IR 05000528/2020001

Integrated Inspection Report 05000528/2020001, 05000529/2020001, and 05000530/2020001

ML20133K115
Person / Time
Site:	Palo Verde
Issue date:	05/12/2020
From:	John Dixon NRC/RGN-IV/DRP/RPB-D
To:	Lacal M Arizona Public Service Co
References
IR 2020001
Preceding documents:	ML19312A131 (8 November 2019)
Download: ML20133K115 (29)

Text

May 12, 2020

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

INTEGRATED INSPECTION REPORT 05000528/2020001, 05000529/2020001, AND 05000530/2020001

Dear Mrs. Lacal:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station, Units 1, 2, and 3, and 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, Units 1, 2, and 3.

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, Units 1, 2, and 3. 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 17:04:46 -05'00'

Date: 2020.05.12 John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects Docket Nos. 05000528, 05000529, and 05000530 License Nos. NPF-41, NPF-51, NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000528, 05000529, and 05000530 License Numbers: NPF-41, NPF-51, and NPF-74 Report Numbers: 05000528/2020001, 05000529/2020001, and 05000530/2020001 Enterprise Identifier: I-2020-001-0001 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Units 1, 2, and 3 Location: 5801 S Wintersburg Road Tonopah, AZ 85354 Inspection Dates: January 1 to March 31, 2020 Inspectors: C. Peabody, Senior Resident Inspector R. Bywater, Resident Inspector D. You, Resident Inspector A. Athar, Acting Resident Inspector J. Drake, Senior Reactor Inspector S. Hedger, Emergency Preparedness Inspector D. Johnson, Senior Emergency Preparedness Specialist S. Makor, Reactor Inspector D. Reinert, Reactor Inspector W. Sifre, Senior Reactor Inspector 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,

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

List of Findings and Violations

Failure to Incorporate Vendor Recommendations into GE Magne-Blast Medium Voltage Circuit Breaker Maintenance and Overhaul Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.12 Systems NCV 05000528, 05000529, Evaluation 05000530/2020001-01 Open/Closed The inspectors identified a Green non-cited violation of Technical Specification 5.4.1.a for the licensees failure to incorporate pertinent vendor information into circuit breaker maintenance procedures, including specifications and recommendations per the stations preventive maintenance program. This has led to increased service failures of class 1E medium voltage circuit breakers.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000528,05000529, Fuel Oil transfer system 71111.20 Closed 05000530/2019002-02 LER 05000528, LER 2017-002-00 for Palo 71153 Closed 05000530/2017-002-00 Verde Nuclear Generating Station, Units 1 and 3,

Emergency Diesel Generator Inoperable Due to Fuel Oil Transfer Pump Testing.

LER 05000529/2019-001-00 LER 2019-001-00 for Palo 71153 Closed Verde Nuclear Generating Station, Unit 2, Automatic Actuation of the Reactor Protection System Resulting from a Loss of Reactor Coolant Pumps.

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. On March 3, 2020, Unit 2 tripped due to low steam generator levels following a loss of both main feedwater pumps. The unit restarted on March 7, 2020, and operated at or near full power for the remainder of the inspection period.

Unit 3 entered the inspection period at full power. On February 8, 2020, Unit 3 was forced to shut down due to excessive reactor coolant system leakage. The cause of the leakage was the reactor coolant loop 1B pump seal, which was replaced during the forced outage. Unit 3 restarted on February 16, 2020, and operated at or near full power for the remainder 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. From January 1-March 19, 2020, 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 (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 and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk-significant activities when warranted. 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 the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.

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 3 containment spray system B on January 4, 2020

(2) Unit 1 high pressure safety injection B during train A high pressure safety injection work on January 29, 2020

(3) Unit 1 diesel generator B during planned maintenance on diesel generator A on March 3, 2020

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 containment spray pump A room, Fire Zone 30A, on January 4, 2020

(2) Unit 3 essential switchgear A room, Fire Zone 5A, on January 30, 2020

(3) Unit 2 Class 1E battery rooms and DC switchgear A, Fire Zones 8A and 9A, on March 16, 2020

(4) Unit 2 essential chiller A room, Fire Zone 1, on March 24, 2020

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade performance on January 21, 2020.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1 diesel generator A jacket water cooler performance on March 4, 2020.

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 Unit 3 operators conducting a controlled shutdown and cooldown for a forced outage on February 8-9, 2020.

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

(1) The inspectors observed and evaluated a simulator scenario for the Deliberate Acts abnormal operating procedure on January 17, 2020.

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 remain capable of performing their intended function:

(1) Unit 1 high pressure safety injection pump B breaker closing spring failure on July 17, 2019

(2) Unit 3 spray pond pump B motor breaker failed to close on December 29, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 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 risk assessment for work on recirculation actuation sump isolation valve SIB676 on January 16, 2020

(2) Unit 3 risk assessment for replacement of reactor coolant pump seal 1B with fuel in the reactor vessel and controlled leakage past the stop seal on February 12, 2020

(3) Unit 3 shutdown risk assessment of protected equipment during a forced outage on February 13, 2020

(4) Unit 1 risk assessment for diesel generator A super outage on March 3, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 3 turbine drive auxiliary feedwater indications of a steam leak on the steam bypass line on January 31, 2020

(2) Unit 3 elevated pressurizer safety valve tailpipe temperatures following the forced outage on March 5, 2020

(3) Unit 3 diesel generator A rendered inoperable during common cause testing on March 19, 2020

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for Title 10 of the Code of Federal Regulations (CFR) 50.59 from February 3-7, 2020:

(1) Screening S-16-0014, Upgrade the Containment Polar Cranes to Single Failure Proof in Each of the Units, Revision 6

(2) Screening S-16-0029, Combustion Engineering 16x16 Next Generation Fuel, Revision 0

