IR 05000528/2021001

PV 2021001, Palo Verde Nuclear Generating Station - Integrated Inspection Report 05000528/2021001 and 05000529/2021001 and 05000530/2021001

ML21131A223
Person / Time
Site:	Palo Verde
Issue date:	05/12/2021
From:	John Dixon NRC/RGN-IV/DRP
To:	Lacal M Arizona Public Service Co
References
IR 2021001
Download: ML21131A223 (24)

Text

May 12, 2021

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - INTEGRATED INSPECTION REPORT 05000528/2021001 AND 05000529/2021001 AND 05000530/2021001

Dear Mrs. Lacal:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station. On April 7, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Palo Verde 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 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, John L. Digitally signed by John L. Dixon Dixon Date: 2021.05.12 08:25:08 -05'00'

John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects Docket Nos. 05000528 and 05000529 and 05000530 License Nos. NPF-41, NPF-51 and NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000528, 05000529 and 05000530 License Numbers: NPF-41, NPF-51 and NPF-74 Report Numbers: 05000528/2021001, 05000529/2021001 and 05000530/2021001 Enterprise Identifier: I-2021-001-0090 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: Tonopah, AZ Inspection Dates: January 1, 2021 to March 31, 2021 Inspectors: C. Peabody, Senior Resident Inspector E. Lantz, Resident Inspector N. Cuevas, Resident Inspector R. Alexander, Senior Emergency Preparedness Inspector N. Greene, Senior Health Physicist G. Hansen, Senior Emergency Preparedness Inspector A. Siwy, Senior Resident Inspector S. Hedger, Emergency Preparedness Inspector D. Reinert, Reactor Inspector B. Baca, Health Physicist D. Antonangeli, Health Physicist Approved By: John L. Dixon, Jr., Chief Reactor Projects 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, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Correctly Classify a Condition Adverse to Quality Associated with Turbine Driven Auxiliary Feed Water Pump Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.06 Systems NCV 05000528, 05000529, Margins05000530/2021001-01 Open/Closed The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, for the licensees failure to disposition a condition adverse to quality associated with safety-related cables in accordance with the licensees condition reporting procedure. This has led to repeated water intrusion into Class 1E electrical conduits, which could degrade cabling and affect the reliability of the turbine driven auxiliary feedwater (AFW) pump.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000528, 05000529, 10 CFR Part 37 71124.08 Open 05000530/2021001-02 Requirements URI

PLANT STATUS

Unit 1 operated at or near full power for the duration of the inspection period.

Unit 2 entered the inspection period at full power. Between February 22 through 25, 2021, the unit had a short-term planned down power to 40 percent for condenser leakage repairs. Shortly after returning to full power on February 26, 2021, the unit tripped due to inadvertent manipulation of generator output breaker protective relay controls by personnel performing maintenance evolutions in the Palo Verde switchyard. Unit 2 was restarted on February 28, 2021 and remained at or near full power for the remainder of the inspection period.

Unit 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 1, high pressure safety injection B, on January 21, 2021

(2) Unit 2, Class 1E 125Vdc batteries B and D during startup transformer NANX02 outage, on February 10, 2021

(3) Unit 3, essential spray pond system B during planned maintenance on diesel generator A, on March 2, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 3, main turbine operating deck and main turbine bearings, Fire Zones TB9 and TB10, on February 10, 2021

(2) Unit 1, Class 1E 4kV switchgear A, Fire Zone 5A, on March 11, 2021

(3) Unit 2, Class 1E 4kV switchgear A, Fire Zone 5A, on March 11, 2021

(4) Unit 3, high pressure safety injection pump A, Fire Zone 31A, on March 12, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, turbine driven auxiliary feedwater pump room, on January 2, 2021

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Unit 3, diesel generator B fuel vault, on March 24, 2021

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 reactor startup, on February 28, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated operator requalification simulator training activities, on March 17, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 1, safety injection system performance monitoring criteria exceeded due to safety injection tank vent valves SIA-608 and SIB-633 failing to close, on February 13, 2021

(2) Unit 2, condition monitoring and maintenance plan for radwaste level transmitter failure, on February 13, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 1, repair of main steam isolation valve B thermal relief valve manifold assembly, on February 4, 2021

(2) Unit 3, revised weekly risk assessment for extended diesel generator A outage from previous week displacing planned maintenance on high pressure safety injection pump A, on March 8, 2021

(3) Unit 3, weekly risk assessment diesel generator, spray pond, essential cooling water, and essential chilled water planned maintenance, on March 28, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1, missed valve position indication test following maintenance for containment power access purge isolation valve, on February 17, 2021

