 2017

100536 NVLAP Accreditation Report April 8, 2016

100536 NVLAP Proficiency Testing Results - TLD May 2, 2016

100536 NVLAP Proficiency Testing Results-EPD August 5, 2016

100536 NVLAP Accreditation Report February 15, 2018

2017 Unit 1 Dry Active Waste December 1, 2017

2017 Unit 2 Dry Active Waste May 18, 2017

2016 Unit 3 Dry Active Waste December 22, 2016

25116 Intake Dose Assessment April 21, 2016

Miscellaneous

Number Title Date

47194 Personnel Dosimetry Processing Report November 15, 2017

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number Title Date

2016-002-01 Licensee Event Report June 27, 2017

2017-001-00 June 27, 2017 June 14, 2017

Palo Verde Plant Computer PI ProcessBook

Palo Verde Control Room Logs (1/1/17 - 12/31/17)

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

40ST-9DG01 Diesel Generator A Test 49

Condition Reports (CRs)

17-15901 18-03517 17-15838 17-11155 17-09750

16-03783

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports (CRs)

18-02544 18-02688 18-02664 18-02605 18-02716

The following items are requested for the

Occupational Radiation Safety Inspection

at Palo Verde Nuclear Generating Station, Units 1, 2, and 3

February 12 to 16, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 26, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

louis.carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: October 20, 2017

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: January 22, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18127A004

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JDixon Yes No Publicly Available Sensitive NRC-002

OFFICE DRP/SRI DRP/RI DRP/RI C:DRS/EB1 C:DRS/EB2 C:DRS/OB

NAME CPeabody DReinert DYou TFarnholtz JDrake VGaddy

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 4/30/18 5/1/2018 5/1/18 04/30/2018 4/30/18 4/30/18

OFFICE C:DRS/PS2 TL:IPAT C:DRP/D

NAME HGepford GGeorge GMiller

SIGNATURE /RA/ /RA/ /RA/

DATE 4/30/18 4/30/2018 5/7/18

May 7, 2018

Mr. Robert Bement

Executive Vice President, Nuclear/CNO

Mail Station 7602

Arizona Public Service Company

P.O. Box 52034

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED

INSPECTION REPORT 05000528/2018001, 05000529/2018001, AND

05000530/2018001

Dear Mr. Bement:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On April 11, 2018, the NRC

inspectors discussed the results of this inspection with Mr. Jack Cadogan and other members of

your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a

non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within

days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the

NRC resident inspector at the Palo Verde Nuclear Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Palo Verde Nuclear Generating Station.

R. Bement 2

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Geoffrey

B. Miller, 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 05000528/2018001,

05000529/2018001, 05000530/2018001

w/ Attachment:

1. Supplemental Information

2. Occupational Radiation Safety

Inspection Item Request

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000528, 05000529, 05000530

License Numbers: NPF-41, NPF-51, NPF-74

Report Numbers: 05000528/2018001, 05000529/2018001, and 05000530/2018001

Licensee: Arizona Public Service Company

Facility: Palo Verde Nuclear Generating Station

Location: 5801 South Wintersburg Road, Tonopah, AZ 85354

Inspection Dates: January 1, 2018 to March 31, 2018

Inspectors:

C. Peabody, Senior Resident Inspector

D. Reinert, PhD, Resident Inspector

D. You, Resident Inspector

L. Carson, Senior Health Physicist

S. Hedger, Emergency Preparedness Inspector

Approved By: Geoffrey

B. Miller, Chief, Project Branch D, Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Palo Verde Nuclear Generating Station,

Units 1, 2, and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight

Process is the NRCs program for overseeing the safe operation of commercial nuclear power

reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

NRC and self-revealed findings, violations, and additional items are summarized in the table

below.

List of Findings and Violations

Inadequate Post Maintenance Test Instructions for Diesel Fuel Oil Transfer Pump

Cornerstone Significance Cross-cutting Aspect Report

Section

Mitigating Green [H.12] - Human 71111.12 -

Systems NCV 05000528/2018001-01 Performance, Avoid Maintenance

Closed Complacency Effectiveness

The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to prescribe

appropriate work instructions for maintenance on the Unit 1 diesel fuel oil transfer pump

A.

Specifically, following power cable maintenance on November 9, 2017, the instructions for

conducting a post-maintenance test for the transfer pump were inadequate to detect a high

resistance connection in the associated motor control center.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On February 15, 2018, the unit

automatically tripped from full power when a control system failure caused a loss of generator

field excitation. The unit was restarted on February 19, 2018, and remained at or near rated

thermal power for the remainder of the inspection period.