(3) Screening S-16-0036, Spray Pond Margin Recovery Modification, Revision 3

(4) Screening S-17-0023, Add Torque Values, Gap Settings, and Lubrication Requirements for the Station Blackout Generator Igniter Plug, Revision 0

(5) Screening S-17-0025, Engineering Evaluation 4813085 Fire Retardancy Testing Requirements, Revision 0

(6) Screening S-17-0034, Calculation 13-NC-ZY-0297 to Determine Offsite Doses for a Main Steam Line Break Inside Containment, Revision 0

(7) Screening S-17-0035, Addition of Drain Line with Isolation Valve to Containment Spray Auxiliary Headers, Revision 0

(8) Screening S-17-0036, TMOD 16-20383-03, Install Bypass Cable Between Junction Box 1EZYT2NKFJ20 and Breaker 1ENGNL20D2, Revision 0

(9) Screening S-17-0040, Alternate Technique for Adjusting the Nitrogen Pre-charge Pressure in a Charging Pump Pulsation Dampener, Revision 0

(10) Screening S-17-0045, DEC-01057, Software Update to Plant Computer and Core Monitoring Computer, Revision 0

(11) Screening S-17-0053, DMWO 4438815, Installation of a Pipe Extension to Lower the Suction Point of the Spent Fuel Pool Cooling Suction Line, Revision 0

(12) Screening S-17-0073, T-Mod 17-09932-003, Restoration of Alarm Function for CEDMCS Timer Card Trouble, Revision 0

(13) Screening S-17-0096, Procedure Change to Allow Operation of the Containment Purge Supply and Exhaust Fans Concurrently with the Containment Equipment Hatch Open, Revision 0

(14) Screening S-17-0098, Design Equivalent Change 17-14902-003 to Accept the Anomaly on the Flow Baffle Skirt Attachment Weld, Revision 0

(15) Screening S-18-0041, Valve Lineup to Reduce Differential Pressure Across Feedwater Isolation Valves SGBUV132 and SGBUV137, Revision 0

(16) Screening S-18-0042, Minor Change on the Plant Computer System, Revision 0

(17) Screening S-18-0056, Replace Existing Electro-Mechanical Under-Frequency and Under-Voltage within a Single Multi-function Generator Protection Relay, Revision 0

(18) Screening S-18-0061, DMWO 5035279 Modifies the Auxiliary Feedwater Motor Operated Gate Valves such that the Valves are no Longer Susceptible to Pressure Locking, Revision 1

(19) Screening S-18-0062, DMWO 4743537 Modifies the Safety Injection Motor Operated Gate Valves and Associated Piping such that the Valves are no Longer Susceptible to Pressure Locking, Revision 1

(20) Screening S-18-0069, Leave Valve PCNV118 Open During Fuel Movement Inside Containment, Revision 0

(21) Screening S-18-0070, Engineering Design Change Evaluation 18-07456-007, Spray Pond Pump Operation and Maintenance Manual, February 20, 2019

(22) Screening S-19-0015, Standard Item Equivalency Process, Revision 0

(23) Screening S-19-0017, Essential Cooling Water System Train A Flow Balance After Cross Tie to Provide Fuel Pool Cooling Backup, April 8, 2019

(24) Screening S-19-0022, TMOD 19-03044-009, Install Heated Blankets at the MSIV Actuators, Revision 0

(25) Screening S-19-0025, Essential Spray Pond Pumps - Acceptable Packing Leak Range, Revision 3

(26) Screening S-19-0033, Alternate Split Bus Configuration at Reactor Power Levels Greater than 20 Percent, Revision 1

(27) Screening S-19-0044, Calculation of a Second Value for Reactor Coolant Pump Speed Cross Channel Deviation Alarm Setpoint, Revision 0

(28) Evaluation E-16-0005, Installation of Permanent Neutron Absorber Inserts in the Spent Fuel Pool, Revision 2

(29) Evaluation E-17-0001, Revision of the PVNGS [Palo Verde Nuclear Generating Station] Inservice Inspection Program to implement the EPRI Risk Informed Inspection Methods to the Break Exclusion Region, Revision 6

(30) Evaluation, E-17-0002, Calculation 13-NC-ZY-0251 Addresses Changes to Radiological Consequences Resulting from the Westinghouse Next Generation Fuel Modification, Revision 0

(31) Evaluation E-17-0003, Update the Essential Spray Pond System Tornado Missile Probabilistic Risk Assessment, Revision 0

(32) Evaluation E-17-0004, TMOD 17-07348-002, Alignment of Portable Demineralizers, Revision 1

(33) Evaluation 17-0006, Compensatory Actions for Unit 2 Safety Injection Tank Fill and Drain Header, Revision 0

(34) Evaluation 18-0001, Open Phase Protection System (OPPS) Monitoring and Detection System, Revision 0

71111.18 - Plant Modifications

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

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2 main feedwater lube oil control panel protective relay system

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

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

(1) 36ST-9SB52, Unit 2 reactor trip switch B gear shunt and undervoltage trip functional test following breaker swap out on January 14, 2020

(2) 40OP-9RC03, Unit 3 reactor coolant pump 1B normal operating pressure and temperature leak check on February 15, 2020

(3) 40OP-9EW01, Unit 1 essential cooling water system A test procedure following maintenance during the Unit 1 diesel generator A super outage on March 3, 2020

(4) 40OP-9EC01, Unit 1 essential chilled water A test procedure following maintenance on the refrigerant head pressure control valve during the Unit 1 diesel generator A super outage on March 3, 2020

(5) 32MT-9ZZ21, Unit 2 essential cooling water pump B motor Meggar, PI, and Doble testing on March 16, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated a Unit 3 forced outage for replacement of a leaking reactor coolant pump seal from February 9-16, 2020.