(2) Unit 1, main steam support structure door 1-CA01 locking mechanism malfunctioning, on March 11, 2021

(3) Unit 3, diesel generator B sump pump failed to start, on March 12, 2021

(4) Unit 1, 2, and 3, charging line containment isolation valve CH-560 limit switches may not provide reliable position indications during loss of cooling accident (LOCA) event submergence, on March 12, 2021

(5) Unit 2, charging pump A missed vibration data gathering during surveillance testing, on March 30, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Unit 1, inspect and adjust Class 1E 480V Circuit Breaker 1EPHBM3607, on March 25, 2021

(2) Unit 3, inspect and adjust Class 1E 480V Circuit Breaker 3EPHBM3810, on March 25, 2021

(3) Unit 3, A diesel generator post-maintenance testing on replaced air start valves, on March 31, 2021

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Unit 2 forced outage activities following reactor trip from February 26 to 28, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 3, control element assembly operability check surveillance test risk informed documented evaluation for a one-time extension of frequency from every nine months to annually under the surveillance frequency control program, on January 12, 2021

(2) Unit 1, observed engineered safety features actuation system train B relay testing (main steam isolation signal, recirculation actuation signal, containment isolation actuation signal), on March 15, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 1, observed safety injection train B emergency core cooling system throttle valve inservice testing, on March 23, 2021

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Partial)

(1) (Partial)

The inspectors evaluated the biennial emergency plan exercise which was conducted on March 9, 2021. However, as of the end of the 1st Quarter 2021, the licensee had not completed its critique process for the exercise. As such, the inspectors were unable to complete the full evaluation of the exercise and the critique process. The inspectors will complete the inspection early in the 2nd Quarter, and the results of the inspection will be documented in that report.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following recently submitted Emergency Action Level and Emergency Plan changes.

• PVNGS Emergency Plan Revisions 67 and 68 This evaluation does not constitute NRC approval.

71114.08 - Exercise Evaluation Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensee's preliminary exercise scenario which was submitted to the NRC on December 18, 2020 (ADAMS Accession No.

ML20353A421), for the exercise scheduled to occur on March 9, 2021. The inspectors discussed the preliminary scenario with Ms. C. Shields, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on February 3, 2021. The inspectors' review does not constitute NRC approval of the scenario.

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Eberline AMS 4, SN #112914, 08/05/2020

(2) Econoair Plus L-12P Personal Air Sampler, SN #1741, 12/11/2020

(3) Ludlum Model 3 Count Rate Meter, SN #231550, 07/08/2020

(4) GM Probe, SN #13478, 12/04/2020

(5) AMP-100, SM #5014035, 09/17/2020

(6) RO-20 Meter, SN #1411, 09/09/2020

(7) RO-7 Meter, SN #679, 10/24/2020

(8) Neutron Detector, SN #110762, 10/30/2020

(9) Air Sampler - Charcoal, SN #16456, 12/04/2020

(10) Small Article Monitor (SAM) 12, SN #6700, 10/28/2020

(11) Small Article Monitor (SAM) 12, SN #6710, 11/18/2020

(12) ThermoFisher Scientific Personal Contamination Monitor (PM-12), SN #12018, 09/03/2020

(13) ThermoFisher Scientific Personal Contamination Monitor (PM-12), SN #1213, 11/17/2020

(14) ThermoFisher Scientific iPCM 12, SN #112021, 11/20/2020

(15) ThermoFisher Scientific iPCM 12, SN #12019, 08/14/2020 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) RU-200, Radioactive Liquid Effluent Monitor

(2) RU-144, Plant Vent Radiation Monitor High

(3) RU-14, Radwaste Effluent Radiation Monitor

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Waste Characterization and Classification (IP Section 03.03)

The inspectors evaluated the licensees characterization and classification for the following radioactive waste streams:

(1) Unit 1 Resin Stream for 2020

(2) Unit 2 Resin Stream for 2020

(3) Unit 2 Dry Active Waste stream for 2020

Shipping Records (IP Section 03.05) (5 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) 19-RW-018, LSA - II, Dewatered Resin

(2) 19-RW-023, LSA - I, Concentrates

(3) 20-RW-012, LSA - II, Dewatered Resin

(4) 20-RW-031, LSA - II, Dewatered Resin

(5) 20-RW-034, LSA - II, Dewatered Resin

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 03.01) ===

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

(3) Unit 3, January 1, 2020 through December 31, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (3 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

(3) Unit 3, January 1, 2020 through December 31, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (3 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

(3) Unit 3, January 1, 2020 through December 31, 2020

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 03.04) (3 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

