IR 05000528/2019001: Difference between revisions

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==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==


===
===Seasonal Extreme Weather Sample (IP Section 03.02)===
Seasonal Extreme Weather Sample (IP Section 03.02)
===
{{IP sample|IP=IP 71111.01|count=1}}
{{IP sample|IP=IP 71111.01|count=1}}
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme high temperatures.
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme high temperatures.
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==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==


===
===Partial Walkdown (IP Section 02.01)
Partial Walkdown (IP Section 02.01)
  (3 Sample s)  The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
  (3 Sample s)  The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Unit 3 containment spray system B, on January 24, 2019
: (1) Unit 3 containment spray system B, on January 24, 2019
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Inspection Activities  
Inspection Activities  
- Internal Flooding (IP Section 02.02a.)
- Internal Flooding (IP Section 02.02a.)===
 
===
{{IP sample|IP=IP 71111.04|count=1}}
{{IP sample|IP=IP 71111.04|count=1}}
The inspectors evaluated internal flooding mitigation protections in the 80' and 100' elevations of the Unit 1, 2, and 3 main steam support structures on March 21, 2019.
The inspectors evaluated internal flooding mitigation protections in the 80' and 100' elevations of the Unit 1, 2, and 3 main steam support structures on March 21, 2019.
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==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==


===
===Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)===
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
===
{{IP sample|IP=IP 71111.11Q|count=1}}
{{IP sample|IP=IP 71111.11Q|count=1}}
The inspectors observed and evaluated Unit 3 control room operators during a maintenance activity to replace power switch assemblies for control element assembly 22 on February 12, 2019. Licensed Operator Requalification Training/Examinations (IP Section 03.02)
The inspectors observed and evaluated Unit 3 control room operators during a maintenance activity to replace power switch assemblies for control element assembly 22 on February 12, 2019. Licensed Operator Requalification Training/Examinations (IP Section 03.02)
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==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==


===
===Routine Maintenance Effectiveness Inspection (IP Section 02.01)
Routine Maintenance Effectiveness Inspection (IP Section 02.01)
  (2 Sample s)  The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
  (2 Sample s)  The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
: (1) Unit 1 chemical and volume control system charging pump discharge pressure relief valve failures, on January 24, 2019
: (1) Unit 1 chemical and volume control system charging pump discharge pressure relief valve failures, on January 24, 2019
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The inspectors evaluated the following surveillance tests:
The inspectors evaluated the following surveillance tests:
In Service Testing (IST) (IP Section 03.01)
In Service Testing (IST) (IP Section 03.01)===
===
{{IP sample|IP=IP 71111.12|count=1}}
{{IP sample|IP=IP 71111.12|count=1}}
77ST-9EW01, Unit 1 essential cooling water A inservice pump test, on January 31, 2019 Surveillance Testing (IP Section 03.01)
77ST-9EW01, Unit 1 essential cooling water A inservice pump test, on January 31, 2019 Surveillance Testing (IP Section 03.01)
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==71114.06 - Drill Evaluation==
==71114.06 - Drill Evaluation==


===
===Drill and/or Simulator
Drill and/or Simulator
-Based Licensed Operator Requalification Training (IP Section 02.01) (see 71114.06 for sample guidance)===
-Based Licensed Operator Requalification Training (IP Section 02.01) (see 71114.06 for sample guidance)
===
{{IP sample|IP=IP 71114.06|count=1}}
{{IP sample|IP=IP 71114.06|count=1}}
The inspectors evaluated a dress rehearsal drill that required emergency facilities to respond to a fire in a diesel generator room, a steam generator tube rupture, and a steam line break on February 5, 2019.
The inspectors evaluated a dress rehearsal drill that required emergency facilities to respond to a fire in a diesel generator room, a steam generator tube rupture, and a steam line break on February 5, 2019.
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==71114.08 - Exercise Evaluation Scenario Review==
==71114.08 - Exercise Evaluation Scenario Review==


===
===Inspection Review (IP Section 02.01  
Inspection Review (IP Section 02.01  
- 02.04)===
- 02.04)===
{{IP sample|IP=IP 71114.08|count=1}}
{{IP sample|IP=IP 71114.08|count=1}}
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==71124.05 - Radiation Monitoring Instrumentation==
==71124.05 - Radiation Monitoring Instrumentation==


===
===Calibration and Testing Program (IP Section 02.02)===
Calibration and Testing Program (IP Section 02.02)
===
{{IP sample|IP=IP 71124.05|count=1}}
{{IP sample|IP=IP 71124.05|count=1}}
The inspectors evaluated the calibration and testing program implementation.
The inspectors evaluated the calibration and testing program implementation.
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==71124.06 - Radioactive Gaseous and Liquid Effluent Treatment==
==71124.06 - Radioactive Gaseous and Liquid Effluent Treatment==


===
===Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02)===
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02)
===
{{IP sample|IP=IP 71124.06|count=1}}
{{IP sample|IP=IP 71124.06|count=1}}
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
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==71124.07 - Radiological Environmental Monitoring Program==
==71124.07 - Radiological Environmental Monitoring Program==


===
===Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)===
Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)
===
{{IP sample|IP=IP 71124.07|count=1}}
{{IP sample|IP=IP 71124.07|count=1}}
The inspectors evaluated the licensee's groundwater monitoring program.
The inspectors evaluated the licensee's groundwater monitoring program.
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==71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation==
==71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation==


===
===Radioactive Material Storage (IP Section 02.01)===
Radioactive Material Storage (IP Section 02.01)
===
{{IP sample|IP=IP 71124.08|count=1}}
{{IP sample|IP=IP 71124.08|count=1}}
The inspectors evaluated radioactive material storage in the follow areas:
The inspectors evaluated radioactive material storage in the follow areas:
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-December 31, 2018 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)
-December 31, 2018 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)
  (3 Sample s)  Units 1, 2, and 3, January 1, 2018
  (3 Sample s)  Units 1, 2, and 3, January 1, 2018
-December 31, 2018 Drill/Exercise Performance (IP Section 02.12)===
-December 31, 2018 Drill/Exercise Performance (IP Section 02.12) ===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
The inspector reviewed data for the Drill/Exercise Performance indicator for the period January 1, 2018 , through December 31, 2018. ERO Drill Participation (IP Section 02.13) (1 Sample)===
The inspector reviewed data for the Drill/Exercise Performance indicator for the period January 1, 2018 , through December 31, 2018. ERO Drill Participation (IP Section 02.13) (1 Sample)===

Revision as of 10:16, 3 June 2019

NRC Integrated Inspection Report 05000528/2019001, 05000529/2019001, 05000530/2019001, and 07200044/2019001
ML19122A295
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/30/2019
From: O'Keefe N F
NRC/RGN-IV/DRP
To: Bement R
Arizona Public Service Co
References
IR 2019001
Download: ML19122A295 (41)


Text

April 30, 2019

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION

- NRC INTEGRATED INSPECTION REPORT 05000528/2019001, 05000529/2019001 , 05000530/2019 001 , AND 07200044/2019001

Dear Mr. Bement:

On March 31, 2019

, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3 and on April 12, 2019, discussed the results of this inspection with Mr. Jack Cadogan

, Senior Vice President, Site Operations

, and other members of your staff.

The results of this inspection are documented in the enclosed report. The NRC inspectors did not identify any finding or violation of more than minor significance

. 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/ Neil F. O'Keefe, Chief Project Branch D Division of Reactor Projects Docket No s. 05000528 , 05000529 , 05000530 , and 07200044 License No s. NPF-41 , NPF-51 , NPF-74 Enclosure:

Inspection Report

05000528/2019001

, 05000529/2019001

, 05000530/2019001

, and 07200044/2019001 w/attachments:

1. Supplemental Information 2. Information Request

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s):

05000528, 05000529

, 05000530, and 07200044 License Number(s):

NPF-41, NPF-51 and NPF-74 Report Number(s):

05000528/2019001, 05000529/2019001

, 05000530/2019001, and 07200044/2019001 Enterprise Identifier:

I-2019-001-0013 I-2019-001-0077 Licensee: Arizona Public Service Co.