(2) The inspectors evaluated a Unit 2 forced outage due to a reactor trip caused by a loss of main feedwater from March 3-7, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Station blackout generator 2 monthly test on January 24, 2020

(2) Unit 1 control element assemblies operability testing on March 13, 2020

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Unit 3 reactor coolant system elevated leak rates observed on February 7, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX reactor water tank transfer pump test on March 17, 2020

71114.02 - Alert and Notification System Testing

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

(1) The inspectors evaluated the maintenance and testing of the alert and notification system between February 1, 2018, and February 28, 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between February 1, 2018, and February 28, 2020. Inspectors also evaluated the licensees ability to staff their emergency response facilities in accordance with emergency plan commitments.

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between February 1, 2018, and February 28, 2020. The evaluation reviewed screenings and evaluations documenting implementation of the process. In addition, the inspectors evaluated emergency plan revisions 65 and 66 submitted to the NRC on December 12, 2019, and January 10, 2020, respectively. The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

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

(1) The inspectors evaluated the maintenance of the emergency preparedness program between February 1, 2018, and February 28, 2020. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors evaluated an emergency planning drill involving a seismic event which damaged plant equipment on March 10,

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) ===

(1) Unit 1 (January 1, 2019, to December 31, 2019)

(2) Unit 2 (January 1, 2019, to December 31, 2019)

(3) Unit 3 (January 1, 2019, to December 31, 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(3 Samples)

(1) Unit 1 (January 1, 2019, to December 31, 2019)

(2) Unit 2 (January 1, 2019, to December 31, 2019)

(3) Unit 3 (January 1, 2019, to December 31, 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (3 Samples)

(1) Unit 1 (January 1, 2019, to December 31, 2019)

(2) Unit 2 (January 1, 2019, to December 31, 2019)

(3) Unit 3 (January 1, 2019, to December 31, 2019)

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (3 Samples)

(1) Unit 1 (January 1, 2019, to December 31, 2019)

(2) Unit 2 (January 1, 2019, to December 31, 2019)

(3) Unit 3 (January 1, 2019, to December 31, 2019)

EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)

(1) (January 1, 2019, to December 31, 2019)

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) (January 1, 2019, to December 31, 2019)

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) (January 1, 2019, to December 31, 2019)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Elevated seal bleed off flow from reactor coolant pump 1B following the fall 2019 refueling outage. This issue continued to degrade and culminated in a Unit 3 forced maintenance outage to replace the seal package on February 9-16, 2020.

(2) Multiple issues encountered with the rod control system while trying to startup following the Unit 2 forced outage on March 4, 2020.

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

(1) The inspectors evaluated a Unit 2 reactor trip following loss of both main feedwater pumps and the licensees response on March 3, 2020.

Event Report (IP Section 03.02) (2 Samples)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000528, 05000530/2017-002-00, Emergency diesel generator INOPERABLE due to fuel oil transfer pump testing on November 13, 2017

(2) LER 05000529/2019-001-00, Automatic Actuation of the Reactor Protection System Resulting from a Loss of Reactor Coolant Pumps on August 16,

INSPECTION RESULTS

Failure to Incorporate Vendor Recommendations into GE Magne-Blast Medium Voltage Circuit Breaker Maintenance and Overhaul Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71111.12 Systems NCV 05000528, 05000529, Evaluation 05000530/2020001-01 Open/Closed The inspectors identified a Green non-cited violation of Technical Specification 5.4.1.a for the licensees failure to incorporate pertinent vendor information into circuit breaker maintenance procedures including specifications and recommendations per the stations preventive maintenance program. This has led to increased service failures of class 1E medium voltage circuit breakers.

Description:

On September 19, 2017, the Unit 2 spray pond pump B 4kV breaker failed to properly recharge during a planned chemistry run. The direct cause was found to be a broken drive pawl assembly and the root cause was determined to be the failure to incorporate vendor guidance and operating experience found in General Electric (GE)

Service Advisory Letter (SAL) 352.1. This event is detailed in NRC Inspection Report 05000528, 05000529, 05000530/2018001 as NCV 05000529/2018001-001 (ADAMS Accession No. ML18030A678). However, the station has continued to experience failures of GE Magne-Blast Class 1E medium voltage circuit breakers that have been caused by a failure to incorporate vendor guidance into the in-house breaker maintenance and overhaul program. In particular, the licensee experienced two failures related to a relay closing switch contact issue described in GE SAL 361.1: Unit 3 spray pond pump breaker A failed in November 2018 and Unit 2 high pressure safety injection pump breaker B failed in July 2019.

On December 29, 2019, the Unit 3 spray pond pump breaker B failed to close for unknown reasons. The breaker was swapped out successfully with a spare and the failed breaker was further tested by the licensee and GE. The vendors report on the breaker failure, dated February 25, 2020, noted that the licensee had not implemented four SAL 352.1 recommendations. The report also noted three unsatisfactory component alignment tolerances and seven instances of unsatisfactory original equipment manufacturer (OEM)clearances as well as excessive play in the bushings and interference wear on the interlock switch striker. This information is consistent with inspector discussions with maintenance personnel stating they were unsure of whether the stations in-house refurbishment acceptance criteria for breaker internal tolerances and clearances were consistent with proprietary OEM guidance for refurbishment. In this instance, the breaker met the licensees in-house acceptance criteria, but not those at the vendor facility for many of the same measurements. The licensees corrective action program concluded that some combination of unsatisfactory clearances, alignment tolerances, and bushing play were responsible for the trip-free condition that failed to close the breaker on December 29, 2019.

The licensee performed a root cause evaluation for the September 2017 breaker failure event (17-13171-005). Revision 1 of the root cause evaluation was issued on December 21, 2017, and it reduced the scope of the extent-of-condition action substantively. The vendor guidance review was limited to the date range of 1993-1999 and only required a random sample rather than a complete review. This was a missed opportunity to identify the SAL 361.1 issue which led to two subsequent breaker failures.