Units 2 and 3 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 1 containment spray system B on January 4, 2018

(2) Unit 2 auxiliary feedwater system A on January 30, 2018

(3) Unit 3 control building heating ventilation and air conditioning B on March 16, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 3

containment spray system on January 18, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Unit 3 main turbine operating deck and bearings area, Fire Zones 9 and 10, on

January 4, 2018

(2) Unit 2 control room, Fire Zone 17, on January 19, 2018

(3) Unit 2 containment spray pump A room and adjacent corridor, Fire Zones 30A and 88A,

on January 23, 2018

(4) Unit 1 high pressure safety injection pump B room, Fire Zone 31B on February 2, 2018

(5) Unit 3 vital switchgear room A, Fire Zone 5A, on February 8, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated Unit 1 diesel generator A lube oil and jacket water heat exchanger

performance on February 21, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated risk informed completion time program and

CFR 50.69 program classroom training on January 31, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance synchronizing the Unit 1 main

generator to the grid following a reactor trip caused by a fault in the main generator

excitation system on February 19, 2018.

The inspectors observed and evaluated operator response to Unit 3 loss of A channel

indication for main steam and feedwater isolation valves, MSIV-170, 171, 180, 181, and

FWIV-174, 177, on February 27, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Reach rod operator gear box maintenance on safety injection valves SI-184 and SI-185

in Units 2 and 3

(2) Diesel fuel oil transfer pump predictive engineering cable testing

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Unit 1 elevated risk due to failure of emergency core cooling system A combined

minimum flow recirculation valve SIA-UV660 on January 4, 2018

(2) Unit 1 emergent risk due to diesel generator A unexpectedly shutdown during a

surveillance run on January 5, 2018

(3) Unit 3 elevated risk due to planned maintenance on containment spray pump A

atmospheric dump valves SG-179A and SG-184A, and low pressure safety injection

valve SI-687 January 29, 2018 through February 4, 2018

(4) Unit 1 elevated risk due to diesel generator A super outage on February 26, 2018

(5) Unit 2 elevated risk due to diesel generator B super outage on March 19, 2018

71111.15 - Operability Determinations and Functionality Assessments (9 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Unit 2 abnormal trend for containment sump level transmitter, RDL-411, on

January 3, 2018

(2) Unit 1 essential spray pond A pressure relief valves lifting during pump starts on

January 25, 2018

(3) Unit 3 containment spray discharge to shutdown cooling heat exchanger valve, SI-685,

failed to re-open during breaker maintenance on January 31, 2018

(4) Unit 1 diesel generator B fuel oil leak from cylinder 8L fuel oil jerk pump on

February 13, 2018

(5) Unit 1 calculated qualified life of safety injection combined header isolation valves,

SI-660 and SI-659, on February 23, 2018

(6) Unit 3 loss of indication of the train A main steam isolation valves and feedwater

isolation valves (MSIV-170, 171, 180, 181 and FWIV-174, 177) on February 27, 2018

(7) Unit 1 auxiliary feedwater bypass motor operated valves SG-138A and SG-139A

T-drains on March 6, 2018

(8) Unit 1 essential cooling water pump A oil samples appear to contain metal or debris on

March 7, 2018

(9) Unit 2 steam generator sodium concentration increase on March 12, 2018

71111.18 - Plant Modifications (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 480V electrical breaker for containment spray to low pressure safety cross-

connect valve, SI-696, replacement with General Electrical model Spectra breaker per

Design Equivalent Change 01035 on March 15, 2018

71111.19 - Post Maintenance Testing (6 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 emergency core cooling system A combined minimum flow recirculation valve

SIA-UV660 following limit switch adjustment on January 4, 2018

(2) Unit 1 diesel generator A cooldown relay, power supply, and test hand switch

replacement following an unplanned cooldown during a monthly surveillance run on

January 9, 2018

(3) Unit 3 containment spray pump A test following breaker maintenance on

February 6, 2018

(4) Unit 3 30-volt power supply replacement for lost indication to main steam isolation valves

on February 28, 2018

(5) Unit 2 essential cooling water pump A test and flow balance following planned

maintenance to calibrate motor overcurrent relays and replace a high discharge

pressure switch on March 20, 2018

(6) Unit 2 diesel generator A emergency mode simulated engineered safeguards features

fast start test following online maintenance outage on March 23, 2018

71111.20 - Refueling and Other Outage Activities (1 Sample)

The inspectors evaluated activities from February 15 - 19, 2018, for the Unit 1 forced

outage due to an unplanned reactor trip caused by a fault in the main generator excitation

circuitry.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (6 Samples)

(1) Unit 1 diesel fuel oil transfer pump A inservice test on January 24, 2018

(2) Unit 1 atmospheric dump valve 178 stroke time testing on February 9, 2018

(3) Unit 2 containment leakage type B and C testing, SR 3.0.3 entry for missed

surveillance on February 28, 2018

(4) Unit 3 diesel fuel oil transfer pump A inservice test on March 7, 2018

(5) Unit 3, essential chiller A vibration analysis on March 8, 2018

(6) Unit 1 containment spray pump B inservice test on March 22, 2018

In-service (1 Sample)

(1) Unit 2 containment spray pump A inservice test on March 1, 2018

71114.02 - Alert and Notification System Testing (1 Sample)

The inspectors evaluated the maintenance and testing of the alert and notification system

between May 1, 2016 - February 20, 2018.