Facility: Palo Verde Nuclear Generating Station and Independent Spent Fuel Storage Installation Location: 5801 South Wintersburg Road, Tonopah, AZ 85354 Inspection Dates:

January 1, 2019 , to March 31, 2019 Inspectors:

C. Peabody, Senior Resident Inspector D. Reinert, Resident Inspector D. You, Resident Inspector R. Bywater, Resident Inspector R. Alexander, Senior Project Engineer L. Carson, Senior Health Physicist P. Elkmann, Senior Emergency Preparedness Inspect or N. Greene , PhD, Senior Health Physicist S. Hedger, Emergency Preparedness Inspector J. O'Donnell, Health Physicist C. Alldredge, Allegations/Enforcement Specialist B. Baca, Health Physicist O. Masnyk Bailey, Health Physicist (Region I)

K. Warner, Health Physicist, (Region I)

Approved By

Neil O'Keefe, Chief, Project Branch D, Division of Reactor Projects

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting baseline inspections at Palo Verde Nuclear Generating Station Units 1, 2, and 3 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's 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-identified and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.

List of Findings and Violations No findings were identified.

Additional Tracking Items None.

3

PLANT STATUS

===Units 1, 2, and 3 operated at or near full power for the duration of the 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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.02)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme high temperatures.

71111.04 - Equipment Alignment

===Partial Walkdown (IP Section 02.01)

(3 Sample s) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 3 containment spray system B, on January 24, 2019
(2) Unit 3 diesel generators A and B jacket water cooling systems, on February 1, 2019
(3) Unit 3 loss of power sequencer A, on March 22, 2019

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01)

(6 Sample s) The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 3 non-class switchgear and battery rooms, Fire Area TB4, on January 16, 2019
(2) Unit 2 auxiliary feedwater A room, Fire Area 72, on January 17, 2019
(3) Unit 1 auxiliary feedwater B room, Fire Area 73, on February 20, 2019
(4) Unit 3 auxiliary feedwater A room, Fire Area 72, on March 22, 2019
(5) Unit 1 auxiliary feedwater A room, Fire Area 72, on March 25, 2019
(6) Unit 1 Class 1E switchgear B room, Fire Area 5B, on March 29, 2019

71111.06 - Flood Protection Measures

Inspection Activities

- Internal Flooding (IP Section 02.02a.)===

The inspectors evaluated internal flooding mitigation protections in the 80' and 100' elevations of the Unit 1, 2, and 3 main steam support structures on March 21, 2019.

Inspection Activitie s - Underground Cables (IP Section 02.02c.)

(1 Sample) The inspectors evaluated cable submergence protection in Unit 3 Bravo diesel fuel oil vault on March 1, 2019

.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

The inspectors observed and evaluated Unit 3 control room operators during a maintenance activity to replace power switch assemblies for control element assembly 22 on February 12, 2019. Licensed Operator Requalification Training/Examinations (IP Section 03.02)

(1 Sample) The inspectors observed and evaluated a licensed operator continuing training simulator scenario on February 5 , 2019. The inspectors assessed the performance of the operators and the control room simulator.

71111.12 - Maintenance Effectiveness

===Routine Maintenance Effectiveness Inspection (IP Section 02.01)

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

(1) Unit 1 chemical and volume control system charging pump discharge pressure relief valve failures, on January 24, 2019
(2) Unit 3 essential chill ed water temperature control valve ECB

-TV0030, on March 21, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)

(3 Sample s) The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 2 elevated risk during station blackout generator and high pressure safety injection pump A maintenance, on January 8, 2019
(2) Unit 1 emergent work for main feedwater pump B mini

-flow valve failure, on February 20, 2019

(3) Unit 3 online risk during diesel generator A super outage, on March 5, 2019

71111.15 - Operability Determinations and Functionality Assessments

Sample Selection (IP Section 02.01)

(6 Sample s) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 3 spent fuel pool decrease in Boron

-10 concentration, on January 25, 2019

(2) Unit 3 control room essential air handing unit B temperature control valve response to handheld radio interference, on February 14, 2019
(3) Units 1, 2, and 3 analysis of manual compensatory actions to maintain high pressure safety injection operability and availability during reactor water tank full flow recirculation evolutions, on February 20, 2019
(4) Unit 2 reactor coolant pump vibration monitoring system, on February 22, 2019
(5) Unit 2 operability of shutdown cooling loop 1 isolation valve SI

-653, on March 21, 2019

(6) Unit 3 pressurizer level control system tuning issues, on March 26, 2019

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Sample s) The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 diesel generator A crankcase breather ventilation piping modification DG

-1153, on February 28, 2019

(2) Station blackout generator 1 and 2 modification for permanently adjusting lube oil high pressure alarm set point, on March 20, 2019

71111.19 - Post Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01)

(4 Sample s) The inspectors evaluated the following post maintenance tests:

(1) Unit 3 control element assembly power switch assembly test following replacement, on February 12, 2019
(2) Unit 3 diesel generator B fuel oil transfer pump test following terminal board replacement, on February 21, 2019
(3) Unit 3 diesel generator A fast start following a diesel super outage, on March 8, 2019
(4) Unit 3 safety injection valve 615 test following periodic maintenance

, on March 19, 2019

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

In Service Testing (IST) (IP Section 03.01)===

77ST-9EW01, Unit 1 essential cooling water A inservice pump test, on January 31, 2019 Surveillance Testing (IP Section 03.01)

(3 Sample s)

(1) Unit 3 diesel generator A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance and hot restart, on January 7, 2019
(2) 77ST-9SB19, Unit 1 core protection calculator system channel C functional test, on January 8, 2019
(3) 36ST-9SA02, Unit 1 engineered safety features actuation system train B subgroup relay functional testing, on February 21, 2019

71114.06 - Drill Evaluation

===Drill and/or Simulator

-Based Licensed Operator Requalification Training (IP Section 02.01) (see 71114.06 for sample guidance)===

The inspectors evaluated a dress rehearsal drill that required emergency facilities to respond to a fire in a diesel generator room, a steam generator tube rupture, and a steam line break on February 5, 2019.

71114.08 - Exercise Evaluation Scenario Review

===Inspection Review (IP Section 02.01

- 02.04)===

The inspectors reviewed and evaluated the proposed scenario for biennial emergency plan exercise on February 11, 2019. This review did not constitute approval of the scenario.

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 02.02)

The inspectors evaluated the calibration and testing program implementation.

Alarm set point and calibration method check of personnel contamination monitors, portal monitors and small article monitors

iPCM-12 SAM-12 7 Failure to meet calibration or source check acceptance criteria
SAC-4 PNR-4 MGTM Walk Downs and Observations (IP Section 02.01)

(1 Sample) The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

The inspector observed the following

Portable survey instruments
BC-4 SAC-4 RM-20 (multiple)

FH40GL CM-11 Source check demonstration

RM-20 FH40GL SAM-12 Area radiation monitors and continuous air monitors
RU-1 RU-2 RU-3 RU-8 RU-12 RU-15 RU-16 RU-33 RU-34 RU-37 RU-140 RU-142A-D RU-149 RU-152A RU-155D RU-158D Personnel contamination monitors, portal monitors and small article monitors
iPCM-12 PCM-12 SAM-12

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

RU-12, Unit 1 Waste Gas Decay Tank Monitor Calibration RU-144, Unit 1 Plant Vent Monitor High Calibration RU-143, Unit 2 Plant Vent Monitor Low Calibration RU-145, Unit 2 Fuel Building B Vent Exhaust Monitor Low Calibration RU-143, Unit 3 Plant Vent Monitor Low Calibration RU-146, Unit 3 Fuel Building B Vent Exhaust Monitor High Calibration Dose Calculations (IP Section 02.05)