The inspectors also reviewed licensee actions to implement GE SAL 352.1 and questioned why some SAL 352.1 recommendations were still unmet. The licensee had considered all the recommendations separately under Condition Report Low Level Evaluation CR-17-13901-001. For Recommendation 3, to replace cast iron bushings with bronze, the licensee opted not to make a status determination as to whether the recommendation had been implemented; however, the document implied that it had. That conclusion had been based on the fact that maintenance personnel familiar with the overhaul evolutions could not recall encountering cast iron bushings during recent maintenance activities. However, this conclusion was incorrect. In fact, most of the bushings encountered were cast iron, not bronze. Therefore, the vendor recommendation was not implemented.

Recommendation 9, to replace the prop spring, was also incorrectly assumed to have been implemented at the station. It referenced GE SAL 348.1 and NRC Information Notice 90-41, which pertain to the affected prop spring design. The station had the replacement parts on hand, but opted to wait until 1,500 cycles to replace the component per station procedures.

For unknown reasons, the last time the Unit 3 spray pond pump B breaker was maintained (between overhauls) in March 2017, maintenance workers ignored this step in the procedure, the counter indicated 1,816 cycles, and the prop spring was re-used and not replaced; this was captured in Condition Report CR-20-03639. Considering Recommendation 9 was a Priority 1 (next immediate maintenance opportunity) recommendation, the licensees option to defer it does not meet vendor recommendations.

Based on the review of the evaluations and actions described above, the inspectors concluded that the licensee was not properly considering vendor recommendations and alignment specifications when developing their preventive maintenance program for Class 1E medium voltage circuit breakers.

Corrective Actions: The licensees corrective actions included: First, ensure that internal tolerances and clearances needed to refurbish Class 1E circuit breakers to their original condition are understood. The in-house refurbishment program should meet or exceed the OEM vendor refurbishment requirements. Second, ensure that all relevant vendor information and operating experience is properly reviewed and incorporated into the appropriate maintenance and overhaul procedures.

Corrective Action Program Reference: Condition Report CR-19-18776

Performance Assessment:

Performance Deficiency: The licensee failed to implement vendor recommendations or specifications when setting preventive maintenance guidelines in accordance with procedure 30DP-9MP08, Preventive Maintenance Program, Revision 29, step A.2.2.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in three subsequent failures of safety related breakers: Unit 3 spray pond pump breaker A failed in November 2018, Unit 2 high pressure safety injection pump breaker B failed in July 2019, and Unit 3 spray pond pump breaker B failed in December 2019.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The 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: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. The extent of cause actions for Root Cause Evaluation 17-13171-005 were not satisfactory to address the issue prior to additional breaker service failures. This issue is considered indicative of current performance due to the continuing sequence of breaker failures between September 2017 and December 2019 that were due in part to failure to implement vendor guidance.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, requires, in part, that the licensee implement procedures recommended by Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33, Appendix A, Section 9.b, recommends procedures for scheduling preventive maintenance of components that have a specified lifetime. The licensee satisfies these requirements, in part, through Procedure 30DP-9MP08, Preventive Maintenance Program, Revision 29. Procedure 30DP-9MP08, step A.2.2, requires the licensee to consider vendor recommendations or specifications when setting preventive maintenance guidelines.

Contrary to the above, from September 2017 to March 2020, the licensee failed to consider vendor recommendations or specifications when setting preventive maintenance guidelines. Specifically, the licensee was aware of vendor recommendations and missing specifications necessary to maintain the effectiveness of their periodic Class 1E medium voltage circuit breaker refurbishment program, and the licensee did not properly take action to obtain the missing alignment specifications or implement the vendors recommendations before subsequent preventable breaker failures occurred.

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

Minor Violation 71111.15 Minor Violation: During a review of LER 05000528, 05000530/2017-002-00, Emergency diesel generator INOPERABLE due to fuel oil transfer pump testing, the inspectors identified a minor violation of 10 CFR Part 50, Appendix B, Criterion V for the licensees failure to maintain an adequate diesel generator fuel oil transfer pump testing procedure.

Screening: The inspectors determined the performance deficiency was minor. An inadequate procedure caused the Unit 3 diesel generator A to be inoperable when the day tank level gauge, not seismically qualified, was valved in as part of a common cause test when the opposite train diesel generator was declared inoperable due to a failed surveillance. However, it was determined that diesel generator A would have been able to perform its safety function since at the time no seismic event occurred. Also, an auxiliary operator was standing by to quickly isolate the level gauge if necessary. This closes out LER 05000528, 05000530/2017-002-00.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee has taken action to restore compliance.

Unresolved Item Fuel Oil transfer system 71111.20 (Closed) URI 05000528, 05000529,05000530/2019002-02

Description:

The inspectors observed excavation efforts for repairs to leaking domestic water piping. During the excavation, three pipes were uncovered. The workers had only expected two pipes to be in the location. Review of site drawings identified the third line as nonsafety-related piping comprising a portion of the fuel oil transfer system connected to all three units. This piping was also connected to the bulk fuel oil tanks and associated loads in the water treatment facility. The inspectors questioned whether this was acceptable per the licensing basis and had the following questions regarding the fuel oil system for the diesel generators:

a. The inspectors requested the licensee demonstrate that the alternative method of testing the buried portions of the fuel oil transfer system provided results that were equivalent or superior to the method specified in Section XI of the ASME Code.

b. The inspectors had questions as to whether the use of isolation valves DFBV069, DFBV021, and DFAV015 was an adequate alternative to the requirement in ANSI N195-1976, Fuel-Oil Systems For Standby Diesel Generators, Section 5.3, Multiple Reactor Unit Nuclear Stations.

The inspectors reviewed various documents pertaining to the fuel oil system.