(3) Unit 3, January 1, 2020 through December 31, 2020

EP01: Drill/Exercise Performance (IP Section 03.12) (1 Sample)

(1) January 1, 2020 through December 31, 2020

EP02: ERO Drill Participation (IP Section 03.13) (1 Sample)

(1) January 1, 2020 through December 31, 2020

EP03: Alert & Notification System Reliability (IP Section 03.14) (1 Sample)

(1) January 1, 2020 through December 31, 2020

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated Unit 2 automatic reactor trip and licensees response on February 26,

INSPECTION RESULTS

Failure to Correctly Classify a Condition Adverse to Quality Associated with Turbine Driven Auxiliary Feed Water Pump Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.06 Systems NCV 05000528, 05000529, Margins05000530/2021001-01 Open/Closed The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, for the licensees failure to disposition a condition adverse to quality associated with safety-related cables in accordance with the licensees condition reporting procedure. This has led to repeated water intrusion into Class 1E electrical conduits, which could degrade cabling and affect the reliability of the turbine driven auxiliary feedwater (AFW) pump.

Description:

On August 22, 2019, indication of water intrusion was found on a junction box and two electrical conduits that penetrate down through the 100 foot train A auxiliary feed pump room. The licensee identified deposits from previous water intrusion and corrosion on the bottom of the junction box around the junction box cover. The union on conduit 1EZCAEARK63, which transitions between an unlabeled junction box and another junction box 1EZCAEAKKJ17 (J17), also had signs of water leaking out of the fittings indicating that water had entered the conduit at some point in the past. The licensee screened this issue as not a condition adverse to quality, entered it into the Performance Monitoring Program, and assigned a corrective maintenance work order to correct the condition per condition report CR 19-10684.

Per step 4.5.2 of licensee procedure, 01DP-0AP12, Condition Reporting Process, Revision 34 the screening committee classifies condition reports as either a significant condition adverse to quality, condition adverse to quality, or not a condition adverse to quality. This same procedure defines a condition adverse to quality as an all-inclusive term used in reference to failures, malfunctions, deficiencies, defective items, and non-conformances in items, activities, software and services that fall within the current licensing basis.

On January 1, 2021, the licensee observed water dripping from electrical conduit junction box J17 and after further evaluation determined that the source of water leakage was from main steam safety valves condensation overflow above which was spilling onto junction box 1EZC2EAKKJ04 (J04) at the 120 foot level. Per evaluation 21-00021-004, water flowed from junction box J04 down through the internal side of two electrical conduit penetrations into junction box J17 leaking into the AFW pump room. The main steam safety valve condensation is handled by a temporary drip catch which diverts the flow away from the junction box, however, in August 2019 and January 2021, that temporary drip catch had a clogged collection standpipe resulting in overflow onto junction box J04.

The inspectors concluded that the disposition on August 22, 2019, as not a condition adverse to quality was incorrect because safety-related power cables in this conduit provide electrical power to the turbine governor and valves associated with train A AFW pump, which is described in the current licensing basis. Therefore, continued water intrusion as observed on January 1, 2021, could degrade the electrical cabling and affect the reliability of the auxiliary feedwater system components.

The inspectors visually examined junction box J04 and it was apparent that water had been pooling on the roof of the junction box challenging the front side cover seal. Until the licensee corrects the configuration to prevent pooling on the top of the junction box, it will likely continue to leak into the cable conduit when wetted.

Corrective Actions: Per evaluation report 21-00013, junction boxes J17 and J04 will be inspected for drain holes if not already installed or inspected for drain hole-clogging if already installed.

Corrective Action References: Condition Reports 21-00013 and 21-03848

Performance Assessment:

Performance Deficiency: The licensee failed to correctly classify a condition adverse to quality in accordance with step 4.5.2 of licensee procedure, 01DP-0AP12, Condition Reporting Process. Specifically, during the screening committee review of Condition Report 19-10684, the licensee classified water intrusion into safety-related junction boxes and electrical conduits related to Class 1E electrical cabling and turbine driven AFW pump train A as a condition not adverse to quality.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the performance deficiency resulted in repeated water intrusion into junction boxes and conduits which could degrade cabling and affect the reliability of the turbine driven AFW pump.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions. finding was determined to be of very low safety significance (Green) because it

(1) was not a design deficiency,

(2) did not represent a loss of system and/or function,

(3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time,

(4) did not represent a loss of the probabilistic risk assessment (PRA) function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

(5) did not represent a loss of a PRA system and/or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

(6) did not result in the loss of a high safety-significant, nontechnical specification train.