(1 Sample): The inspectors reviewed the following liquid and gaseous discharge permits to evaluate public dose calculations:

Permit 20172058, Unit 2 Refueling Purge Permit 20182030, Unit 2 Plant Vent Permit 20182103, Unit 2 Fuel Building Vent Permit 20181142, Unit 1 Plant Vent Permit 20181145, Unit 1 Fuel Building Vent Permit 20191015, Unit 1 Fuel Building Vent Permit 20192013, Unit 2 Plant Vent Permit 20192015, Unit 2 Fuel Building Vent The inspectors also reviewed the following annual radiological effluent release reports:

2016 Annual Radioactive Effluent Release Report 2017 Annual Radioactive Effluent Release Report Abnormal gaseous or liquid tank discharges

CR-2018-14265, Oily Waste Separator Tank Overflow Instrumentation and Equipment (IP Section 02.04)

(1 Sample) The inspectors reviewed the following radioactive effluent discharge system surveillance test results: STWO 4777407, Unit 1 Containment Building Purge Air Filtration Unit STWO 4813386, Unit 2 Fuel and Aux Building Essential Air Filtration Unit STWO 4836778, Unit 1 Fuel and Aux Building Essential Air Filtration Unit STWO 4866355, Unit 3 Fuel and Aux Building Essential Air Filtration Unit

9 Sampling and Analysis (IP Section 02.03)

(1 Sample) The inspectors reviewed the following radioactive effluent sampling and analysis activities:

RU-145, Unit 3 Fuel Building Radiation Monitor Filter Change out and Gas Grab Sample RU-143, Unit 2 Plant Ventilation Radiation Monitor Filter Change out and Gas Grab Sample Unit 2 Primary to Secondary Sampling Effluent discharges

Unit 3 Fuel Building Vent Gas Effluent Discharge Permit Unit 2 Plant Vent Gas Effluent Discharge Permit Walk Downs and Observations (IP Section 02.01)

(1 Sample) The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

Unit 2 Plant Vent Radiation Monitoring System Unit 3 Plant Vent Radiation Monitoring System Unit 3 Fuel Building Radiation Monitoring System Unit 3 Fuel Building Ventilation Exhaust System

71124.07 - Radiological Environmental Monitoring Program

Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)

The inspectors evaluated the licensee's groundwater monitoring program.

Site Inspection (IP Section 02.01)

(1 Sample) The inspectors evaluated the radiological environmental monitoring program implementation.

Walkdowns and calibration and maintenance record review

Air Sampling Station Site 4 The inspectors observed the following environmental sample collections and preparation:

Sites 4, 6A, 7A, 14A, 15, 17A, 21, 29, 35, and 40 Goat milk Licensee actions in response to missed sample, inoperable sampler, lost thermoluminescent detector (TLD) or anomalous measurement

Air Sample Site 6A Milk Sample Site 53 TLD Site 16 Sampling program for the potential of licensed material entering groundwater Reactor Water Makeup Tank Reactor Water Tank Holdup Tank Essential Pipe Density Tunnel

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage in the follow areas:

Dry Active Waste Processing and Storage (DAWPS) Facility Low Level Radioactive Materials Storage Facility (LLRWSF)

Container check (e.g., swelling, leakage and deformation)

10-4191 Main Steam Safety Valve container 12-0197 Main Steam Safety Valve container 14-210H Shipping Cask 17-1-044 55 gallon drum of In Core Instruments (ICI's)17-1-045 55 gallon drum of ICI's 17-1-046 55 gallon drum of ICI's 18-3-097 Sealand Dry Active Waste (DAW)19-2-004 Sealand DAW 19-2-007 Intermodal Asphalt 19-2-008 Intermodal Asphalt 19-3-006 Sealand DAW Radioactive Waste System Walkdown (IP Section 02.02)

(1 Sample) The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns

.

Liquid or solid radioactive waste processing systems

Dry Active Waste Processing and Storage (DAWPS) Facility Low Level Radioactive Materials Storage Facility (LLRWSF)

Radioactive waste resin and/or sludge discharges processes:

High Integrity Container Receipt, Handling, Use, and Closure Self-Engaging Rapid Dewatering Systems (SERDS) Operation Shipment Preparation (IP Section 02.04)

(1 Sample) The inspectors were not able to evaluate and observe radioactive material shipment preparation processes as no shipments were in process.

However, the inspectors reviewed several shipment packages that included surveys, pictures, and assessments in preparation for shipment.

Shipping Records (IP Section 02.05)

(1 Sample) The inspectors evaluated the following non

-excepted package shipment records:

17-SH-036 17-SH-068 18-RW-026 18-RW-028 18-RW-034 18-SH-018 18-SH-062 Waste Characterization and Classification (IP Section 02.03)

(1 Sample) The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

Dry Active Waste streams for Unit 1 (Sample ID: 1-17-042), Unit 2 (Sample ID: 2 014), and Unit 3 (Sample ID: 3 040) Filter analysis associated with shipping packages 18

-RW-026 and 18

-RW-028 Unit 2 waste oil analysis (Sample ID: 2 037) Resin analysis associated with shipping package 18

-SH-06

==OTHER ACTIVITIES

- BASELINE==

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)

(3 Sample s) Units 1, 2, and 3, January 1, 2018

-December 31, 2018 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(3 Sample s) Units 1, 2, and 3, January 1, 2018

-December 31, 2018 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (3 Sample s) Units 1, 2, and 3, January 1, 2018

-December 31, 2018 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)

(3 Sample s) Units 1, 2, and 3, January 1, 2018

-December 31, 2018 Drill/Exercise Performance (IP Section 02.12) ===

The inspector reviewed data for the Drill/Exercise Performance indicator for the period January 1, 2018 , through December 31, 2018. ERO Drill Participation (IP Section 02.13) (1 Sample)===

The inspector reviewed data for

the ERO Participation Performance indicator for the period January 1, 2018 , through December 31, 2018. Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

The inspector reviewed data for the Alert and Notification Performance indicator for the period January 1, 2018 , through December 31, 2018.

71152 - Problem Identification and Resolution

Annual Follow

-up of Selected Issues (IP Section 02.03)

(2 Sample s) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:

(1) Units 1 and 3 control element drive mechanism control system power switch assembly failures
(2) Unit 1 balance of plant engineered safety features actuation system train A troubleshooting, and replacement of the train A engineered safety features load sequencer module

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60854 - Preoperational Testing of an Independent Spent Fuel Storage Inspection (ISFSI) An ISFSI inspection was conducted at PVNGS on March 19

-21, 2019, by inspectors from Region I, Division of Nuclear Material s Safety. The PVNGS ISFSI was licensed as a general 10 CFR Part 72 licensee. The licensee had been utilizing the NAC, Universal Multi

-Purpose Canister system (UMS), approved under Certificate of Compliance (CoC)72-1015, Amendment 5, and NAC UMS Final Safety Analysis Report (FSAR), Revision 11, to load and store spent fuel at their ISFSI. At the time of the on

-site inspection, PVNGS's ISFSI pad contained 152 NAC ventilated concrete casks (VCCs), each containing the steel Transportable Storage Container (TSC) with a capacity for 24 pressurized water reactor 13 (PWR) spent fuel assemblies. The last routine ISFSI inspection was performed in March 2017 (ADAMS Accession No. ML17130B002).

Under the provisions of 10 CFR 72.210 and 10 CFR 72.212, PVGNS has decided to adopt and utilize a different storage system to store spent fuel casks at their ISFSI. The licensee has elected to utilize the NAC, Magnastor System under CoC 72

-1031, Amendment 7, and FSAR Revision 10. The Magnastor TSC has the capacity to store 37 PWR spent fuel assemblies in each VCC.