Company Correspondence ID 450-00575, dated June 18, 2018, indicates that the licensee shifted to an alternative pressure test for the buried portions of the diesel fuel oil transfer system. The licensee cited American Society of Mechanical Engineers (ASME) Code,Section XI, paragraph IWA-2240, for the proposed ultrasonic examination to determine the fuel level in the fill line. ASME,Section XI, IWA-2240, ALTERNATIVE EXAMINATIONS, states, Alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods specified in this Division, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method. In addition to changing the methodology of the pressure test, the licensee also changed the pressure at which the test was performed. ASME Code IWD-5221, Pressure, states, The system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability (e.g., to demonstrate system safety function or satisfy technical specification surveillance requirements). The inspectors noted that the licensee was also performing a flow verification test, which meets the requirements of the system pressure test for buried piping as allowed in ASME Code Edition 2013.

After reviewing the safety evaluation report, related to the operation of Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Docket Nos. STN 50-528, STN 50-529, and STN 50-530, dated November 1981, the inspectors determined that the use of redundant locked valves had been an approved exception for the separation of the fuel oil systems for the three units.

The NRC inspectors did not identify any findings or violations of more than minor significance.

This unresolved item is closed.

Corrective Action Reference(s): 19-05734, 19-05914

EXIT MEETINGS AND DEBRIEFS

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

• On February 7, 2020, the inspectors presented the Inspection Procedure 71111.17T, Evaluation of Changes, Tests, and Experiments, inspection results to Mr. M. McLaughlin, Vice President, Operations Support, and other members of the licensee staff.

• On March 5, 2020, the inspectors presented the Emergency Preparedness Program Inspection Exit Meeting inspection results to Mr. J. Cadogan, Senior Vice President for Site Operations, and other members of the licensee staff.

• On April 2, 2020, the inspectors presented the Emergency Preparedness Program Inspection Re-exit Meeting (with Residents' Quarterly Exit) inspection results to Mrs. M. Lacal, Executive Vice President/Chief Nuclear Officer, and other members of the licensee staff.

• On April 14, 2020, the inspectors presented the Fuel Oil Transfer System inspection results to Mr. B. Rash, Vice President, Engineering, and other members of the licensee staff.

• On May 1, 2020, the inspectors presented the integrated inspection results to Mr. J. Cadogan, Senior Vice President for Site Operations, and other members of the licensee staff.

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 59

01-M-SIP-002 P&I Diagram: Safety Injection & Shutdown Cooling System 41

Procedures 40ST-9SI07 High Pressure Safety Injection System Alignment 21

Verification

40ST-9SI14 Train B LPSI and CS System Alignment Verification 2

71111.05 Corrective Action Condition Reports 20-00124, 20-02409, 20-01325

Documents

Miscellaneous PVGS Pre-Fire Strategies Manual 28

NPL36-D-003B- Unit 2 Fire Drill Package 02/21/2020

71111.07A Corrective Action Condition Reports 20-02904

Documents

Miscellaneous 20-0161 Eddy Current Examination Report: U1 DG A Jacket Water 03/05/2020

Cooler

Work Orders 5074226

71111.11Q Miscellaneous Standard Maneuver Plan: 75 EFPD 100 to 19%, Unit 3 0

Cycle 22

Procedures 40OP-9ZZ05 Power Operations 150

40OP-9ZZ24 Short Notice Outage 54

71111.12 Corrective Action Condition Reports 19-10419, 18-17577

Documents

Miscellaneous Corrective maintenance work mechs from L2 Eval 19-10419- 12/17/2019

007

GE Energy - Philadelphia, PA: SAL 361.1 01/17/2007

Procedures 32MT-9ZZ34 Maintenance of AM-4.16-250-9H GE Magne-Blast Circuit 38

Breakers

71111.13 Corrective Action Condition Reports 20-02023

Documents

Miscellaneous Unit 1 Operator Logs 03/02/2020

Schedulers Evaluation for PV Unit 1 03/02/2020

Schedulers Evaluation for PV Unit 1 01/14/2020

Procedures 02DP-0RS01 Online Integrated Risk 8

Inspection Type Designation Description or Title Revision or

Procedure Date

40DP-9AP21, Protected Equipment Scheme 02/11/2020

Appendix B

40DP-9RS03 Online Integrated Risk 0

75RP-0RP02 Radiological Survey Schedule 11

Work Orders 4699034

71111.15 Corrective Action Condition Reports 19-10645, 20-01384, 20-01242, 19-04741, 19-18663, 16-

Documents 03732

Drawings 40OP-9DF01 Diesel Fuel Oil Storage and Transfer (DF) 43

40OP-9DG01 Emergency Diesel Generator A 79

NDE Reports Palo Verde Unit 3 Control Room Logs 02/20/2019

Procedures 01DP-0AP22-02 Procedure Writers Guide - Operations Supplement 1

40OP-9AF01 Essential Auxiliary Feedwater System 68

40OP-9DF01 Diesel Fuel Oil Storage and Transfer (DF) 44

71111.17T Calculations 13-MC-SP-0306 Hydraulic Analysis of SP System 6

13-MC-SP-0307 SP/RW System Thermal Performance Design Basis 9

Analysis

13-MC-SP-0307, Replacement Steam Generator and Power Uprate 9

Appendix N Evaluation

13-MC-SP-307, Spray Pond Sludge Evaluation 9

Appendix NI

13-NC-SP-201 Spray Pond Tornado Missile Damage Frequency 3

Corrective Action Condition Reports 18-18141, 19-13292, 19-14008, 19-17423, 19-14008, 15-

Documents 05143, 19-00126, 19-07570, 17-01659, 16-14042, 16-20383

Drawings 01-M-SGP-001 Main Steam System 71

13-E-MAA-001 Main Single Line Diagram 31

13-P-ZZG-0012 Piping Material Classification 52

Miscellaneous 1006937 Extension of the EPRI Risk-Informed Inservice Inspection 0-A

(RI-ISI) Methodology to Break Exclusion Region (BER)

Programs

13-CN-0380 Installation Specification for Seismic Cat IX and Non-Seismic 24

Scaffolding

13-N-001-1900- Spent Fuel Pool Criticality Analysis for 900 ppm Boron 3

21-1 Credit

Inspection Type Designation Description or Title Revision or

Procedure Date

13-NS-A106 Probabilistic Risk Assessment of Tornado Missile Damage 0

to the Station Ultimate Heat Sink

13-NS-A106 Probabilistic Risk Assessment of Tornado Missile Damage 0

to the Station Ultimate Heat Sink

13-NS-A29 Tornado Generated Missile Criteria 12/02/2009

13-NS-C067 Risk-Informed Inservice Inspection Consequence Evaluation 2

of Class 1 & 2 Piping for Palo Verde Nuclear Generating

Station Units 1,2, and 3.