71114.03 - Emergency Response Organization Staffing and Augmentation System (1 Sample)

The inspectors evaluated the readiness of the Emergency Response Organization between

May 1, 2016 - February 20, 2018. Inspectors also evaluated the licensees ability to staff

their emergency response facilities in accordance with emergency plan commitments.

71114.04 - Emergency Action Level and Emergency Plan Changes (1 Sample)

The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and

practices between May 1, 2016 - February 20, 2018. The evaluation reviewed

screenings and evaluations documenting the implementation of this process. The review

of the change process documentation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness (1 Sample)

The inspectors evaluated the maintenance of the emergency preparedness program

between May 1, 2016 - February 20, 2018. The evaluation reviewed activations of the

emergency plan, the conduct of drills and exercises, licensee audits and assessments,

and the maintenance of equipment important to emergency preparedness.

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated a full-scale emergency preparedness drill on February 13, 2018.

RADIATION SAFETY

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Radiological Work Planning (1 Sample)

The inspectors evaluated the licensees radiological work planning by reviewing the

following activities:

(1) RWP 2017-9-1016, RMC Operations and Routine Tasks

(2) RWP 2018-1-1523, Temporary Mat Insulation Fiber Inspection

(3) RWP 2017-3002, Reactor Destack/Restack

(4) RWP 2017-3015, Cavity Decontamination

(5) RWP 2017-3039, 10-Year In-Service Inspection Vessel

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

71124.04 - Occupational Dose Assessment

Source Term Characterization (1 Sample)

The inspectors evaluated the licensees source term characterization.

External Dosimetry (1 Sample)

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (15 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017 -

December 31, 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017 -

December 31, 2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017 -

December 31, 2017)

(4) MS05: Safety System Functional Failures (SSFFs) Sample (April 1, 2017 -

December 31, 2017)

(5) EP01: Drill/Exercise Performance (DEP) Sample (January 1, 2017 - December 31,

2017)

(6) EP02: Emergency Response Organization (ERO) Drill Participation Sample (January 1,

2017 - December 31, 2017)

(7) EP03: Alert and Notification System (ANS) Reliability Sample (January 1, 2017 -

December 31, 2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Multiple failures of diesel generator underfrequency protective relay on March 26, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion

Events (1 Sample)

The inspectors evaluated the Unit 1 reactor trip following a loss of main generator excitation

and licensees response on February 15 - 16, 2018.

INSPECTION RESULTS

Inadequate Post Maintenance Test Instructions for Diesel Fuel Oil Transfer Pump

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.12] - 71111.12 -

Systems NCV 05000528/2018001-01 Human Maintenance

Closed Performance, Effectiveness

Avoid

Complacency

The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to prescribe

appropriate work instructions for maintenance on the Unit 1 diesel fuel oil transfer pump

A.

Specifically, following power cable maintenance on November 9, 2017, the instructions for

conducting a post-maintenance test for the transfer pump were inadequate to detect a high

resistance connection in the associated motor control center.

Description: On November 12, 2017, the licensee was conducting a 24-hour surveillance test

run of Unit 1 diesel generator (EDG) A. The EDG was fully loaded at 10:19 a.m. which began

the 24-hour test period. At 10:53 a.m., control room operators received a fuel oil transfer

pump A inoperable equipment status alarm. The diesel fuel oil transfer pump A did not start

on a diesel fuel oil day tank low level signal. Operators manually unloaded and stopped the

EDG a few minutes later and declared the Unit 1 EDG A inoperable due to its inability to run

for its design basis mission time and began troubleshooting the failed fuel oil transfer pump.

Licensee electricians took electrical resistance readings across the connections in the motor

control center for the fuel oil transfer pump breaker. The electricians identified that the direct

cause of the transfer pump failure was a high variable resistance secondary stab connection

in the motor control center cubicle. The electricians removed the breaker and cleaned and

adjusted the connection. Electricians reinstalled the breaker and confirmed an acceptable as

left connection resistance of less than 0.2 ohms. The diesel fuel oil transfer pump was

successfully retested with a 20 minute functional run and the Unit 1 EDG A was declared

operable following the successful completion of the 24-hour surveillance run on November

14, 2017.

The licensees apparent cause investigation determined that the diesel fuel oil transfer pump

breaker had been removed from service for periodic predictive maintenance on November 9,

2017, under work order 4685719. During this maintenance activity licensee engineers

disconnected the diesel fuel oil transfer pump motor power and control cables for megger

testing. Cable lug screw connections attach each of these cables to the secondary stab

connections on the movable motor breaker and the stationary motor control center chassis.

Cable connections on the secondary stab connections are removed for testing, and then

following testing, the cables are re-landed onto the secondary stabs of the breaker and motor

control center chassis. The licensees work planners had not recognized the possibility that

removing and re-landing the cables on the lug screw connections had the potential to disturb

the motor control center secondary stab connections.