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, when water intrusion into safety-related junction boxes and electrical conduits was found on August 22, 2019, the licensee failed to maintain safety-related equipment and incorrectly screened this issue as not a condition adverse to quality.

Enforcement:

Violation: 10 CFR 50 Appendix B, Criterion V, requires, in part, that activities affecting quality shall be accomplished in accordance with instructions, procedures or drawings. Procedure 01DP-0AP12, Condition Reporting Process, Revision 34, step 4.5.2, requires that the licensee screening committee assigns the condition report an appropriate quality classification.

Contrary to the above, on August 22, 2019, the licensee failed to accomplish an activity affecting quality in accordance with instructions, procedures, or drawings. Specifically, during condition report screening, an activity that affects quality, the licensee failed to assign the correct level of classification to junction box water intrusion, which could affect the reliability of the turbine driven AFW pump, as a condition adverse to quality, in accordance with procedure 01DP-0AP12.

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

Unresolved Item 10 CFR Part 37 Requirements URI 71124.08 (Open) URI 05000528, 05000529,05000530/2021001-02

Description:

The inspectors, while conducting a public radiation safety baseline inspection, identified numerous issues of concern regarding the implementation of 10 CFR Part 37 requirements during their review of the controls for an aggregated Category 2 quantity of radioactive material. The inspection was conducted the week of January 11, 2021, using IP 71124.08, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation. The inspectors informed the licensee of the issues of concern regarding the implementation of the 10 CFR Part 37 requirements, specifically associated with 10 CFR 37.49(a)(3)(ii), 37.51(a), and 37.51(b).

10 CFR 37.49(a)(3)(ii) requires, in part, for Category 2 quantities of radioactive material, that the licensee shall establish and maintain weekly verification through physical checks, tamper indicating devices, use, or other means to ensure that the radioactive material is present.

10 CFR 37.51 requires, in part,

(a) that the licensee shall implement a maintenance and testing program to ensure that intrusion alarms, associated communication systems, and other physical components of the systems used to secure or detect unauthorized access to radioactive material are maintained in operable condition and are capable of performing their intended function when needed; and

(b) that the licensee shall maintain records on the maintenance and testing activities for 3 years.

These issues of concern relative to the control of Category 2 radioactive material required additional information and review to determine whether the licensee performance constituted violations of NRC requirements. Consequently, we are considering this matter as an Unresolved Item (URI).

Planned Closure Actions: The inspectors plan to continue their review of documentation provided by the licensee as it is made available, as well as hold discussions to resolve these issues of concern. This review will be a comprehensive assessment of all associated violations and/or findings related to these potential issues identified. The results of the final determination of these 10 CFR Part 37 violations, if validated, will be documented in a standalone report due to the security-related aspects of the potential violations.

Licensee Actions: The licensee placed this matter into their corrective action program for review and implementation of corrective actions. The licensee used the corrective action program to document their corrective actions already taken and planned, as well as communicated them to the inspectors. Thus far, the licensee has been very responsive to the potential violations. The licensee has already addressed perceived gaps the inspectors identified in the implementation of 10 CFR Part 37 requirements.

Corrective Action References: CR-21-03309

EXIT MEETINGS AND DEBRIEFS

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

• On February 4, 2021, the inspectors presented the Radiation Safety inspection results to Mrs. Maria Lacal, Site Vice President/Chief Nuclear Officer and other members of the licensee staff.

• On March 11, 2021, the inspectors presented the EP Performance Indicator Verification and Emergency Plan Changes inspection results to Mrs. Maria Lacal, Site Vice President/Chief Nuclear Officer and other members of the licensee staff.

• On April 7, 2021, the inspectors presented the integrated inspection results to Mrs. Maria Lacal, Site Vice President/Chief Nuclear Officer and other members of the licensee staff.

• On April 22, 2021, the inspectors discussed the integrated inspection results to Mr. Matt Kura, Department Leader, Nuclear Regulatory Affairs, and other members of the licensee staff.

• On April 28, 2021, the inspectors debriefed the 10 CFR Part 37 Requirements URI with Mr. Todd Horton, Senior Vice President, Site Operations.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings 01-M-SIP-001 P& I Diagram Safety Injection & Shutdown Cooling System 062