13-NS-C068 Risk-Informed In-Service Inspection Break Exclusion Region 2

(BER) Consequence Evaluation

13-NS-C069 Risk-Informed In-Service Inspection Break Exclusion Region 2

(BER) Weld Selection Impact Assessment

13-NS-I08 Probabilistic Risk Assessment of Tornado Missile Damage 03/10/2009

to the Station Ultimate Heat Sink

15-F029 Change to UFSAR Section 8.2.2 updates the UFSAR to 04/30/2019

reflect Open Phase Condition (OPC) detection system

modification

16-15545-023 Engineering Evaluation - For the Unit 3 Train B Emergency 2

Diesel Generator failure, calculate the maximum allowed

outage time for the Emergency Technical Specification

Change Request and provide PRA input required for

submission of the Emergency Technical Specification

Change Request.

17-07348-002 Temporary Modification - CST External Filtration and 1

Demineralizer Skid System Operation

17-09932-003 Acknowledge and clear Unit 3 CEA 74 Timer Failure Alarm 0

to restore all other Unit 3 CEDMCS alarms

17-14902-003 Design Change Package - Anomaly Near the Toe of the 0

Flow Baffle Pad to Reactor Vessel Cladding Weld

19-03044-009 Temporary Modification - Main Steam Isolation Valve Oil 0

Temperature Heating

19-10797-001 Item Equivalency Evaluation of ASCO/Solenoid Valve/Model 0

HT8211D14-Replaced by ASCO/Solenoid Valve/Model

EFHT8210G014 120/60 VAC

Inspection Type Designation Description or Title Revision or

Procedure Date

19-13198-001 Material Replacement Evaluation for the Spring in Lonergan 0

DB-10M Safety Relief Valve from Carbon Steel to

Chromium-Vanadium Alloy Steel for the Auxiliary Steam

System

19-14294-002 Item Equivalency Evaluation of Siemens Motor Model 1080 0

2664 09 - Replaced by Siemens Motor Model 1630 0560 71

19-15820-001 Evaluate 6" 630 Century valve in lieu of original 6" model 0

465 Hills-McCanna valve.

2018-00934 Engineering Document Change - 18-07456-007 - Spray 3

Pond Pump Operation and Maintenance Manual

73ST-9SG01 MSIVs - Inservice Test 46

AF-1701 Design Equivalent Change Package - MOV Pressure 0

(5035279) Locking Modification for Auxiliary Feed Valves

1,2,3JAFCUV0036, 1,2,3JAFAUV0037 and

1,2,3JSGAUV0138

DEC-00847 Change vibration set points for the Unit 1 Feedwater Pump 0

Turbine low pressure shaft

DEC-01057 Plant Monitoring System (PMS) Printer Driver and Firmware 1

Upgrade

DEC-17-16810- Plant Computer (PC) database and software changes 0

001

EDC 2018-00934 Spray Pond Pump Operation and Maintenance Manual 02/20/2019

EDC-2016-00860 Update the Station Blackout Generator Technical Manual, 8

VTD-S903-0003, to provide torque values, gap setting, and

lubrication requirement for the igniter plug.

EDC-2017-00527 SDOCs for Spent Fuel Pool Inserting Testing 08/03/2017

EER 87-RJ-035 PMS does not alarm subgroup deviation for part length 12/17/1987

groups P1 and P2

ENG 19-02656- Review of the Standard Item Equivalency Process 08/25/2019

003

ENG TM0D 17- Develop a TMOD to install a GE Skid to filter the Unit 3 CST 06/05/2017

07348

ENG-DM Engineering Disposition - Polar Crane Upgrade Modification 3

282819

Inspection Type Designation Description or Title Revision or

Procedure Date

ENG-DM Design Modification: Spray Pond Bypass Line / Margin 9

3304346 Recovery Modification

EO-18-EG-01 Standard Item Equivalency Process 0

MB1344 Safety Evaluation of Topical Report TR-1006937, "Extension 06/27/2002

of the EPRI Risk Informed ISI Methodology to Break

Exclusion Region Programs"

MN591-A00001 Degradation Mechanism Evaluation for Class 1, Class 2 and 0

BER Program

Piping Welds for Palo Verde Units 1, 2 and 3

N-0001-0507- SNAP-IN Installation Tool (Palo Verde) 0

00070

N-001-05057- Palo Verde Test Insert with End Curls 0

00069

N0001-0507- NETCO Inserts Dimensional Sizing Procedure 1

00067

N001-0507-00071 SNAP-IN Removal Tool Assembly (Palo Verde) 0

SABD-6.05 CEAPDS and PMS CPC/CEAC Deviation Alarm Setpoints 1

SI-1682 Design Equivalent Change Package - MOV Pressure 0

(4743537) Locking Modification for Safety Injection Valves

1,2,3JSIBUV0671 and 1,2,3JSIAHV0686

VTD-B265-0001 Instructions for Bingham - Willamette Multi-Stage Vertical 08/28/1991

Pumps, Wet Pit Type VCM & VTM

VTD-S903-00003 Solar Turbines Installation and Maintenance Instructions for 8

Centaur Taurus Gas Turbine-Driven Generator Set

Procedures 40OP-9CP01 Containment Purge System 28

40OP-9ZZ04 Plant Startup Mode 2 to Mode 1 77

40OP-9ZZ23 Outage GOP 81

73DP-9XI03 ASME Section XI Inservice Inspection 20

73ST-9SP01 Essential Spray Pond Pumps - Inservice Test 55

80DP-0CC01 Control of Software and Data for Digital Process Control and 22

Monitoring Systems (PCMS)