The purpose of the inspection was to observe and evaluate the licensee's pre-operational testing and training exercises required to be performed by a general licensee prior to use of the system to load spent fuel assemblies. The NAC Magnastor CoC 72

-1031, Appendix A, Technical Specification (TS) 5.8 contains a list of loading, closure, handling, unloading, and transfer operations that are required to be performed. During the inspection the NRC inspectors observed PVNGS perform the following demonstrations from TS 5.8 (c): closing and sealing of the TSC to demonstrate welding

weld inspection and documentation
and leak testing. PVNGS still has a number of demonstrations that are required to be completed before the licensee can utilize the Magnastor system. Those demonstrations are projected to be performed in the summer of 2019.

The ISFSI activities specifically reviewed during the on

-site inspection:

(1) Evaluated and observed dry run operations which included welding, weld inspection and documentation, and leak testing in accordance with TS 5.8 (c).
(2) Reviewed welder qualification program, welder performance qualifications, welding procedure specifications, and welding procedure qualification records.
(3) Reviewed NDE program procedure, NDE personnel certification records, the qualification program for visual test and liquid penetrant exams, liquid penetrant procedure, visual testing procedure, and helium leak testing procedure.
(4) Review Certified Material Test reports for liquid penetrant chemicals and welder filler metals.
(5) Evaluated and observed licensee's radiation protection implementation during the dry run observations.
(6) Evaluated and observed licensee's implementation of foreign material exclusion program during welding demonstrations.

The inspectors did not identify any issues of concern requiring documentation.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

On February 8, 2019, the inspector presented the baseline radiation safety inspection results to Mr. J. Cadogan , Senior Vice President of Site Operations, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

14 On March 21, 2019, the inspectors presented the results from the ISFSI pre

-operational welding demonstration inspection to Ms. Maria Lacal, Senior Vice President of Regulatory Oversight, and other members of the licensee staff. Licensee personnel acknowledged the information presented. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On April 12, 2019, the inspector presented the quarterly resident inspector inspection results to Mr. Jack Cadogan, Senior Vice President, Site Operations

, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

DOCUMENTS REVIEWED

71111.01-Adverse Weather Protection

Procedures Number Title Revision 40OP-9ZZ19 Hot Weather Protection

40OP-9HS01 Site Building HVAC

Calculations

Number Title Revision 13-MC-SP-0307 SP/EW System Thermal Performance Design Bases Analysis 9 71111.04-Equipment Alignment

Condition Reports

17-02911 Work Orders

2711244 2781196 Procedures Number Title Revision 40OP-9DG01 Emergency Diesel Generator A

40ST-9SI13 Train A LPSI and CS System Alignment Verification

Drawings Number Title Revision 13-M-DGP-0001 P & I Diagram Diesel Generator System

71111.05AQ

-Fire Protection Annual/Quarterly

Miscellaneous Documents

Revision or Date Number Title PVNGS Updated FSAR

PVGS Pre-Fire Strategies Manual

13-MC-ZA-0808 MSSS Flooding At Elevation 81'

Fire Protection Database Detailed Report

05/09/1998

PVNGS Safety Evaluation Report

71111.06-Flood Protection Measures

Condition Reports

19-02890 19-02658 19-02418 19-02625 Procedures Number Title Revision 40DP-9OPA3 Auxiliary Building Station Rounds

40AL-9RK2B Panel B02B Alarm Response

40OP-9RD01 Radwaste Facility Sumps and Drains

Drawings Number Title Revision 01-M-RDP-002 Radioactive Waste Drain System

02-M-RDP-002 Radioactive Waste Drain System

03-M-RDP-002 Radioactive Waste Drain System

Miscellaneous Documents

Revision or Date Number Title PVNGS Updated FSAR

Pre-Fire Strategies Manual

13-MC-ZA-0808 MSSS Flooding at Elevation 81'

PO EDC-2019-00144 Revise Calculation 13

-MC-ZA-0808 03/01/2019

71111.11-Licensed Operator Requalification Program and Licensed Operator Performance

Procedures Number Title Revision 40DP-9OP02 Conduct of Operations

01DP-0AP57 Management of Critical Evolutions and Infrequently Performed Test or Evolutions

Miscellaneous Documents

Date Number Title Licensed Operator Continuing Training Simulator Evaluation Scenario

2/05/2019

71111.12-Maintenance Effectiveness

Condition Reports

18-16615 18-02240 18-01811 19-02330 19-02133 18-10880 18-10879 19-02364

Work Orders

4441828 4441462 Miscellaneous Documents Number Title Date 19-02330-006 Engineering Evaluation

2/21/2019

Palo Verde Maintenance Rule Database

71111.13-Maintenance Risk Assessments and Emergent Work Control

Condition Reports

16-15545 Procedures Number Title Revision 40DP-9RS01 Operations Department Online Nuclear Risk Management in Modes 1 and 2

70DP-0RA05 Assessment and Management of Risk When Performing Maintenance

40DP-9AP21 Protected Equipment

Miscellaneous Documents

Number Title Date EOOS 4.1 Scheduler's Evaluation for Palo Verde Unit 1

2/21/2019 09:41

EOOS 4.1 Scheduler's Evaluation for Palo Verde Unit 3

03/05/2019

71111.15-Operability Determinations and Functionality Assessments

Condition Reports

18-16665 17-04204 18-18476 19-02567 19-02330 19-01290 18-17794 19-01962 19-01941 14-00853 19-04380 19-04382 Work Orders

5071741 Procedures Number Title Revision 40DP-9OP26 Operations Condition Reporting Process and Operability Determination / Functionality Assessment

73DP-0EE05 Engineering Preventive Maintenance Program

Procedures Number Title Revision 40OP-9SV01 Loose Parts and Vibration Monitoring

73TI-9ZZ35 Ultrasonic Examination of Reactor Coolant Pump Shafts

31MT-9RC23 Reactor Coolant Pump Sulzer Bingham Seal Replacement

40TI-9SF01 Pressurizer Level Control System Tuning

Miscellaneous Documents

Revision or Date Number Title 18-17794-004 Level 2 Cause Analysis Report

TR-100491 EPRI: UPS Maintenance and Application Guide

Design Basis Manual: Safety Injection System

CRAI 3245187

Evaluation of the Class

-1E and PK Inverters and Associated Subcomponents

CRDR 3300933

Year SCR Replacement for PN and PK Inverters

RCTSAI 4524360

RCP Vibration Monitoring

04/17/2014

RCTSAI 4524358

RCP Shaft Ultrasonic Inspection Following Seal Replacement

04/17/2014

RCTS 4524352

RCP Vibration Monitoring and Shaft UT Inspections

04/18/2014

PVAR 4524366

Actions for License Amendments 84, 72, and 56

04/17/2014

71111.18-Plant Modifications

Condition Reports

16-19472 19-02927 14-00965 18-04376 Work Orders

3094267 4805058 Miscellaneous Documents

Number Title Revision S-19-0005 10 CFR 50.59 Screening/Evaluation

18-04376-004 Design Equivalent Change Package: TMOD SBOG#! Lube Oil High Pressure Alarm Set

point Schedule Adjustment

71111.19-Post Maintenance Testing

Condition Reports

16-03732 19-03482 19-04033

Work Orders

5103635 4945749 4498502 4507037 4752532 5055992 5076980 4960255 5085998 Procedures Number Title Revision 40OP-9DG01 Emergency Diesel Generator A

40OP-9DF01 Diesel Fuel Oil Storage and Transfer

73ST-9DF01 Diesel Fuel Oil Transfer Pumps

- Inservice Test

40OP-9SF01 Control Element Drive Mechanism Control System (CEDMCS) Operation

71111.22-Surveillance Testing Work Orders

4802907 4936283 4937964 4940893 Procedures Number Title Revision 36ST-9SA02 ESFAS Train B Subgroup Relay Functional Test

40ST-9DG01 Diesel Generator A Test

73ST-9DG07 Class 1E Diesel Generator Load Rejection 24 Hour Rated Load And Hot Start Test Train A