The post-maintenance test associated with the cable testing was a momentary start of the

diesel fuel oil transfer pump. The transfer pumps control switch was held in the start position

for only a few seconds. The licensees apparent cause investigation identified that

nonintrusive as-left quantitative resistance checks could have been used to assess the

integrity of the secondary stab connections. The licensee performs similar checks when

performing individual breaker cubicle preventative maintenance tasks that actively remove

and re-test the individual motor control center bucket. Such a check was the method used by

the electricians to initially diagnose the breaker failure. However, no such quantitative

resistance check was specified in the cable testing work order.

The post-maintenance test was not written in accordance with station procedure 30DP-

9WP04, Post-Maintenance Testing Development, Revision 19, Step 4.1.1, which states, in

part, that the post-maintenance test shall ensure that equipment performs its intended

function when returned to service following maintenance, that a new deficiency has not been

created, and that the equipment will function as designed for safe and reliable plant operation.

The act of de-terminating and re-terminating the diesel fuel oil transfer pump cable for testing

created new failure deficiency by disturbing electrical continuity and creating a high resistance

condition at the secondary stab connection that impacted EDG operability. The post-

maintenance test following the cable testing maintenance was not adequate to ensure that a

new deficiency had not been created.

Corrective Action: The licensee has taken corrective action to revise the work instructions for

performing future cable testing to include quantitative resistance retests when re-terminating

motor control center secondary stab connections. As an interim measure, the inspectors

confirmed that all safety-related 480V electrical breakers that have been subject to this cable

testing have performed satisfactorily during subsequent diesel generator surveillance testing.

Corrective Action Reference: Condition Report 17-16497

Performance Assessment:

Performance Deficiency: The licensees failure to prescribe appropriate retest activities

following predictive maintenance on diesel fuel oil transfer pump cables is a performance

deficiency.

Screening: The performance deficiency is more-than-minor and a finding because it is

associated with the equipment performance attribute of the mitigating systems cornerstone

objective to ensure the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. Specifically, on November 9, 2017,

the licensee performed cable testing that disturbed the power cables for the Unit 1 diesel fuel

oil transfer pump

A. Without an appropriate post-maintenance test, this activity rendered the

Unit 1 diesel generator A inoperable.

Significance: The inspectors performed the initial significance determination using NRC

Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for

Findings at Power, Exhibit 2, Mitigating Systems Screening Questions and determined that

the finding was of very low safety significance (Green) because the finding did not represent

an actual loss of safety function of a single train for greater that its technical specification

allowed outage time.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human

performance associated with the avoid complacency aspect. Specifically, licensee work

planners did not consider potential undesired consequences associated with disturbing the

power cables leads, instead relying on past successful tests [H.12].

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and

Drawings, requires, in part, that activities affecting quality be prescribed by documented

instructions, procedures, or drawings, of a type appropriate to the circumstances and be

accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on November 9, 2017, the licensee performed maintenance on the

Unit 1 diesel fuel oil transfer pump A, an activity affecting quality to which Appendix B applies,

without documented instructions, procedures, or drawings of a type appropriate to the

circumstances. Specifically, work order 4685719 did not include appropriate testing to ensure

the maintenance was successful and the pump was returned to service, and as a result, the

Unit 1 diesel generator A was rendered inoperable from November 9, 2017 to November 14,

2017.

Disposition: This violation is being treated as a non-cited violation consistent with Section

2.3.2.a of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 16, 2018, the inspector presented the radiation safety inspection results to

Ms.

M. Lacal, Senior Vice President, Regulatory and Oversight, and other members of the

licensee staff.

On March 2, 2018, the inspector provided a debrief for the emergency preparedness program

inspection to Mr.

M. McLaughlin, Vice President, Operations Support, and other members of the

licensee staff. On March 29, 2018, the inspector communicated the inspection results

telephonically to Mr.

T. Weber, Acting Director, Nuclear Regulatory Affairs, and other members

of the licensee staff.

On April 11, 2018, the inspector presented the quarterly residents inspection results to

Mr.

J. Cadogan, Senior Vice President, Site Operations, and other members of the licensee

staff.

SUPPLEMENTAL INFORMATION

DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

40ST-9AF07 Auxiliary Feedwater Pump AFA-P01 Monthly Valve 6

Alignment

40ST-9SI13 LPSI and CS System Alignment Verification 33

Condition Reports (CRs)

16-17321 17-03027

Drawings

Number Title Revision

03-M-HJP-001 P&I Diagram Control Building HVAC 14

03-M-HJP-002 P&I Diagram Control Building HVAC 14

03-M-SIP-001 P&I Diagram Safety Injection & Shutdown Cooling System 49

03-P-SIF-0207 Auxiliary Building Isometric Safety Injection System LPSI & 6

Cont. Spray Discharge

03-P-SIF-0201 Auxiliary Building Isometric Safety Injection System ESF 7

Pump Suction Lines

Miscellaneous

Number Title Revision

STM-30D System Training Manual Volume 30D: Control Building 6

HVAC System (HJ)

Section 1R05: Fire Protection

Procedures

Number Title Revision

14FT-9FP70 Appendix R & Former Tech Spec Penetration Seal Surveillance 13

Condition Reports (CRs)