81DP-0DC17 Temporary Configuration Changes 43

81DP-0EE10 Design Change Process 48

87DP-0MC06 Item Equivalency Evaluation (IEE) 33

Inspection Type Designation Description or Title Revision or

Procedure Date

93DP-0LC07 10 CFR 50.59 and 72.48 Screenings and Evaluations 28

93DP-0LC07-01 10 CFR 50.59 and 72.48 Administrative Guideline 5

IP-ENG-001 Standard Design Process 0

Work Orders 4894744, 4894745, 3148202, 4438816, 4618004, 4438815,

4991847, 5192259, 4813085, 4655939, 5101219, 4876832

71111.19 Corrective Action Condition Reports 19-18235

Documents Condition Reports 19-18235

Procedures 32MT-9ZZ21 4.16kV Motor Operational Testing 7

36ST-9SB44 RPS Matrix Relays to Reactor Trip Response Time Test 25

36ST-9SB52 RTSG Shunt and Undervoltage Trip Functional Test 12

40OP-9EC01 Essential Chilled Water Train A 31

40OP-9EW01 Essential Cooling Water System (EW) Train A 32

Work Orders 5081066

5074182, 5019142, 5019098

71111.20 Calculations 13-MC-DF-0306 As Built Calculation for Sizing the Diesel Fuel Storage and 11

Day Tanks

Drawings 01-M-DFP-001 P & I Diagram Diesel Fuel Oil and Transfer System 13

01-M-DGP-0001 P & I Diagram Diesel Generator System 63

AO-W-FSP-0300 Water Reclamination Facility Fuel Oil System P&ID 20

Miscellaneous AC POWER DIST IDR-# 1 Excerpt Diesel Fuel Oil Transfer 07/09/1980

System

High Impact Team Charter for RCP 3-1B Seal Degradation

Update Final Safety Analysis Report 20

ANSI N195-1976 Fuel-Oil Systems For Standby Diesel Generators 04/12/1976

ASME Code American Society Of Mechanical Engineers Code, Section

Section XI XI, Edition 2007 and 2013

PVNGS SER Safety Evaluation Report - related to the operation of Palo 11/01/1981

NUREG-0857 Verde Nuclear Generating Station: Units 1, 2, and 3, Docket

Nos. STN 50-528, STN 50-529, and STN 50-530

PVNGS SER Safety Evaluation Report related to the Operation of Palo November

NUREG-0857 Verde Nuclear Generating Station: Units 1, 2, and 3, Docket 1981

Nos. STN 50-528, STN 50-529, and STN 50-530

Arizona Public Service Company, et al.

Inspection Type Designation Description or Title Revision or

Procedure Date

Regulatory Guide Fuel-Oil Systems For Standby Diesel Generators 1

1.137

71111.22 Procedures 14MT-9BD31 FLEX RWT Transfer Pump Inspections and Tests 5

40ST-9GT03 Station Blackout Generator 2 Monthly Test 6

Work Orders 5062342, 5146842

71114.02 Miscellaneous Palo Verde Nuclear Generating Station, Alert and 5

Notification System (ANS) FEMA 350 Report, July 2019

71114.03 Miscellaneous 240-02821 CS/ma 2018 1st Quarter - Emergency Preparedness Augmentation 01/31/2018

Drill Report

240-02827 May 2018 ERO Augmentation Drill Report 06/05/2018

240-02832 2018 3rd Quarter - Emergency Preparedness Augmentation 08/23/2018

Drill Report

240-02843 2018 4th Quarter - Emergency Preparedness Augmentation 01/15/2019

Drill Report

Procedures EP-902 Notifications 15

71114.04 Miscellaneous PVNGS Emergency Plan 59-66

2-08023-CS/LH Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, 12/12/2019

and 3 and Independent Spent Fuel Installation; Docket Nos.

50-528, 50-529, 50-530, and 72-44; License Nos. NPF-41,

NPF-51, and NPF-74; PVNGS Emergency Plan, Revision 65

2-08042-CS/LH Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, 01/10/2020

and 3 and Independent Spent Fuel Installation; Docket Nos.

50-528, 50-529, 50-530, and 72-44; License Nos. NPF-41,

NPF-51, and NPF-74; PVNGS Emergency Plan, Revision 66

Evaluation Revision 61 to the PVNGS Emergency Plan 05/18/2018

Tracking Number

2018-001E

Evaluation Revision 62 Palo Verde Nuclear Generating Station 08/29/2018

Tracking Number Emergency Plan

2018-002E

Evaluation Revision 64 to the PVNGS Emergency Plan 06/21/2019

Tracking Number

2019-001e

Evaluation Numerous Changes/Corrections to the PVNGS Emergency 08/07/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Tracking Number Plan Revision 64

2019-002e

Evaluation Emergency Plan Revision 65 11/21/2019

Tracking Number

2019-003e

Evaluation Emergency Plan Revision 66 12/12/2019

Tracking Number

2019-004e

Screening Change in Notification Process and Communications 12/03/2019

Tracking Number Equipment with Offsite Agencies

2019-011s

Procedures 16DP-0EP22 Emergency Plan Maintenance 12, 13, 14

71114.05 Corrective Action Condition Reports 18-02598, 18-04925, 18-07580, 18-10461, 18-11148, 18-

Documents 11979, 18-12725, 18-14077, 18-16169, 18-18246, 18-

20137, 19-02003, 19-02103, 19-02232, 19-02712, 19-

03318, 19-03810, 19-03963, 19-03969, 19-03714, 19-

04338, 19-07679, 19-08797, 19-08901, 19-09184, 19-

09910, 19-09947, 19-12962, 19-13384, 19-13928, 19-

244, 19-18312, 19-18597, 20-00112

Corrective Action Condition Reports 20-01449, 20-03012, 20-03079, 20-03080, 20-03630