71111.04 Drawings 01-M-SIP-002 P& I Diagram Safety Injection & Shutdown Cooling System 044

71111.04 Drawings 03-M-SPP-001 P& I Diagram Essential Spray Pond System 071

71111.04 Drawings 03-M-SPP-002 P& I Diagram Essential Spray Pond System 019

71111.05 Miscellaneous PVGS Pre-Fire Strategies Manual 29

71111.05 Miscellaneous USAR Section 9B Fire Hazards Analysis 19

71111.06 Calculations 13-MC-ZA-0807 MSSS 100 Elevation Flooding Evaluation 4

71111.06 Calculations 13-MC-ZA-0808 MSSS 81 Elevation Flooding Evaluation 7

71111.06 Corrective Action Condition Reports 21-00013, 21-00016, 21-00021, 20-03848, 20-16841, 19-

Documents 10684

71111.11Q Miscellaneous NLR21S020201 Licensed Operator Training Simulator Scenario: LOCA / 02/24/2021

Loss of Class Instrument / Rapid Downpower

71111.12 Corrective Action Condition Reports 20-15752, 20-15757, 20-15943, 20-15954, 20-16314

Documents

71111.12 Miscellaneous 20-15752-003 MRFF Evaluation

71111.12 Miscellaneous 20-15752-004 Level 3 Evaluation Report

71111.12 Miscellaneous 20-15757-003 MRFF Evaluation

71111.12 Miscellaneous 20-15757-004 Level 3 Evaluation Report

71111.12 Miscellaneous Level 3 Maintenance Rule Expert Panel Meeting 633 02/04/2021

Evaluation Report

71111.12 Miscellaneous SI-2503 Maintenance Rule (a)(1) Issue Tracking Form 0

71111.12 Procedures 70DP-0MR01 Maintenance Rule 46

71111.13 Corrective Action Condition Reports 21-00853

Documents

71111.13 Miscellaneous U1 MSIV RICT Projection Details 02/04/2021

71111.13 Miscellaneous U1 MSIV Risk Management and Readiness Plan 02/03/2021

71111.13 Miscellaneous EOOS 4.1 Weekly Schedulers Evaluation for PV Unit 3 Mar 8-14 02/17/2021,

03/8/2021

71111.13 Miscellaneous EOOS 4.1 Weekly Schedulers Evaluation for PV Unit 3 Mar 22-28 03/25/2021

71111.13 Miscellaneous Phoenix Risk WW 2112 Schedule Evaluation (3/22-28/2021) 03/23/2021

Monitor

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.13 Miscellaneous Phoenix Risk WW 2110 Schedule Evaluation (3/8-14/2021) 02/17/2021,

Monitor 03/8/2021

71111.13 Miscellaneous RICT-U1-2021-01 Risk Informed Completion Time Summary 02/04/2021

71111.13 Miscellaneous Risk Challenge Risk Challenge Meeting for U1 MSIV-171 Repair 02/03/2021

Meeting

71111.13 Procedures 02DP-0RS01 Online Integrated Risk 9

71111.13 Procedures 40DP-9RS01 Operations Department Online Nuclear Risk Determination 7

in Modes 1 and 2

71111.13 Procedures 40DP-9RS03 Risk Management Actions 1

71111.13 Work Orders 5310300

71111.15 Corrective Action Condition Reports 21-01818, 21-02855, 21-02888

Documents

71111.15 Miscellaneous Updated Final Safety Analysis Report 20B

71111.15 Miscellaneous 21-01818-002 Engineering Evaluation

71111.15 Miscellaneous EEQ-N007-001 Namco EA180 Limit Switches 23

71111.15 Procedures 40DP-9OP26 Operations Condition Reporting Process and Operability 47

71111.15 Procedures 40DP-9ZZ17 Control of Doors, Hatches, and Floor Plugs 65

71111.15 Procedures 73ST-9XI15 CP (Power Access Purge) Valves - Inservice Test 11

71111.15 Work Orders 5159840

71111.19 Procedures 32MT-9ZZ74 Molded Case Circuit Breaker Test 53

71111.19 Work Orders 5062359, 5202497

71111.22 Miscellaneous Plant Review STRIDE PRB Approval Meeting for CEA Operability Checks 01/12/2021

Board

71111.22 Procedures 01DP-0RS01 Surveillance Frequency Control Program 1

71111.22 Procedures 01DP-0RS02 Surveillance Test Risk Informed Documented Evaluation 3

(STRIDE) Process

71111.22 Procedures 70DP-0RA06 PRA Methodology for Evaluating Changes to Surveillance 2

Test Intervals

71111.22 Procedures PVN-N-0034 STRIDE for One-Time Change for DEA Operability Checks 0

71114.01 Corrective Action Condition Reports 19-03672, 19-03691, 19-05088, 19-08356, 19-13385, 19-

Documents 13930, 19-17244, 20-01446, 20-01527, 20-03432, 20-

03738, 20-04408, 20-04999, 20-14892, 20-15325, 20-

15510, 20-16537, 20-16863

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.01 Miscellaneous 102-05627 Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, 01/11/2007

and 3; Docket No. STN 50-528; 50-529; 50-530 and 72-44;