17-03870 18-00999

Miscellaneous

Number Title Revision/Date

PVNGS Pre-Fire Strategies Manual 26

13-MM-0650 Fire Protection & Spray System Sub 007

13-MS-A083 NFPA Code Applicability and Conformance Review 007

4834415 Fire Safety Component Condition Record November 3, 2016

4834430 Fire Safety Component Condition Record November 3, 2016

4843902 Fire Safety Component Condition Record December 6, 2016

Unit 3 Tamper/Vital/Security Tour - Post 31 February 7, 2018

4971714 Open Door/Hatch/Floor Plug Permit January 29, 2018

4971687 Open Door/Hatch/Floor Plug Permit January 29, 2018

Section 1R07: Heat Sink Performance

Procedures

Number Title Revision

73DP-9ZZ21 Heat Exchanger Visual Inspection 6

73DP-9ZZ11 Heat Exchanger Program 15

Condition Reports (CRs)

18-03133 18-03138 18-03139

Work Orders (WOs)

4591574 4591575 4667054 4667055 4667098

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

40OP-9MB01 Main Generation and Excitation 63

40DP-9OP02 Conduct of Operations 72

Procedures

Number Title Revision

40AL-9RK6A Panel B06A Alarm Responses 18

Condition Reports (CRs)

18-02797 18-02593 18-03215

Miscellaneous

Number Title Date

Current Alarm Status Report February 16, 2018

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

2MT-9ZZ74 Molded Case Circuit Breaker Test 48

30DP-9WP04 Post-Maintenance Testing Development 19

Condition Reports (CRs)

17-08025-005 17-08025 17-16497

Work Orders (WOs)

25959 4925966 4925967 4925969 4685719

4788985

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

40DP-9AP21 Protected Equipment 7

70DP-0RA05 Assessment and Management of Risk when Performing 23

Maintenance in Modes 1 and 2

40MT-9ZZ01 Operations Maintenance Activities 5

40DP-9RS01 Operations Department Online Nuclear Risk Management 4

Mode 1 and 2

Condition Reports (CRs)

18-00249 185-00136 18-00336 18-02544

Miscellaneous

Number Title Date

Schedulers Evaluation for PV Unit 1 January 4, 2018

Schedulers Evaluation for PV Unit 1 February 23, 2018

Schedulers Evaluation for PV Unit 3 February 1, 2018

Schedulers Evaluation for PV Unit 2 March 19, 2018

Unit 3 Archived Operator Logs January 29, 2018 -

February 4, 2018

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

40ST-9ZZm1 Operations Mode 1 Surveillance Logs 71

40AL-9RK6A Panel B06A Alarm Responses 18

74DP-9CY04 Systems Chemistry Specifications 94

Condition Reports (CRs)

17-18475 12-01397 17-17856 13-01198 18-03127

17-16393 18-03215 18-03291 18-02839 18-01610

18-02334 3127427 18-02468 18-03980

Miscellaneous

Number Title Revision/Date

03-E-SGF-023 Control Wiring Diagram Main Steam Isolation Valves 11

18-02334-003 Engineering Evaluation February 15, 2018

28056 Adverse CRDR July 19, 2013

EQ Program Manual 26

Section 1R18: Plant Modifications

Condition Reports (CRs)

18-04116

Work Orders (WOs)

4989102

Miscellaneous

Number Title Date

DEC-01035 Design Equivalent Change April 12, 2017

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

40OP-9CH12 Refueling Water Tank (RWT) Operations 41

2MT-9ZZ13 Testing and Calibration of 121FC66K01A Time Overcurrent 4

Relays

2MT-9ZZ17 Testing and Calibration of 12PJC11AV1A Instantaneous 4

Overcurrent Relays

40OP-9EW02 Essential Cooling Water System (EW) Train B 26

40ST-9DG01 Diesel Generator A Test 49

73ST-9DG08 Class 1E Diesel Generator Load Reject 24 Hour Rated Load 13

and Hot Start Test Train B

40ST-9DG02 Diesel Generator B Test 54

Condition Reports (CRs)

18-00136 18-00197 18-01931 18-00210 18-00290

18-00336 18-00377 18-00346 18-04731 18-04732

Work Orders (WOs)

4964492 4822983 4981967 4726747 4821113

4847651 4965079 4972486 4847637

Drawings

Number Title Revision

01-E-DGB-007 Elementary Diagram: Diesel Engine Control 15

01-E-DGF-007 Control Wiring Diagram: Diesel Engine 13

13-M018-00141 Control Schematic (Starting Sequence Control) 25

Miscellaneous

Number Title Revision/Date

18-00210-004 Engineering Evaluation: EDG 1A Unexpected Cooldown January 8, 2018

during Surveillance Run 1/5/2018

Section 1R20: Refueling and Other Outage Activities

Procedures

Number Title Revision

40OP-9MB01 Main Generation and Excitation 63

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

73DP-9CL02 Containment Leakage Rate Testing Program 33

73ST-9XI20 Atmospheric Dump Valves - Inservice Test 47

73ST-9SI06 Containment Spray Pumps and Check valves - Inservice 42

Test

73ST-9DF01 Diesel Fuel Oil Transfer Pumps - Inservice Test 34

40DP-9OP06 Operations Department Repetitive Task Program 130

73ST-9SI06 Containment Spray Pumps and Check Valves- Inservice 42

Test

Condition Reports (CRs)

