IR 05000528/2021010
| ML21117A295 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/28/2021 |
| From: | Ami Agrawal Division of Reactor Safety IV |
| To: | Lacal M Arizona Public Service Co |
| References | |
| IR 2021010 | |
| Download: ML21117A295 (13) | |
Text
April 28, 2021
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2 AND 3 -
BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000528/2021010 AND 05000529/2021010 AND 05000530/2021010
Dear Ms. Lacal:
On March 26, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
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, Digitally signed by Ami Agrawal Ami Agrawal Date: 2021.04.28 16:00:47-05'00'
Ami N. Agrawal, Team Lead Inspection Programs & Assessment Team Division of Reactor Safety Docket Nos. 05000528 and 05000529 and 05000530 License Nos. NPF-41 and 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: 05000528/2021010, 05000529/2021010 and 05000530/2021010 Enterprise Identifier: I-2021-010-0001 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Units 1, 2 and 3 Location: Tonopah, AZ Inspection Dates: March 01, 2021 to March 26, 2021 Inspectors: R. Azua, Senior Reactor Inspector D. Bollock, Senior Reactor Operations Engineer B. Correll, Reactor Inspector P. Vossmar, Senior Project Engineer Approved By: Ami N. Agrawal, Team Lead Inspection Programs & Assessment Team Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the licensee's ultimate heat sink/spray ponds.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Palo Verde Nuclear Generating Station developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance.
- As part of this inspection, the team selected the plants ultimate heat sink/spray ponds for a focused review within the corrective action program. For these systems, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of these systems. However, the team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the Palo Verde Nuclear Generating Station is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process. Audits were very detailed, thorough, and identified issues.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed eighteen individuals. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a Condition Report or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Instrumentation and Controls organization, and the Security organization. Due to the challenges brought on by the COVID-19 pandemic, and the Palo Verde Nuclear Generating Station's performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the Palo Verde Nuclear Generating Station has an adequate Safety Conscious Work Environment.
Willingness to Raise Nuclear Safety Issues: In the assessed focus groups, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
Overall, the team concluded that the Palo Verde Nuclear Generating Station maintained a healthy SCWE.
Employee Concerns Program: The team looked at the Palo Verde Nuclear Generating Station 's Employee Concerns Program (ECP). The team interviewed the ECP manager and discussed her cases. The team reviewed the ECPs investigative packages. Overall, the team did not identify any concerns with the program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 26, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Maria Lacal and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations 13-JC-SG-0205 Uncertainty Calculation for MSIV / FWIV Air Reservoir 7
Pressure Channels
Corrective Action Evaluation 20-02912-008 "U2 Reactor Trip due to Loss of 0
Documents Both Main Feedwater Pumps"
Condition Reports 16-08132, 16-08153, 17-16121, 17-16133, 18-00202, 18-
00361, 18-00362, 18-00906, 18-04090, 18-02591, 18-02604,
18-02625, 18-04013, 18-04386, 18-04528, 18-04757, 18-
05850, 18-06986, 18-07057, 18-07654, 18-07701, 18-08748,
18-08082, 18-08905, 18-09037, 18-09607, 18-09754, 18-
10332, 18-10362, 18-10569, 18-10611, 18-10686, 18-10939,
18-11093, 18-11413, 18-11600, 18-11605, 18-12188, 18-
2586, 18-12595, 18-12606, 18-12710, 18-12882, 18-13094,
18-13464, 18-13597, 18-13697, 18-14201, 18-14254, 18-
278, 18-14355, 18-14363, 18-14492, 18-14563, 18-14670,
18-14765, 18-14792, 18-14811, 18-14913, 18-15062, 18-
15114, 18-15136, 18-15173, 18-15271, 18-15705, 18-15988,
18-15990, 18-16124, 18-16256, 18-16438, 18-16467, 18-
16556, 18-16698, 18-16803, 18-17013, 18-17038, 18-17577,
18-17619, 18-17740, 18-17794, 18-17834, 18-18102, 18-
18730, 18-18935, 18-19036, 19-00797, 19-01919, 19-01992,
19-02554, 19-02846, 19-02987, 19-03055, 19-03935, 19-
04074, 19-04076, 19-04087, 19-04570, 19-04980, 19-05097,
19-05320, 19-05782, 19-05839, 19-06112, 19-06401, 19-
06472, 19-07158, 19-07346, 19-07419, 19-07977, 19-08022,
19-09064, 19-09306, 19-09307, 19-09323, 19-09352, 19-
09369, 19-09395, 19-10419, 19-10681, 19-10968, 19-11630,
19-11859, 19-11892, 19-12247, 19-12283, 19-12647, 19-
2699, 19-12700, 19-13273, 19-13292, 19-14793, 19-14968,
19-16095, 19-16375, 19-16711, 19-17214, 19-17504, 19-
17515, 19-18408, 19-18545, 19-18552, 19-18566, 19-18776,
20-01013, 20-01928, 20-02092, 20-02214, 20-02567, 20-
2912, 20-03247, 20-03639, 20-03915, 20-04177, 20-04286,
Inspection Type Designation Description or Title Revision or
Procedure Date
20-04287, 20-04681, 20-04780, 20-04787, 20-04958, 20-
04960, 20-05251, 20-05314, 20-05452, 20-05517, 20-05802,
20-05938, 20-06557, 20-06850, 20-07241, 20-07481, 20-
07547, 20-07670, 20-07739, 20-08110, 20-08198, 20-08199,
20-08265, 20-09028, 20-09364, 20-09585, 20-09725, 20-
09924, 20-10484, 20-10494, 20-10515, 20-10641, 20-10816,
20-11174, 20-11182, 20-11409, 20-11431, 20-11551, 20-
11560, 20-11568, 20-11593, 20-11696, 20-11699, 20-11850,
20-11978, 20-12024, 20-12081, 20-12429, 20-12624, 20-
13190, 20-13770, 20-14083, 20-14169, 20-14289, 20-14754,
20-15396, 20-15470, 20-16013, 20-16123, 20-16333, 21-
00183, 21-00892, 21-01086, 21-01121, 21-02448, 21-02452,
Corrective Action NCV 2019002-01 LEVEL 2 EVALUATION CR 19-06854 in response to NRC 0
Documents closure NCV 2019002-01
Resulting from NCV 2019003-01 Evaluation 19-02688-007 Revision 2 "Unit 3B Diesel Fuel Oil Rev 2
Inspection closure Transfer Pump Trip"
NRC FIN LEVEL 3 EVALUATION REPORT 18-15727-001 and 0
2018003-01 LEVEL 2 EVALUATION CR 18-10686 in response to NRC
FIN 2018003-01
Engineering DMWO 3560653 Diesel Fuel Oil Storage Tank Cable
Changes Replacement (DF-1555)
EC 18-14201-010 "New knob design / installation method for 0
910 and 911 Series hand-switches."