77ST-9SB19 CPCS Channel C Functional Test

73ST-9EW01 Essential Cooling Water Pumps

- Inservice Test

71114.06-Drill Evaluation

Miscellaneous Documents

Number Title Date 1901 Dress Rehearsal Controller Guide TSC - Position Log

2/05/2019

Significant Events Log

2/05/2019

Form EP-0541 Palo Verde NAN Emergency Message Form

71124.05-Radiation Monitoring Instrumentation

Procedures

Number Title Revision 74DP-9CY08 Radiological Monitoring Program

Procedures

Number Title Revision 74ST-9SQ23 Radiation Monitoring Calibration Test for New Scope Area

Monitors 18 74ST-9SQ33 Radiation Monitoring Calibration Test for Main Steam Line

Monitors 1 75RP-9EQ04 Calibration of the Eberline PNR

-4 Neutron Dose Rate

Instrument

75RP-9EQ13 Canberra Whole Body Counting System Calibration

75RP-9EQ31 Calibration, Response Check and Operation of the SAM

-12 Small Article Monitor

75RP-9EQ47 Calibration of the Eberline Model HP Series Frisker Probes

75RP-9EQ66 Calibration of the Thermo Scientific Model RO

-20 Ion Chamber Survey Meter

75RP-9ME05 Scaler Counting Systems Performance Checks

Audits and Self

-Assessments

Number Title Date 2Q 2017 Integrated Performance Assessment Report:

Radiation Protection Department

09/14/2017

2018-001 Audit Plan and Report: Chemistry

04/06/2018

218-04312 2017 Annual Radiation Protection Program Summary Report

07/11/2018

2018-007 Audit Plan and Report: Radiation Safety

2/14/2018

Condition Reports

17-01400 17-02247 17-08311 17-11014 17-13020 17-13492 17-15582 17-17353 18-02590 18-09583 Portable Instrumentation Calibration Data Sheet

Number Title Date 4380 PNR-4/NRD-1 Calibration Data Sheet

07/10/2018

8143 RO-20 Meter Data Sheet

09/07/2018

2708085 DRM 1/2 Calibration Data Sheet

10/01/2018

2914/12818

AMS-4 Calibration Data Sheet

10/09/2018

RAS-1 Air Sampler Calibration Data Sheet

10/19/2018

1182 RM-20 Count Rate Meter Data Sheet

01/04/2019

2927 FH 40 GL Internal Detector Calibration Data Sheet

01/15/2019

Portable Instrumentation Calibration Data Sheet

Number Title Date 11499 FHZ 612 Teleprobe Detector Calibration Data Sheet

01/24/2019

Stationary Radiation Instrument Calibration Records

Number Title Date 668 Small Article Monitor Calibration Data Sheet

09/18/2018 FastScan2 Calibration Verification Data Sheet

01/16/2019

364 BC-4 Instrument Calibration Data Sheet

01/22/2019

2983 3030P Calibration Data Sheet

01/23/2019

24 CM-11 Calibration Data Sheet

01/24/2019

213 PM-12 Calibration Cover Sheet

01/31/2019

2020 iPCM-12 Calibration Cover Sheet

2/05/2019

Calibration Source Records Number Title Date N997-0358 Kaman Report of Calibration Model KDA

-HR High Range Area Monitor Ion Chamber Detector

01/23/1980

8143 Shepherd Model 89 Verification Sheet

10/14/2018

940521 CDM-21 Calibrator Verification Report

10/24/2018

Work Order Records

Number Title Date 4980211 74ST9SQ343 Radiation Monitoring Calibration Test for Waste Gas Decay Tank RMC Monitor (Unit 3) RU

-12 03/08/2018

4867547 74ST9SQ333 Radiation Monitoring Calibration Test for Main Steam Line Monitors. (Unit 3)

(RU-139/140) 04/23/2018

4889856 "B" CTMT Build Refueling Purge Exhaust Monitor (Unit 1

RU-34) 07/25/2018

4898443 Personnel IARM A

-Side (Unit 1 RU

-155D) 08/28/2018

4948127 "A" Essential Cooling Water Radiation Monitor (Unit 3 RU

-02) 09/13/2018

4911530 74ST9SQ232 Radiation Monitoring Calibration Test for Baseline Area Monitors (Unit 2 RU

-148-151) 10/23/2018

Miscellaneous Documents

Number Title Date LS-6500 (U1, U2, & U3)

QC: Observed Source Response

- dpm 2018 U1 MCA Detectors 1, 2, & 3

QC: 88 and

1332 keV Activity and 1332 keV FWHM

2018

Miscellaneous Documents

Number Title Date U2 MCA Detectors 1, 2, & 3

QC: 88 and 1332 keV Activity and 1332 keV FWHM

2018 U3 MCA Detectors 1, 2, & 3

QC: 88 and 1332 keV Activity and 1332 keV FWHM

2018 237-03041-CAS 2 nd Quarter 2018 Chemistry Hot Cross Checks

07/27/2018

237-03046-CAS 4 th Quarter 2018 Chemistry Hot Cross Checks

01/22/2019

71124.06-Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision 74AL-9SQ01 Radiation Monitoring Systems Alarm Validation and Response

001 74RM-9EF20 Gaseous Radioactive Release Permits and Offsite Dose Assessment

018 74RM-9EF23 Secondary System Liquid Discharge

016 74RM-9EF40 Radiation Monitoring System Operations

2 74RM-9EF41 Radiation Monitoring System Alarm Response

23 74RM-9EF42 Radiation Monitor Alarm Setpoint Determination

033 74RM-9EF43 Actions for Non

-Functional Radiation Monitors: Preplanned Alternate Sampling Program

017 74RM-9EF60 RMS Sample Collection

2 74RM-9EF63 RU-143 Sample Operations

001 74RM-9EF65 RU-145 Sample Operations

000 74RM-9EF80 RMS/Effluent Action Documentation

006 75RM-9EF01 Determination of Primary

-to-Secondary Leak Rate

000 Audits and Self

-Assessments

Number Title Date 17-11047-003 Radiological Monitoring Program

09/07/2017

2018-001 Nuclear Assurance Department (NAD): Chemistry

04/06/2018

2018-04312 2017 Annual Radiation Protection Program Summary Report 07/11/2018

2018-007 Nuclear Assurance Department (NAD): Radiation Safety

2/14/2018

Condition Reports

16-02244 17-0299 17-01573 17-01926 17-05289 17-07961 17-11047 17-11559 17-13603 17-17884 18-02621 18-04140 18-04530 18-06915 18-08466 18-09004 18-11148 18-12193 18-13299 18-14265 18-14342 18-17591 19-00212 19-01531