16-15793 18-03304 18-01314 18-03825

Work Orders (WOs)

22921 4840032 4843076 4843390

Miscellaneous

Number Title Revision/Date

13-JC-SI-0215 Containment Spray Pump Discharge Flow Indication 18

Loops Uncertainty Calculation

18-01314-002 Engineering Evaluation: ADV 178 Fast Stroke Time January 26, 2018

18-03304-002 Engineering Evaluation: SR 3.0.3 Evaluation for March 2, 2018

SB-200, 202, and 205

Section 1EP2: Alert and Notification System Testing

Miscellaneous Documents

Number Title Date

ID/Letter Palo Verde Nuclear Generating Station Alert and May 26, 2017

Number: Notification System (ANS) FEMA 350 Report -

240-02802 May 2017

Palo Verde Nuclear Generating Station, Alert and May 2017

Notification System (ANS), FEMA 350 Report

Palo Verde Nuclear Generating Station Siren Operating November 2015

Manual January 4, 2018

Letter from FEMA Region IX to Director, Division of September 19,

Emergency Management, State of Arizona 2017

State of Arizona/Maricopa County Offsite Emergency November 2017

Response Plan, Palo Verde Nuclear Generating Station

The Maricopa County Sheriffs Office Emergency August 2016

Response to Palo Verde Nuclear Generating Station

Work Orders (WOs)

474965/0

Section 1EP3: Emergency Response Organization Staffing and Augmentation

Procedures

Number Title Revision

EP-0902 Notifications 10

EP-0901 Classifications 10

40AL-9RK7C Panel B07C Alarm Responses 15

40AO-9ZZ21 Acts of Nature 37

79IS-9SM01 Analysis of Seismic Event 27

Miscellaneous Documents

Number Title Date

240-02799 2017 1 Quarter - Emergency Preparedness

st

March 21, 2017

JF/MA Augmentation Drill Report

240-02803 2017 2nd Quarter - Emergency Preparedness June 6, 2017

CS/MA Augmentation Drill Report

240-02797 2017 3rd Quarter - Emergency Preparedness July 25, 2017

Augmentation Drill Report (After Hours)

240-02808 2017 3rd Quarter - Emergency Preparedness September 6, 2017

Augmentation Drill Report

240-02817 2017 4th Quarter - Emergency Preparedness December 13,

CS/ma Augmentation Drill Report 2017

240-02790 2016 2nd Quarter - Emergency Preparedness June 23, 2016

JF/MA Augmentation Drill Report

240-02791 2016 3rd Quarter - Emergency Preparedness August 3, 2016

JF/MA Augmentation Drill Report

240-02798 December 5, 2016, Alert Event Report January 17, 2017

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Procedure

Number Title Revision

16DP-0EP22 Emergency Plan Maintenance 11, 12

Miscellaneous Documents

Number Title Date

Evaluation Replace the Meteorological Instrumentation and Data August 8, 2017

Tracking Number Transmission System (MDTS)

2017-001E

Evaluation EP-0900, Rev. 16 August 17, 2017

Tracking Number

2017-003E

Evaluation EP-0901, Rev. 10 August 21, 2017

Tracking Number

2017-004E

Screening 74RM-9EF42, Radiation Monitor Alarm Setpoint April 16, 2017

Tracking Number Determination, Rev. 30

2017-002S

Screening Procedure EP-0901, Classifications, Added New EALs August 20, 2017

Tracking Number form EPLAN R60, Revise PV Proc Format

2017-022S

Miscellaneous Documents

Number Title Date

Screening EP-905, Revision 9, Protective Actions June 7, 2017

Tracking Number

2017-014S

Screening DMWO 3452940 Palo Verde Nuclear Generating September 8,

Tracking Number Station Radio Replacement Project 2017

2017-023S

Screening 40AO-9ZZ18 R018 Fire Outside Control Room September 26,

Tracking Number 2017

2017-029S

EPM Tracking DEC-00720 Allow Solar-Charged Offsite Sirens to February 18,

Number Replace AC-Charged Offsite Sirens 2015

2015-006S

Section 1EP5: Maintenance of Emergency Preparedness

Procedures

Number Title Revision

01DP-0AP12 Condition Reporting Process 28

01DP-0AP12-01 Condition Reporting Process Administrative Guide 4

EP-0905 Protective Actions 9

EP-0902 Notifications 8, 9, 10

16DP-0EP31 Emergency Preparedness Equipment Out-of-Service 9

16DP-0EP27 Emergency Preparedness Equipment Testing 10

16DP-0EP28 Emergency Facility/Kit Inventories and Inspections 5

Condition Reports (CRs)