18-03753-003 Raise the Setpoint for the MSIV/FWIV Control Air Reservoir 0
Low Pressure Alarm
Engineering 18-12188-007 Lack of O2 Analyzer Cells for GR System Becoming an 03/15/2020
Evaluations Issue
18-18935-002 Unit 2 Polar Crane Modification Issues 0
20-06850-003 Contractor Injury While Moving Portable A/C Unit 0
Miscellaneous Radiation Protection Event logs (2018-2020) 01/27/2021
SI Shut Down Cooling Performance Criteria Formulation 06/30/2008
Bases
SI Tanks SITs Performance Criteria Formulation Bases 06/30/2008
Spray Pond Maintenance Rule Performance Criteria Basis 3
Inspection Type Designation Description or Title Revision or
Procedure Date
Worksheet
Station Blackout Generators Performance Criteria 03/16/2011
Formulation Bases
Spray Pond System Health Reports 01/01/2016-
01/01/2021
Main Steam Maintenance Rule Performance Criteria Basis 5
Worksheet
SI Containment Spray Performance Criteria Formulation 06/30/2008
Bases
SI High Pressure SI Performance Criteria Formulation Bases 06/30/2008
Instrument Air Maintenance Rule Performance Criteria Basis 3
Worksheet
19-02987 Maintenance Rule a(1) Issue Tracking Form - MSIVs 0, 1
February 2021 Station Quality Issue (SQI): Maintenance Material Storage February
Station Quality 2021
Issue (SQI):
Maintenance
Material Storage
NGT90C000136 Technical Conscience Principles 09/13/2019
SI Low Pressure 06/30/2008
SI Performance
Criteria
Formulation
Bases
SR-19-0037 Document review of U3R21 refueling outage work order 10/19/2019
instructions (SG blowdown valve replacement).
SR-19-0039 Observation of work associated with PB 1655 modification 10/22/2019
for replacement of existing Class 1E 727 relays.
SR-20-0032 Walkdown of Electrical Maintenance Shop (EMS) Level B 10/19/2020
storage area
Operability 19-03935
Evaluations 19-04277
19-16834
20-06195
Inspection Type Designation Description or Title Revision or
Procedure Date
21-00373
Procedures 01DP-0AP50 Project Management 6
01DP-0XX01 Control and Monitoring of Potential Tornado Borne Missiles Revision 6
31MT-9RC23 Reactor Coolant Pump Sulzer Bingham Seal Replacement 42
40DP-9ZZ04 Time Critical Action (TCA) Program 16
40OP-9FT01 Feedwater Pump Turbine A 58
40OP-9FT02 Feedwater Pump Turbine B 55
60DP-0QQ23 Nuclear Assurance Stop Work and Escalation Processes 12
70DP-0MR01 Maintenance Rule 46
70DP-0RA03 Probabilistic Risk Assessment Model Control 18
81DP-0CC28 Classification of Structures, Systems, and Components Revision 16
81DP-0EE10 Design Change Process 50
AP50-55 Complexity Evaluation 2
EDG 01 Engineering Human Performance Tools 14
IP-ENG-001 Standard Design Process 2
Self-Assessments Audit Plan and Report - Audit 2018-004 Training and 0
Qualification
Audit Plan and Report 2018-007 Radiation Safety 0
Audit Plan and Report 2018-007 Radiation Safety 0
Audit Report Audit 2020-003 Nuclear Training 0
18-10703 3R20 Modifications Site Self Assessment 0
19-0029 Design and Configuration Control Audit 0
19-021 Design and Configuration Control Audit 0
20-00078 Trending Engineering Projects Team Clock Reset Data 0
20-04619 Boric Acid Corrosion Control Program Simple Self 0
Assessment
20-04628 MRV Flow Accelerated Corrosion Self Assessment 0
2018-005 Maintenance and Modifications
2019-003 Engineering Programs Audit 0
2019-004 Fire Protection
2019-007 Design Control and Configuration Management Audit 0
20-004 Nuclear Fuels Audit 0
20-005 Maintenance and Modifications
Inspection Type Designation Description or Title Revision or
Procedure Date
Work Orders 5092504 Align ACTM card cages in CEDMCS cabinets 0
28646 Replace 3A SP Breaker 0
28728 Replace 1B SP Breaker 0
28750 Replace 2A SP Breaker 0
10