License No. NPF-41; NPF-51; NPF-74; Response Providing

Information Regarding Implementation Details for the Phase

and 3 Mitigation Strategies

71114.01 Procedures 16DP-0EP31 Emergency Preparedness Equipment Out of Service 12

71114.01 Procedures 40AO-9ZZ23 Loss of SFP Level or Cooling 31

71114.01 Procedures 40AO-9ZZ24 Deliberate Acts Against PVNGS 32

71114.01 Procedures 40MG-9ZZ05 Extensive Damage Mitigation Guidelines 0

71114.01 Procedures 40MG-9ZZ05-001 EDMG Command and Control 0

71114.01 Procedures 40MG-9ZZ05-002 Mitigating Guidelines Supplemental Strategies 0

71114.01 Procedures 40MG-9ZZ07 FLEX Support Guidelines 0

71114.01 Procedures 40MG-9ZZ07-001 FLEX Support Guidelines, Modes 1, 2, 3, or 4 0

71114.01 Procedures EP-0900 Emergency Response Organization (ERO) Position 20

Checklists

71114.01 Procedures EP-0901 Classifications 14

71114.01 Procedures EP-0905 Protective Actions 10

71114.04 Miscellaneous PVNGS Emergency Plan 67, 68

71114.04 Miscellaneous Emergency Plan Evaluation - Medical Support During a 12/17/2020

Public Health Emergency

71114.04 Miscellaneous 2020-001e Emergency Plan Revision 67 Effectiveness Evaluation Form 05/05/2020

71114.04 Miscellaneous 2020-002s Transitioning the Operations Advisor - STSC position to a 03/17/2020

pooled position Screening Evaluation Form

71114.04 Miscellaneous 2020-003e Emergency Plan Revision 68 Effectiveness Evaluation Form 12/16/2020

71114.04 Miscellaneous 2020-003e, Emergency Plan Revision 68 Effectiveness Evaluation Form 12/16/2020

Revision 1

71114.04 Miscellaneous 2020-003s Emergency Plan Revision 67 Screening Evaluation Form 05/01/2020

71114.04 Miscellaneous 2020-004s Emergency Plan Revision 68 Screening Evaluation Form 07/30/2020

71114.04 Miscellaneous 2020-005s Update to the Palo Verde Emergency Planning Zone (EPZ) 12/10/2020

population Screening Evaluation Form

71114.08 Miscellaneous 1904 ERO Mini Drill - ERO Green Team (June 4, 2019); 10/29/2019

1905 ERO Mini Drill - ERO Blue Team (June 11, 2019);

1906 ERO Mini Drill - ERO Red Team (June 18, 2019)

71114.08 Miscellaneous 1907 ERO Mini Drill - ERO Red Team (September 10, 10/23/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

2019); 1909 ERO Mini Drill - ERO Green Team (September

24, 2019)

71114.08 Miscellaneous 1910 ERO Mini Drill Report - ERO White Team (December 01/2/2020

10, 2019)

71114.08 Miscellaneous 240-02859 1901 Full-Scale Dress Rehearsal - ERO Gold Team 06/13/2019

CS/SW (February 2019)

71114.08 Procedures EP-0905 Protective Actions 10

71124.05 Calibration WO 04908361 RU-143 Plant Ventilation Monitor, Low Range - Unit 3 02/19/2019

Records

71124.05 Calibration WO 05091219 RU-143 Plant Ventilation Monitor, Low Range - Unit 3 06/25/2020

Records

71124.05 Calibration WO 4904815 RU-143 Plant Ventilation Monitor, Low Range - Unit 2 01/03/2019

Records

71124.05 Calibration WO 4906938 RU-143 Plant Ventilation Monitor, Low Range - Unit 1 01/03/2019

Records

71124.05 Calibration WO 4925134 RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit 04/27/2018

Records 3

71124.05 Calibration WO 4981791 RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit 12/12/2019

Records 3

71124.05 Calibration WO 4981791 RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit 12/12/2019

Records 3

71124.05 Calibration WO 5005338 RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit 05/01/2020

Records 2

71124.05 Calibration WO 5027206 RU-151 Radiation Monitor 10/26/2019

Records

71124.05 Calibration WO 5027531 RU-141 Radiation Monitor 11/18/2019

Records

71124.05 Calibration WO 5037715 RU-30 Radiation Monitor 11/12/2019

Records

71124.05 Calibration WO 5074919 RU-157 Radiation Monitor 02/27/2020

Records

71124.05 Calibration WO 5081319 RU-143 Plant Ventilation Monitor, Low Range - Unit 2 06/19/2020

Records

71124.05 Calibration WO 5085209 RU-143 Plant Ventilation Monitor, Low Range - Unit 1 06/22/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Records