Effluent Monitor Calibration Records

Number Title Date STWO 04715454

RU-145 Unit 2 Fuel Building B Vent Exhaust Monitor Low

2/22/2017

STWO 04736183

RU-143 Unit 3 Plant Vent Monitor Low

04/22/2017

STWO 04760261

RU-146 Unit 3 Fuel Building B Vent Exhaust Monitor High Calibration

05/10/2017

STWO 04863095

RU-144 Unit 1 Plant Vent Monitor High

09/15/2017

STWO 04980503

RU-12 Unit 1 Waste Gas Decay Tank Monitor

03/19/2018

STWO 04904815

RU-143 Unit 2 Plant Vent Monitor Low

09/20/2018

Air Cleaning System Surveillance Test Records

Number Title Date STWO 4777407

Unit 1 Containment Building Purge Air Filtration Unit

09/06/2017

STWO 4813386

Unit 2 Fuel and Aux Building Essential Air Filtration Unit

2/21/2017

STWO 4836778

Unit 1 Fuel and Aux Building Essential Air Filtration Unit

2/09/2018

STWO 4866355

Unit 3 Fuel and Aux Building Essential Air Filtration Unit

05/29/2018

Gaseous Discharge Permits

Number Title Date 20172058 Unit 2 Refueling Purge

05/02/2017

20182030 Unit 2 Plant Vent

03/15/2018

20182103 Unit 2 Fuel Building Vent

09/11/2018

20181142 Unit 1 Plant Vent

11/08/2018

20181145 Unit 1 Fuel Building Vent

11/20/2018

20191015 Unit 1 Fuel Building Vent

01/29/2019

20192013 Unit 2 Plant Vent

01/31/2019

20192015 Unit 2 Fuel Building Vent

2/05/2019

Counting Detector Calibrations

Number Title Date GMAR4L HpGE Geometry

- Unit 3 4500 cc gas Marinelli beaker

01/14/2016

PFIL1 HpGE Geometry

- Unit 1 Particulate filer on shelf 1

07/20/2016

CCART1 HpGE Geometry

- Unit 1 F&J cartridge on shelf 1

07/22/2016

CP1001 HpGE Geometry

- Unit 2 CP100 charcoal face down shelf 1

11/21/2017

GMAR1L HpGE Geometry

- Unit 1 Gas 1L Marinelli beaker on detector face

2/08/2017

GVIAL1 HpGE Geometry

- Unit 2 9.2 cc gas vial shelf 1

2/14/2017

Miscellaneous Documents

Number Title Date Palo Verde Generating Station Daily Status Report

2/5-8/2019

Miscellaneous Documents

Number Title Date Offsite Dose Calculation Manual (ODCM) Palo Verde Nuclear Generating Station Units 1, 2, and 3

03/24/2016

RCTSAI 1566

2016 Annual Radioactive Effluent Release Report

04/15/2017

2-17-014 Waste Stream Report: Unit 2 Dry Active Waste

04//18/2017

1-17-042 Waste Stream Report: Unit 1 Dry Active Waste

10/28/2017

3-18-040 Waste Stream Report: Unit 3 Dry Active Waste

04/15/2018

RCTSAI 1566

2017 Annual Radioactive Effluent Release Report

04/25/2018

71124.07-Radiological Environmental Monitoring Program

Procedures

Number Title Revision 74RM-0EN02 Radiological Environmental Air Sampling

74RM-0EN03 Radiological Environmental Sampling

74RM-0EN05 Environmental TLD Exchange/Reporting

74RM-0EN07 Land Use Census

Audits and Self

-Assessments

Number Title Date Integrated Performance Assessment Report

- Radiation Protection Department Quarter #1

06/22/2017

Integrated Performance Assessment Report

- Radiation Protection Department Quarter #2

09/14/2017

Integrated Performance Assessment Report

- Radiation Protection Department Quarter #3

2/19/2017

Integrated Performance Assessment Report

- Radiation Protection Department Quarter #4 03/09/2018

218-04312 Annual Radiation Protection Program Summary Report

07/11/2018

Integrated Performance Assessment Report

- Radiation Protection 1

st Half 2018 08/15/2018

SWMS No. 15-04023-003 Groundwater Protection Initiative NEW 07

-07 12/06/2018

2018-007 Nuclear Assurance Department (NAD) Audit Plan and Report - Radiation Safety

2/14/2018

Condition Reports

17-00760 17-01085 17-01203 17-01859 17-03281 17-03798 17-04052 17-04054 17-04212 17-04747 17-06259 17-07102 17-07269 17-08535 17-10101 17-10463 17-10476 17-10693 17-15048 17-17823

Condition Reports

17-18260 18-00109 18-00633 18-01069 18-01383 18-01500 18-01583 18-03310 18-04530 18-06018 18-10111 18-10649 18-10739 18-11127 18-11210 18-12934 18-14265 18-15019 Groundwater Protection Documents Revision or Date Number Title 75DP-9AP01 Ground Water Protection Program

SWMS No. 15-04023-003 Groundwater Protection Initiative NEI 07

-07 12/06/2018

Meteorological Calibration Records

Number Title Date WO 4905809

Met System Redundant

Cab 12/12/2017

WO 4905809

Met System Primary Cab A

11/06/2017

WO 4988254

Met System Calibration (Primary System)

10/10/2018

WO 4988280

Met System Calibration (Redundant System)

10/10/2018

Miscellaneous Documents

Number Title Date 2016 Annual Radiological Environmental Operating Report

04/14/2017

2017 Annual Radiological Environmental Operating Report

04/10/2018

71124.08-Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation

Procedures

Number Title Revision 75RP-9RP15 Control and Storage of Radioactive Material and Radioactive Wastes 30 76DP-0AP12 Low Level Radioactive Material Storage Facility Overview

76-DP-0RP01 Radioactive Waste Management Program Overview

76-DP-0RP03 Radwaste Process Control Program

76-RP-0RW03 Waste Stream Sampling and Database Maintenance

76-RP-0RW05 Packaging and Classification of Radioactive Waste

76-RP-0RW06 Packaging of Radioactive Material

76-RP-0RW07 Shipping Radioactive Materials

76-RP-0RW08 High Integrity Container Receipt, Handling, Use, and Closure

76-RP-0RW09 Transfer, Storage and Processing of Radioactive Filters

Procedures

Number Title Revision 76-RP-0RW10 Handling and Storage of Radioactively Contaminated Chemical Waste and Mixed Waste

76-RP-0RW82 Self-Engaging Rapid Dewatering System (SERDS) Operation 4 91-DP-0EN50-02 Waste Stream Characterization Administrative Guideline

Audits and Self

-Assessments

Number Title Date 24202 NUPIC Audit: WMG, Inc.

03/18/2016

24365 NUPIC Audit: Energy Solutions 12/04/2017

2017-002 NAD Audit: Procurement and Material Control

05/05/2017

2018-007 NAD Audit: Radiation Safety

2/14/2018

2-03734 January 2018 Offsite Safety Review Committee Meeting 18

-001, Operations, Chemistry and Radiation Protection Subcommittee Report 01/26/2018

Shipping Packages

17-RW-004 17-SH-036 17-SH-055 17-SH-068 18-RW-009 18-RW-020 18-RW-022 18-RW-026 18-RW-028 18-RW-034 18-SH-018 18-SH-062 Condition Reports

17-02737 17-04797 17-12153 17-13693 17-17333 17-18114 18-00790 18-03801 18-07057 Surveys Survey Number

Title Date 0-M-20190110-1 DAWPS Processing Area Monthly Survey

01/10/2019

0-M-20190110-3 LLRMSF Monthly Survey

01/10/2019

0-M-20190102-2 DAWPS Monthly Yard Survey

01/10/2019

0-M-20190123-1 DAWPS Storage Area Monthly Routine Survey

01/23/2019

Sample Analyses

Type Sample ID Date Unit 1 DAW

1-17-042 12/28/2018

Unit 2 DAW

2-17-014 12/28/2018

Unit 3 DAW

3-18-040 12/28/2018

Unit 2 Oil

2-18-037 09/01/2017

Miscellaneous Documents

Number Title Date NBA11C000113

Radiation Protection Technician Training

Program: Packaging Radioactive Material

08/14/2018

NBA19C000109

Radiation Protection Technician Training

Program: Shipping Radioactive Material

07/31/2015

2016 Annual Radioactive Effluent Release Report

04/15/2017

2017 Annual Radioactive Effluent Release Report

04/15/2018

Employee Training Records: Shipping Radioactive Material 03/31/2017 and 08/11/2017

Waste Control Specialist Generator Certification Approval Letter

11/03/2017 and 09/07/2018

71151-Performance Indicator Verification

Miscellaneous Documents

Number Title Revision NEI 99-02 Regulatory Performance Indicator Document

71152-Problem Identification and Resolution

Condition Reports

19-00802 18-18324 18-19112 18-15793 18-18212 19-02376 19-02956 19-03063 Work Orders

4481512 5101889 Procedures Number Title Revision 36ST-9SA05 FBEVAS, CREFAS, and CRVIAS 18 month Functional Test 24 40OP-9SA01 BOP ESFAS Modules Operation