16-08461 16-09213 16-11134 16-11930 16-12640 16-13501

16-14593 16-14934 16-16710 17-02188 17-03147 17-03149

17-03202 17-03605 17-03721 17-03736 17-03826 17-03828

17-03829 17-03884 17-04633 17-06893 17-08328 17-10906

17-10949 17-11437 17-13663 17-14927 17-15449 17-15797

17-15884 17-16771 17-17091 17-17218 17-17739 17-18443

18-03244

Miscellaneous Documents

Number Title Revision/Date

KLD TR-983 Palo Verde Nuclear Generating Station, December 7,

2017 Population Update Analysis 2017

KLD TR-895 Palo Verde Nuclear Generating Station, December 8,

2016 Population Update Analysis 2016

Updated Review of Palo Verde Nuclear Generating September 29,

Station Emergency Plan 2016 Letters of Agreement 2016

Letter # 240- 2017 Review of Palo Verde Nuclear Generating Station December 26,

2819 Emergency Plan Letters of Agreement 2017

NAD Audit 2016- Nuclear Assurance Department (NAD) Audit Plan and December 14,

010 Report, 2016-010, Emergency Preparedness 2016

Palo Verde Nuclear Generating Station After Action August 18,

Report/Improvement Plan, Exercise Date - June 1, 2017

2017, Radiological Emergency Preparedness Program

ID: 240-02806 2017 Onsite Contaminated Injury/Health Physics Drill June 23, 2017

Report (Revised)

ID: 240-02816 2017 Health Physics Drill Report (November 2017) December 12,

2017

ID: 240-02818 1709 ERO Mini Drill - ERO Blue Team December 21,

(December 2017) 2017

NAD Audit 2017- Nuclear Assurance Department (NAD) Audit Plan and January 25,

008 Report, 2017-008, Emergency Preparedness 2018

240-02812 1704 and 1705 ERO Mini Drills - ERO White Team and October 18,

CS/MA Green Team (June and July 2017) 2017

240-02813 1706 ERO Mini Drill - ERO Gold Team (July 2017) October 18,

CS/MA 2017

240-02814 1707 ERO Mini Drill - ERO Red Team (August 2017) October 18,

TW/MA Revision 1 2017

Emergency Response Facility Telephone Book, January 1,

1st Quarter Edition 2018 2018

240-02801 1702 IPZ Evaluated Exercise - ERO White Team April 6, 2017

JF/MA (March 2017)

240-02797 1608 ERO Mini Drill - ERO Red Team January 4,

JF/MA (December 2016) 2017

240-02792 1604 and 1605 ERO Drills September 14,

JF/MA 2016

240-02793 1606 ERO Mini Drill - ERO Green Team October 4,

JF/MA (September 2016) 2016

Miscellaneous Documents

Number Title Revision/Date

240-02795 1609 Off-Hours Drive-in Augmentation Drill - December 2,

JF/MA (November 2016) 2016

240-02796 2016 Health Physics Drill Report (November 2016) December 7,

2016

Evaluation Evaluate Adding STSC ENS Communicator Duties to September 7,

Report 16-11134 STSC Communicator 2016

17-11437-002 Actual Event Investigation, Unit 3 Ammonia Sight glass September 28,

Break 2017

17-13663-001 Actual Event Investigation, Unit 2 Loss of Annunciators October 11,

2017

Level 4 Default Values Used in Dose Assessment November 30,

Evaluation 2017

Report 17-

15797-001

Document No. Master Agreement Between Arizona Public Service 0

500599510 Company and Westinghouse Electric Company LLC for

Goods and Services (Effective January 29, 2016 to

December 31, 2018)

Palo Verde Nuclear Generating Station After Action May 26, 2017

Report/Improvement Plan, Exercise Dates - March 7-8,

2017, Radiological Emergency Preparedness Program

(REPP)

240-02789 2016 Health Physics Drill Report (Re-Demonstration) June 9, 2016

JF/TW

240-02788 2016 Contaminated Injury/Health Physics Drill Report April 22, 2016

JF/MA

Palo Verde Nuclear Generating Station After Action February 9,

Report/Improvement Plan, Exercise Date - 2017

November 16, 2016, Radiological Emergency

Preparedness Program (REPP)

240-02787 1602 IPZ Exercise - ERO Green Team (March 2016) March 25, 2016

JF/MA

Palo Verde Nuclear Generating Station After Action February 9,

Report/Improvement Plan, Exercise Date - 2017

November 16, 2016, Radiological Emergency

Preparedness Program (REPP)

Level 3 Evaluation Report 18-02668-002 March 22, 2018

Work Orders (WOs)

4782667 4783959/0 4787729/0 4787847/0 4836236

4836263/0 4860832/0 4862234/0 4862502/0 4885361/0

4889725/0 4896971/0 4901070 4916668/0 4918303/0

4918455/0 4937577/0 4947802/0

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision

EP-0900 Emergency Response Organization (ERO) Position 16

Checklists

EP-0901 Classifications 10

Condition Reports (CRs)