71124.05 Calibration WO 5086713 RU-150 Radiation Monitor 04/09/2020

Records

71124.05 Calibration WO 5111166 RU-145 Fuel Building B Ventilation Exhaust Monitor, Low 07/15/2020

Records Range - Unit 3

71124.05 Calibration WO 5111180 RU-146 Fuel Building B Ventilation Exhaust Monitor, High 10/16/2020

Records Range - Unit 3

71124.05 Calibration WO 5145645 RU-15 Waste Gas Area Combined Ventilation Exhaust 09/22/2020

Records Monitor - Unit 1

71124.05 Calibration WO 5151446 RU-1 Radiation Monitor 11/07/2020

Records

71124.05 Calibration WO 5151451 RU-148 Radiation Monitor 11/12/2020

Records

71124.05 Corrective Action Condition Reports 19-00740, 19-01086, 19-02060, 19-02467,

Documents 19-02886, 19-03691, 19-05830, 19-06030,

19-06237, 19-08355, 19-08808, 19-12890,

19-13509, 19-13899, 19-16388, 19-17175,

19-17244, 19-18312, 20-00153, 20-00391,

20-00576, 20-01188, 20-02588, 20-04408,

20-04707, 20-04730, 20-07625, 20-08012,

20-08563, 20-09920, 20-12560, 20-12803,

20-13297, 20-15324, 20-15678, 20-16032

71124.05 Miscellaneous 2018 Annual Radioactive Effluent Release Report 04/16/2019

71124.05 Miscellaneous 2019 Annual Radioactive Effluent Release Report 04/17/2020

71124.05 Miscellaneous Offsite Dose Calculation Manual PVNGS Units 1, 2, and 3 29

71124.05 Miscellaneous Portal Monitors (PM) and Personal Contamination Monitors 01/05/2021

(PCM) Alarm Setpoints

71124.05 Miscellaneous Instrument Calibration Data Point Sheet 10/18/2020

71124.05 Miscellaneous Unit 1 2019-2020 Inoperable Effluent Monitor Logs 12/31/2020

71124.05 Miscellaneous Unit 2 2019-2020 Inoperable Effluent Monitor Logs 12/31/2020

71124.05 Miscellaneous Unit 3 2019-2020 Inoperable Effluent Monitor Logs 12/31/2020

71124.05 Miscellaneous Special Report 1- Palo Verde Nuclear Generating Station (PVNGS) Unit 1, 04/26/2019

SR-2019-001-00 Docket No. STN 50-528 /License No. NPF 51, Special

Report 1-SR-2019-001-00: Non-functionality of a fuel

Inspection Type Designation Description or Title Revision or

Procedure Date

building ventilation system high range radioactive gaseous

effluent monitor for more than 7 days

71124.05 Procedures 74DP-0CH02 Analytical Instrument Quality Control (QC) 47

71124.05 Procedures 74RM-9EF43 Actions For Non-Functional Radiation Monitors: Preplanned 17

Alternate Sampling Program

71124.05 Procedures 74ST-9SQ10 Train "A" Radiation Monitoring Quarterly Functional Test 5

Procedure

71124.05 Procedures 74ST-9SQ20 RU-1 Calibration Test 18

71124.05 Procedures 74ST-9SQ21 Radiation Monitoring Calibration Test for Baseline Process 21

Monitors

71124.05 Procedures 74ST-9SQ22 Train "A" Radiation Monitoring Calibration Test for Baseline 12

Area Monitors

71124.05 Procedures 74ST-9SQ23 Train "A" Radiation Monitoring Calibration Test for 21

Containment New Scope Area Monitors

71124.05 Procedures 74ST-9SQ27 Radiation Monitoring Calibration Test for RU-144 21

71124.05 Procedures 75RP-9EQ13 Canberra Whole Body Counting System Calibration 6

71124.05 Procedures 75RP-9EQ22 Calibration of Counter Scalers 6

71124.05 Procedures 75RP-9EQ56 Calibration of the RO-2 and RO-20A Ion Chambers 1

71124.05 Procedures 75RP-9ME20 Canberra APEX - In Vivo Whole Body Counting System 2

Calibration

71124.05 Self-Assessments IPA-RP2020S1 Integrated Performance Assessment Report: Radiation 09/02/2020

Protection - 1st Half 2020 (07/24/2020)