40OP-9SA02 De-Energization of BOP ESFAS

40AL-9RK5A Panel B05A Alarm Response

40DP-9OP06 Operations Department Repetitive Task Program

130 Drawings Number Title Revision 01-E-SAB-004 Elementary Diagram ESF Actuation System BOP

-ESFAS Intertying Circuits Train A & Train B

Miscellaneous Documents

Number Title Revision PVNGS Updated FSAR

4OA5-Other Activities (IP 60854)

Condition Reports

19-04069 Procedures

Number Title Revision GQP 9.0 PCI Training, Qualification, Examination, and Certification of NDE Personnel

GQP 9.1 PCI Training, Qualification, Examination, and Certification of Inspection and Testing Personnel

GQP 9.2 PCI High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds

GQP 9.7 PCI Liquid Penetrant Examination and Acceptance Standards for Welds (40

- 125 degrees F)

GQP 9.6 PCI Visual Examination of Welds

75DC-9SF02 Radiation Protection for Magnastor

PI-CNSTR-OP-PV-NMS-01 Closure Welding of Magnastor Canisters for PV

30DP-9MP23 Foreign Material Exclusion Controls

MSLT-PCI-PV Helium Mass Spectrometer Leak Test Procedure

4108-0 Design Basis Documents

Number Title Revision ISFSI FSAR

NAC Magnastor Final Safety Analysis Report

CoC 1031 CoC and Technical Specifications for Magnastor System Amendment 7

Miscellaneous Documents

Revision or Date Number Title Q-16 A Leak Test Specialist NDE LT Level III Personnel Certificate

09/19/2018

S AP #27044 P CI NDE VT/PT Level II Personnel Certificate

01/15/2019

CMTR s Spotcheck

Penetrant, SKL-SP 2 Spotcheck Developer SKD-S2, SKC-S, and Sherwin Certification for

D-100, D-350, KO-17, KO-19 Liquid Penetrant Materials Various dates

Certificate of

Compliance #915501-02 Various Welding Shims and Wire Various dates

Miscellaneous Documents

Revision or Date Number Title 8 MC-GTAW P CI Welding Procedure Specification

Machine Gas Tungsten Arc Welding 16 PQR-62 PCI Procedure Qualification

Record for WPS

3 PQE-63 PCI Procedure Qualification

Record for

Manual GTAW 6 PQR-600 PCI Procedure Qualification Record for

Machine GTAW

PQR-899 PCI Procedure Qualification Record for

Machine 8 GTAW 4

The following items are requested for the

Public Radiation Safety Inspection

at Palo Verde Dates of Inspection: 02/04/2019

to 02/08/2019

Integrated Report 2019001 Inspection areas are listed in the attachments below.

Please provide the requested information on or before Monday, January 21, 2019

. Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.0

should be in a file/folder titled

"5-A," applicable organization charts in file/folder "

5-B," etc. The information should be provided in electronic format or a secure document management service. If information is placed on a secured document management system, 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 Natasha Greene at 817

-200-1154 or via

e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.

S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150

-0011.

5. Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection:

January 23, 2017

A. List of contacts and telephone numbers for the following areas below. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well. 1. Process monitor calibration (Include Chemistry, Systems Engineering and I&C, as applicable)

2. Radiation protection instrument calibration (Portable and Stationary)

3. Installed instrument calibrations (Include Systems Engineering and I&C)

4. Count room and Laboratory instrument calibrations (Include RP and Chemistry, as applicable)

5. EP contacts for Equipment Important to Emergency Response/Preparedness (EITER) 6. Licensing/Regulatory Affairs

B. Applicable organization charts, including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support, LARs, and LERs, performed since the date of the last inspection, related to:

1. Portable Radiation instruments: Area radiation monitors, portable continuous air monitors (AMS3/4), portable survey instruments (count rate, dose rate, occupational air sampling), electronic dosimeters, teledosimetry

2. Stationary Radiation Instruments: Portal monitors, small article monitors, personnel contamination monitors, or whole body counters

3. Installed Radiation Instruments: Area radiation monitors (RMS), process monitors (non-effluent), criticality monitors, accident monitors

4. Count Room instrumentation (Chemistry and RP, if separate RP Ops and Effluents): Gamma Spec, LSC, Gross Alpha, Gross Beta, including bench

-top counters

D. Procedure indexes for radiation protection procedures and other related disciplines.

1. Calibration, use, and operation of continuous air monitors, portable survey instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry

2. Calibration use and operation of portal monitors, small article monitors, personnel contamination monitors, and whole body counters

3. Calibration of installed area radiation monitors, process monitors, criticality monitors, and accident monitors

4. Calibration use and operation of Count Room instrumentation (GS, LSC, GA, GB) (include bench top counters here)

NOTE: Please ensure that RP, Chemistry, and I&C procedures are included, as appropriate.

E. Please provide specific procedures related to the following areas noted below. Additional procedures may be requested by number after the inspector reviews the procedure index.

1. Calibration of portable ion chambers

2. Calibration of Friskers

3. Calibration of telescoping high range instruments

4. Calibration of portable neutron instruments

5. Calibration of SAMs

6. Whole body counter calibration

7. Laboratory instrumentation quality control

8. Calibration of Containment/Drywell high range radiation monitor

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of the last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, portable survey instruments, electronic dosimeters, and teledosimetry

2. Portal monitors, small article monitors, personnel contamination monitors, and whole body counters

3. Installed radiation monitors, criticality monitors, accident range monitors

4. Count room radiation instruments

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level

assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are "sortable" and "searchable" so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. State the required calibration frequency and provide the most recent calibration data for the whole body counters, at least one portable survey instrument, one area radiation monitor, one air sampler, one continuous air monitor, and one drywell/containment high

-range monitor.

I. Provide a list of any scheduled calibrations, while we are onsite, for the instrumentation noted in request above, in 5

-I. J. Provide the alarm set point values for the portal and personnel contamination monitors in operation.

K. Radiation Monitoring System health report for the previous 12 months

L. Provide the following lists of instruments to include make, model, identifier (S/N or plant ID), and location:

1. Portable radiation instruments currently in use (for EADs just make, model, and quantity).

2. Stationary radiation instruments currently in use.

3. Installed Radiation monitors

a. Area radiation monitors and

b. Process radiation monitors.

(Include their instrumentation designator, function and calibration procedure number and title.) Please indicate which, if any, detectors have been

replaced within the past 2 years (since the last inspection).

c. Radiation instrumentation abandoned in place.

d. Radiation instrumentation covered by the maintenance rule.

M. Provide a list of sources used routinely for source check of portable, stationary, a

nd installed radiation monitoring instruments.

N. Provide the NIST traceability and calibration or verification of the primary sources for instrument calibration and the procedures used to achieve this.

6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection:

January 23, 2017

A. List of contacts and telephone numbers for the following areas. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological effluent control (liquid & gaseous) and reporting

(RP, Chemistry, RW, Ops, etc.)

2. Effluent Monitor calibration (liquid and gaseous) and maintenance

(RP, Chemistry, I&C, Maintenance, Systems Engineering, EP, etc.)

3. Engineered safety feature air

cleaning systems for effluent release

(Systems Engineering, I&C, Maintenance, etc.)

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles for the above individuals and also for their supportive Management. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, self

-assessments, vendor or NUPIC audits of contractor support, and LERs written since the date of the last inspection, related to:

1. Radioactive effluents and effluent radiation monitors 2. Engineered Safety Feature Air cleaning systems

D. Procedure indexes for the following areas and related disciplines.

1. Radioactive effluents and effluent radiation monitors (to include the flow monitors)

2. Engineered Safety Feature Air cleaning systems (both TS and non

-TS systems for effluents)

E. Please provide specific procedures related to the following areas noted below. Additional procedures may be requested by number after the inspector reviews the procedure indexes.