Documents

Resulting from

Inspection

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)

1908 - Health Physics Drill Report 10/11/2019

1910 ERO Mini Drill Report -ERO White Team (December 01/02/2020

10, 2019)

1911 - Environmental Monitoring Drill Report 12/06/2019

Emergency Preparedness Self-Assessment Report, NRC 02/20/2018

Baseline Inspection, Completed - 1/29/2018 to 2/2/2018

2019 EP Department Self-Assessment Report, SWMS No. 01/28/2019

19-00512, Completed 1/7/2019 to 1/11/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-0801 EAL Classification Matrix, Hot Conditions (RCS greater than H

210F)

EP-0930 EAL Classification Matrix, All Conditions A, B

EP-802 EAL Classification Matrix, Cold Conditions (RCS equal H

to/less than 210F)

ID: 240-02825 1801 Full-Scale Dress Rehearsal - ERO Red Team 09/25/2018

CS/MA (February 2018) - Rev 1

ID: 240-02828 2018 Onsite Contaminated Injury/Health Physics Drill Report 06/22/2018

ID: 240-02833 1806 ERO Mini Drill - ERO Green Team (July 10, 2018) 09/12/2018

CS/sw 1807 ERO Mini Drill - ERO White Team (July 24, 2018)

1808 ERO Mini Drill - ERO Blue Team (August 14, 2018)

ID: 240-02834 1802 Full-Scale Exercise - ERO Red Team (March 2018) 09/21/2018

CS/MA

ID: 240-02837 1809 - Health Physics Drill Report 10/11/2018

CS/sw

ID: 240-02838 ERO Off Hours Drive In Drill 10/12/2018

CS/sw

ID: 240-02857 1902 Full-Scale NRC Graded Exercise - ERO Gold Team 05/15/2019

CS/sw (March 2019)

ID: 240-02861 2019 Onsite Contaminated Injury/Health Physics Drill Report 06/19/2019

CS/sw

ID: 240-02867 2019 Annual Review of PVNGS Emergency Plan Letters of 07/17/2019

Agreement and Offsite Emergency Response Plan

ID: 240-2859 1901 Full-Scale Dress Rehearsal - ERO Gold Team 07/13/2019

CS/sw (February 2019)

KLD TR-1057 Palo Verde Nuclear Generating Station 2018 Population 12/06/2018

Update Analysis

KLD TR-1139 Palo Verde Nuclear Generating Station 2019 Population 12/05/2019

Update Analysis

Letter #: 240- 2018 Annual Review of PVNGS Emergency Plan Letters of 05/22/2018

2826 Agreement

LP Number: NRE28 RP Teams Continuing Training 01/11/2019

NRE28C000112

LP Number: NRE98 RPM Continuing Training 01/18/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

NRE98C000133

NAD Audit 2014- Nuclear Assurance Department (NAD) Audit Plan and 10/30/2014

009 Report, Audit 2048-009 Emergency Preparedness

NAD Audit 2015- Nuclear Assurance Department (NAD) Audit Plan and 11/24/2015

010 Report, Audit 2015-010 Emergency Preparedness

NAD Audit 2016- Nuclear Assurance Department (NAD) Audit Plan and 12/14/2016

010 Report, Audit 2016-010 Emergency Preparedness

NAD Audit 2017- Nuclear Assurance Department (NAD) Audit Plan and 01/25/2018

008 Report, Audit 2017-008 Emergency Preparedness

NAD Audit 2018- Nuclear Assurance Department (NAD) Audit Plan and 11/07/2018

006 Report, Audit 2018-006 Emergency Preparedness

NAD Audit 2019- Nuclear Assurance Department (NAD) Audit Report 2019- 11/22/2019

008 008, Emergency Preparedness

Procedures 01DP-0AP12 Condition Reporting Process 28-34

16DP-0EP20 Conduct of Emergency Preparedness Operation 22

16DP-0EP22 Emergency Plan Maintenance 14

16DP-0EP23 Emergency Preparedness Drill/Exercise Administration 12

16DP-0EP25 Emergency Preparedness Training Program Description 18

16DP-0EP28 Emergency Facility/Kit Inventories and Inspections 7

16DP-0EP29 Emergency Preparedness Offsite Program 9

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

60DP-0QQ19 Internal Audits 4, 6, 21, 30

EP-900 Emergency Response Organization (ERO) Position 19

Checklists

EP-901 Classifications 11, 12

EP-904 ERO/ERF Activation and Operation 8

71114.06 Corrective Action Condition Reports 20-03336, 20-03349

Documents

Miscellaneous Form EP-0541

Significant Events Log 03/10/2020

20 Emergency Preparedness Scenario 2002 03/04/2020

Procedures PVNGS Emergency Plan 66

71151 Corrective Action Condition Reports 19-16961, 19-17817, 19-18712, 20-00328

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

Miscellaneous Palo Verde Nuclear Generating Station, Alert and 5

Notification System (ANS) FEMA 350 Report, July 2019

NRC Quarterly Performance Indicators: Palo Verde

NRC Quarterly Performance Indicators: Palo Verde

19-09761-001 Fuel Oil Transfer Pump: NRC ROP PI Safety System

Functional Failure Exclusion Evaluation

19-09761-001 Fuel Oil Transfer Pump: NRC ROP PI Safety System

Functional Failure Exclusion Evaluation

LP Number: SES- PT-100X FH/SGTL/SGTR/ESD (FRP) 10/25/2017

STA-09-00

Procedures Palo Verde Nuclear Generating Station, Siren Operating 10/9/2019

Manual

16DP-0EP27 Emergency Preparedness Equipment Testing 17

16DP-0EP37 Prompt Notification System 7

71152 Corrective Action Condition Reports 20-03500, 20-03363, 20-03216, 20-03162, 20-03111, 20-

Documents 03076, 20-03075, 20-03026

26