71124.05 Self-Assessments SR-20-0021 NAD Surveillance Report: 2020 Radiation Safety 07/23/2020

Performance Evaluation

71124.05 Work Orders 5010217 74ST9SQ042 Effluent Monitor Monthly Source Checks Unit 08/15/2019

2: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.05 Work Orders 5010218 74ST9SQ043 Effluent Monitor Monthly Source Checks Unit 08/15/2019

3: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.05 Work Orders 5011137 74ST9SQ041 Effluent Monitor Monthly Source Checks Unit 08/15/2019

1: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

Inspection Type Designation Description or Title Revision or

Procedure Date

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.05 Work Orders 5030412 74ST9SQ042 Effluent Monitor Monthly Source Checks Unit 10/17/2019

2: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.05 Work Orders 5030413 74ST9SQ043 Effluent Monitor Monthly Source Checks Unit 10/21/2019

3: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.05 Work Orders 5031145 74ST9SQ041 Effluent Monitor Monthly Source Checks Unit 10/17/2019

1: RU-143/RU-144 Plant Vent Gaseous Effluent Monitor and

RU-145/RU-146 Fuel Building Ventilation Gaseous Effluent

Monitor

71124.08 Corrective Action Condition Reports 19-02590, 19-07431, 19-11705, 19-18567, 20-02759, 20-

Documents 02763, 20-14858

71124.08 Miscellaneous December 2020 Radwaste Inventory 12/2/2020

71124.08 Miscellaneous Waste /Material Characteristic Summary for Part 61 Waste 12/17/2020

Stream Analysis - Unit 1 DAW - 2020

71124.08 Miscellaneous Waste /Material Characteristic Summary for Part 61 Waste 12/17/2020

Stream Analysis - Unit 1 DAW - 2020

71124.08 Miscellaneous Waste /Material Characteristic Summary for Part 61 Waste 05/12/2020

Stream Analysis - Unit 2 DAW -2020

71124.08 Miscellaneous Waste /Material Characteristic Summary for Part 61 Waste 05/14/2020

Stream Analysis - Unit 1 Resin - 2020

71124.08 Miscellaneous Waste /Material Characteristic Summary for Part 61 Waste 12/09/2020

Stream Analysis - Unit 2 Resin - 2020

71124.08 Miscellaneous 75ST-9ZZ02 Radioactive Source Leak Test Surveillance Sheet 01/26/2020

71124.08 Miscellaneous 75ST-9ZZ02 Radioactive Source Leak Test Surveillance Sheet 01/15/2019

71124.08 Procedures 20DP-0SK77 Security Miscellaneous Testing 1

71124.08 Procedures 75RP-9RP09 Control of Vehicles, Equipment and Material 45

71124.08 Procedures 75RP-9RP15 Control and Storage of Radioactive Material and Radioactive 31

Wastes

71124.08 Procedures 76DP-0AP12 Low Level Radioactive Material Storage Facility Overview 3

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.08 Procedures 76DP-0RP02 Radioactive Waste Minimization Program Overview 6

71124.08 Procedures 76DP-0RP03 Radwaste Process Control Program 9

71124.08 Procedures 76DP-0RP05 Radwaste Control and Management Activities 3

71124.08 Procedures 76RP-0RW05 Packaging and Classification of Radioactive Waste 6

71124.08 Procedures 76RP-0RW06 Packaging of Radioactive Material 5

71124.08 Procedures 76RP-0RW07 Shipping Radioactive Materials 16

71124.08 Procedures 76RP-0RW08 High Integrity Container Receipt, Handling, Use, and 4

Closure

71124.08 Shipping Records 19-RW-018 Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08 Shipping Records 19-RW-023 Shipping paperwork package for the LSA-I concentrates

shipment

71124.08 Shipping Records 20-RW-012 Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08 Shipping Records 20-RW-031 Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08 Shipping Records 20-RW-034 Shipping paperwork package for the LSA-II dewatered resin

shipment

71151 Corrective Action Condition Reports 20-01508, 20-01734, 20-07606, 20-08679

Documents

71151 Miscellaneous NRC Performance Indicator Data; Emergency Preparedness 01/01/2020 -

- Drill/Exercise Performance; 1st Quarter 2020 - 4th 12/31/2020

Quarter 2020

71151 Miscellaneous NRC Performance Indicator Data; Emergency Preparedness 01/01/2020 -

- ERO Readiness 1st Quarter 2020 - 4th Quarter 2020 12/31/2020

71151 Miscellaneous NRC Performance Indicator Data; Emergency Preparedness 01/01/2020 -

- Alert and Notification System Reliability; 1st Quarter 2020 12/31/2020

- 4th Quarter 2020

71153 Corrective Action Condition Reports 21-02209

Documents

21