1. Sampling and analysis of radioactive effluents

2. Effluent monitor setpoint determination

3. Generating radioactive effluent release permits

4. Effluent Monitor Calibrations (Include associated flow monitors)

5. Laboratory instrumentation quality control

6. In-place testing of HEPA filters and charcoal adsorbers for TS effluent exhaust systems and other effluent air

-cleaning systems, but not breathing air systems

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of the last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors (include associated effluent flow monitors)

3. Engineered Safety Feature Air cleaning systems (effluents, not breathing air)

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level

assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are "sortable" and "searchable" so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.)

If codes are used, please provide a legend for each column where a code is used.

H. Annual Radioactive Effluent Release Reports for the latest two calendar years

I. Current revision of the Offsite Dose Calculation Manual (or other name, but include all parts for effluents) and any changes made since the last inspection.

J. The inter-laboratory comparison results for laboratory quality control performance of effluent sample analysis for the latest two calendar years

K. Effluent sampling schedule for the week of the inspection

L. Provide the last three annual trends of vent/stack effluent flow rates, by chart or table.

M. Operations department (or other responsible dept.) log records for effluent monitors removed from service or out of service or a list of

the same and compensatory actions taken during the out of service condition.

N. Listing or log of liquid and gaseous release permits since the date of the last inspection

O. A list of the technical specification

-required air cleaning systems with the two most recent surveillance test dates of in

-place filter testing (of HEPA filters and charcoal adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers associated with the surveillances (and their system number/name).

P. System Health Report for radiation monitoring instrumentation. Also, please provide a specific list of all effluent radiation monitors that were considered inoperable for 7 days or more since the date of the last inspection.

If applicable, please provide the relative Special Report and condition report(s). If not covered by maintenance rule, please provide rationale.

Q. A list of significant changes made to the gaseous and liquid effluent process monitoring system since the date of the last inspection.

If applicable, please provide the corresponding UFSAR section in which this change was documented.

R. A list of any occurrence in which a non

-radioactive system was contaminated by a radioactive system since the date of the last inspection.

Please include any relevant condition report(s).

S. Current Part 61 analyses for hard to detect radionuclides

T. Latest Land Use Census (coordinate with 71124.07)

U. Effluent based procedures for EALs or EOPs.

7. Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection:

January 23, 2017

A. List of contacts and telephone numbers for the following areas. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological environmental monitoring (RP, Chemistry, I&C, etc.)

2. Meteorological monitoring (RP, Chemistry, EP, I&C, System Engineering, etc.)

3. Maintenance and calibration of the above equipment

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, self

-assessments, vendor or NUPIC audits of contractor support, and LERs written since the date of the last inspection, related to:

1. Radiological environmental monitoring program (including contractor environmental laboratory audits, if used to perform environmental program functions)

2. Environmental TLD processing facility 3. Meteorological monitoring program

D. Procedure index for the following areas and other related disciplines.

1. Radiological environmental monitoring program

2. Meteorological monitoring program

3. Maintenance and calibration of related instrumentation, including the meteorological tower E. Please provide specific procedures related to the following areas noted below. Additional procedures may be requested by number after the inspector reviews the procedure indexes.

1. Sampling, collection and preparation of environmental samples

2. Sample analysis (if performed onsite)

3. Laboratory instrumentation quality control

4. Meteorological Tower sensor calibrations

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of the last inspection, related to the following programs: 1. Radiological environmental monitoring (include TLDs and air sample pumps or their infrastructure)

2. Meteorological monitoring (include Met Tower sensors and support equipment)

These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria

used. Please provide in document formats which are "sortable" and "searchable" so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. Copies of the two most recent calibration packages for the meteorological tower instruments

I. Copies of the Annual Radiological Environmental Operating Reports and Land Use Census for the latest two calendar years, and current revision of the Offsite Dose Calculation Manual. Please include any supportive documentation for the changes made to the ODCM since the last inspection.

J. Copy of the environmental laboratory's inter

-laboratory comparison program results for the latest two calendar years

, if not included in the Annual Radiological Environmental Operating Report

K. Data from the environmental laboratory documenting the analytical detection sensitivities for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)
L. Quality Assurance audits (e.g., NUPIC) for contracted services
M. Current NEI Groundwater Protection Initiative (GPI) Plan and status. Provide the most recent monitoring results for each monitoring well per the GPI. Provide a separate list of any missed samples, as applicable.
N. Technical requirements manual or licensee controlled specifications which list the meteorological instruments' calibration requirements O. If applicable, per NEI 07

-07, provide any reports that document any spills/leaks to groundwater since the date of the last inspection. Please indicate what external communications were made regarding each spill/leak.

P. Provide any new entries

into 10 CFR 50.75(g) files since

the date of the last inspection.

Q. Please identify your three highest X/Q (chi/Q) and/or D/Q sectors, as currently used in the selection of your required REMP sampling locations. If these are different values from your most recent meteorological assessment, please provide that assessment and indicate the three highest X/Q and/or D/Q sectors per your latest assessment. Also indicate your noted predominant

and least prevalent

wind direction/sector, as used in your REMP analysis.

R. Provide the height of the highest effluent release point. Please indicate if the height accounts for plant grade elevation. Please also provide the most probable

atmospheric release height, if different

from the highest effluent release point.

S. Please provide a schedule of any planned REMP sampling activities while we, the NRC, are scheduled to be onsite performing this inspection.

8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08)

Date of Last Inspection:

January 23, 2017

A. List of contacts and telephone numbers for the following areas. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Solid Radioactive waste processing (RP, Chemistry, Ops, Maintenance, I&C, Engineering, etc.)

2. Transportation of radioactive material/waste (RP, Maintenance, Ops, Security, Chemistry, etc.)

3. personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials)

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, department self

-assessments, and LERs written since the date of the last inspection, related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program D. Procedure index for the following areas and other related disciplines.

1. Solid radioactive waste management

2. Radioactive material/waste transportation

E. Please provide specific procedures related to the following areas noted below. Additional procedures may be requested by number after the inspector reviews the procedure indexes.

1. Process control program and any changes made since the last inspection

2. Solid and liquid radioactive waste processing

3. Waste stream sampling and analysis

4. Waste characterization and classification

5. Radioactive material/waste packaging & shipping

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date

for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of the last inspection, related

to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level

assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria

used. Please provide in document formats which are "sortable" and "searchable" so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. Copies of training lesson plans for 49 CFR 172, Subpart H, for radwaste processing, packaging, and shipping
I. Provide a summary list or log of radioactive material and radioactive waste shipments for the two most recent calendar years, in addition to the current calendar year.

J. Please provide at least two different radioactive waste stream sample analysis results and resulting scaling factors for the latest two calendar years.

K. A listing of all onsite radwaste storage facilities. Please include a summary

or list of the items stored in each facility with the most recent dose rates/surveys.

L. A list of any significant (e.g., DAW, resins, Type B or greater) radioactive shipments that will be completed during our onsite inspection period. If available, please provide the applicable shipping manifests/waste characterizations and most recent surveys for each shipment. M. A list of significant changes made to the liquid or solid radwaste processing systems since the date of the last inspection.

If applicable, please provide the corresponding UFSAR section in which this change was documented. Provide any supportive documentation for the changes made or have it readily available for review.

N. List of radioactive waste processing systems or equipment abandoned in place since the last inspection.

O. Please provide a schedule of radioactive material or waste processing or shipment activities during the inspection week. Please indicate the current storage location of the stored RAM or waste prepared for shipment, as well as any supportive surveys of its measured dose rates. If available, please indicate its current stated waste class.

ML19122A295

SUNSI Review:

ADAMS: Non-Publicly Available

Non-Sensitive Keyword: By: JDixon

Yes No Publicly Available

Sensitive

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

C:DRS/EB2

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4/30/2019 4/25/2019 4/25/2019 4/30/2019