18-02352 18-02503 18-02655

Section 2RS2: Occupational ALARA Planning and Controls

Procedures

Number Title Revision

75DP-0RP03 ALARA Program Overview 06

75DP-0RP06 ALARA Committee 07

75DP-0RP08 Managing Radiological Risk 02

75RP-9RP02 Radiation Work Permits 31

75RP-9RP25 Temporary Shielding 14

75TD-9RP02 ALARA Work Planning 11

Audits and Self-Assessments

Title Date

PVGS Integrated Performance Assessment Report Radiation September 14, 2017

Protection 2nd Quarter 2017

2016 Annual ALARA/Management Evaluation Report June 23, 2017

2016 Annual Radiation Protection Program Summary Report July 27, 2017

Condition Reports (CRs)

17-15502 17-15529 17-15802 17-16741 17-17944

17-18180 18-01890

Radiation Work Permits/ALARA Reviews

Number Title

RWP 2017-9-1016 RMC Operations and Routine Tasks

RWP 2018-1-1523 Temporary Mat Insulation Fiber Inspection

RWP 2017-3002 Reactor Destack/Restack

RWP 2017-3015 Cavity Decontamination

RWP 2017-3039 10-Year In-Service Inspection Vessel

Miscellaneous

Title Date

ALARA 5-Year Plan 2015 - 2019 November 2015

1R20 Radiological Safety Summary In Perspective November 7, 2017

2R20 Radiological Safety Summary In Perspective May 9, 2017

3R19 Radiological Safety Summary In Perspective November 10, 2016

Section 2RS4 : Occupational Dose Assessment

Procedures

Number Title Revision

75DP-0RP01 RP Program Overview 11

75DP-0RP06 Managing Radiological Risk 2

75RP-9ME23 Exposure Evaluation for Lost, Damaged, or Suspect 12

Dosimetry, and Anticipated EPD Dose Rate Alarm

75RP-9ME24 Dosimetry Processing, Evaluation, and Documentation 5

75RP-9ME25 TLD Reader Calibration and Response Check 6

75RP-9RP03 Bioassay Analysis 10

75RP-9RP05 Contamination Dose Evaluation 7

75RP-9RP16 Special Dosimetry 24

75RP-9QE21 Calibration of Self-Indicating Dosimeters 13

Procedures

Number Title Revision

75RP-9QE26 Operation and Verification of the Merlin Gerin Model CDM- 10

Calibrator

Audits and Self-Assessments

Title Date

2016 Annual ALARA/Management Evaluation Report June 23, 2017

2016 Annual Radiation Protection Program Summary Report July 27, 2017

Condition Reports (CRs)

17-14033 17-14127 17-14527 17-15700 18-01423

Self-Reading Dosimeter Calibration Records

Number Title Date

837097 Self-Reading Dosimeter September 8, 2017

836204 Self-Reading Dosimeter September 9, 2017

833059 Self-Reading Dosimeter September 30, 2017

810641 Self-Reading Dosimeter gamma/neutron December 12, 2017

810633 Self-Reading Dosimeter gamma/neutron December 12, 2017

810552 Self-Reading Dosimeter gamma/neutron December 13, 2017

Miscellaneous

Number Title Date

2017 Multi-Pack TLD Results 2017

100536 NVLAP Accreditation Report April 8, 2016

100536 NVLAP Proficiency Testing Results - TLD May 2, 2016

100536 NVLAP Proficiency Testing Results-EPD August 5, 2016

100536 NVLAP Accreditation Report February 15, 2018

2017 Unit 1 Dry Active Waste December 1, 2017

2017 Unit 2 Dry Active Waste May 18, 2017

2016 Unit 3 Dry Active Waste December 22, 2016

25116 Intake Dose Assessment April 21, 2016

Miscellaneous

Number Title Date

47194 Personnel Dosimetry Processing Report November 15, 2017

Section 4OA1: Performance Indicator Verification

Miscellaneous

Number Title Date

2016-002-01 Licensee Event Report June 27, 2017

2017-001-00 June 27, 2017 June 14, 2017

Palo Verde Plant Computer PI ProcessBook

Palo Verde Control Room Logs (1/1/17 - 12/31/17)

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

40ST-9DG01 Diesel Generator A Test 49

Condition Reports (CRs)

17-15901 18-03517 17-15838 17-11155 17-09750

16-03783

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports (CRs)

18-02544 18-02688 18-02664 18-02605 18-02716

The following items are requested for the

Occupational Radiation Safety Inspection

at Palo Verde Nuclear Generating Station, Units 1, 2, and 3

February 12 to 16, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 26, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

louis.carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: October 20, 2017

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: January 22, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18127A004

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JDixon Yes No Publicly Available Sensitive NRC-002

OFFICE DRP/SRI DRP/RI DRP/RI C:DRS/EB1 C:DRS/EB2 C:DRS/OB

NAME CPeabody DReinert DYou TFarnholtz JDrake VGaddy

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 4/30/18 5/1/2018 5/1/18 04/30/2018 4/30/18 4/30/18

OFFICE C:DRS/PS2 TL:IPAT C:DRP/D

NAME HGepford GGeorge GMiller

SIGNATURE /RA/ /RA/ /RA/

DATE 4/30/18 4/30/2018 5/7/18