ML18341A025

Notification of NRC Design Bases Assurance Inspection (Teams)(05000528/2019011, 05000529/2019011, and 05000530/2019011) and Initial Request for Information

ML18341A025
Person / Time
Site:	Palo Verde
Issue date:	12/03/2018
From:	Thomas Farnholtz Region 4 Engineering Branch 1
To:	Bement R Arizona Public Service Co
Farnholtz T
References
IR 2019011
Download: ML18341A025 (7)

See also: IR 05000528/2019011

Text

December 3, 2018

Mr. Robert S. Bement

Executive Vice President Nuclear/

Chief Nuclear Officer

Arizona Public Service Company

P.O. Box 52034, MS 7602

Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NOTIFICATION OF NRC

DESIGN BASES ASSURANCE INSPECTION (TEAMS) (05000528/2019011,

05000529/2019011, AND 05000530/2019011) AND INITIAL REQUEST FOR

INFORMATION

Dear Mr. Bement:

On January 24, 2019, the NRC will begin a triennial baseline design bases assurance

inspection at the Palo Verde Nuclear Generating Station. A six person team will perform this

inspection using NRC Inspection Procedure (IP) 71111, Attachment 21M, Design Bases

Assurance Inspection (Teams).

The inspection focuses on the maintenance of the design bases and modifications made to

structures, systems, and components. The samples reviewed during this inspection will be

identified during an information gathering visit. In addition, a number of operating experience

issues will also be selected for review during the in-office preparation week.

The inspection will include an information gathering site visit by the team leader and 2 weeks of

onsite inspection by the team. The inspection will consist of three NRC inspectors and two NRC

contractors, who will focus on engineering, and one NRC inspector that will focus on operations.

The current inspection schedule is as follows:

Onsite Information Gathering Visit: January 24, 2019

Preparation Week: February 4-8, 2019

Onsite Weeks: February 11-15, 2019, and February 25, 2019 - March 1, 2019

The purpose of the information gathering visit is to meet with members of your staff to identify

potential risk-significant components and operator actions. The lead inspector will also request

a tour of the plant with members of your operations staff and probabilistic safety assessment

staff. During the onsite weeks, several days and administration will be needed on the plant-

referenced simulator in order to facilitate the development of operator action-based scenarios.

R. Bement 2

Additional information and documentation needed to support the inspection will be identified

during the inspection, including interviews with engineering managers, engineers, and

probabilistic safety assessment staff.

Our experience with these inspections has shown that they are extremely resource intensive,

both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact

on the site and to ensure a productive inspection, we have enclosed a request for information

needed for the inspection. The request has been divided into two groups. The first group lists

information necessary for the information gathering visit and for general preparation. This

information should be available to the regional office no later than January 21, 2019, unless

otherwise stated. If possible, this information should be provided electronically to the lead

inspector. Since the inspection will be concentrated on high risk/low margin components and

modifications, calculations associated with your list of high risk components and modifications

should be available to review during the information gathering visit to assist in our selection of

components based on available design margin.

The second group of documents requested lists information necessary to aid the inspection

team in tracking issues identified as a result of the inspection. It is requested that this

information be provided to the lead inspector as the information is generated during the

inspection. An additional request will be made by the team during the preparation week once

the specific components and modifications have been selected. Additional requests by

inspectors will also be made throughout the onsite weeks for specific documents needed to

complete the review. It is important that all of these documents are up-to-date and complete in

order to minimize the number of additional documents requested during the preparation and/or

onsite portions of the inspection. In order to facilitate the inspection, we request that a contact

individual be assigned to each inspector to ensure information requests, questions, and

concerns are addressed in a timely manner.

The lead inspector for this inspection is Gerond A. George, Senior Reactor Inspector. We

understand that our licensing engineer contact for this inspection is Ms. L. Weaver. If there are

any questions about the inspection or the requested materials, please contact the lead inspector

by telephone at 817-200-1562 or by e-mail at Gerond.George@nrc.gov.

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

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

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

number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be

made available electronically for public inspection in the NRC Public Document Room or from

R. Bement 3

the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Thomas R. Farnholtz, Chief

Engineering Branch 1

Division of Reactor Safety

Dockets: 50-528; 50-529; and 50-530

Licenses: NPF-41; NPF-51; and NPF-74

Enclosure: Design Bases Assurance

Inspection (Teams) Request for

Information

Initial Request for Information

Design Bases Assurance Inspection (Teams)

Palo Verde Nuclear Generating Station

Inspection Reports: 05000528/2019011, 05000529/2019011, AND

05000530/2019011

EPID ID: I-2019-011-0009

Information Gathering Dates: January 24, 2019

Inspection Dates: February 11, 2019, to March 1, 2019

Inspection Procedure: IP 71111, Attachment 21M, Design Bases Assurance

Inspection (Teams)

Lead Inspector: Gerond A. George, Senior Reactor Inspector

I. Information Requested Prior to Information Gathering Visit (due January 21, 2019)

The following information (Section I of this enclosure) should be sent to the Region IV

office in hard copy or electronic format to the attention of Gerond A. George by

January 21, 2019, to facilitate the reduction in the items to be selected for a final list.

The inspection team will finalize the selected list during the preparation week. The

specific items selected from the lists shall be available and ready for review on the day

indicated in this request. *Please provide requested documentation electronically in

pdf files, Excel, or other searchable formats, if possible. The information should

contain descriptive names and be indexed and/or hyperlinked to facilitate ease of use.

Information in lists should contain enough information to be easily understood by

someone who has knowledge of pressurized water reactor technology. If requested

documents are large and only hard copy formats are available, please inform the

inspector and provide subject documentation during the first day of the onsite inspection.

1. An Excel spreadsheet of equipment basic events (with definitions), including

importance measures sorted by risk achievement worth and Fussell-Vesely from

your internal events probabilistic risk assessment. Include basic events with risk

achievement worth value of 1.3 or greater.

2. A list of the top 50 cut-sets from your PRA.

3. Copies of probabilistic risk assessment system notebooks and the latest

probabilistic risk assessment summary document.

4. An Excel spreadsheet of probabilistic risk assessment human action basic events or

risk ranking of operator actions from your site-specific PSA sorted by risk

achievement worth and Fussell-Vesely. Provide copies of your human reliability

worksheets for these items.

5. If you have an external events or fire PSA model, provide the information requested

in items 1-4 for external events and fire.

Enclosure

6. A list of high large early release frequency impact events and associated

components.

7. Structures, systems, and components in the Maintenance Rule (a)(1) category.

8. A list of high risk maintenance rule systems/components and functions; based on

engineering or expert panel judgment.

9. Site top 10 issues list, if available.

10. Any pre-existing list of components and associated calculations with low design

margins.

11. A list of operating experience evaluations for the last 3 years.

12. A list of all time-critical operator actions in procedures.

13. A list of current operator work arounds/burdens.

14. Procedures, including emergency and abnormal, used to accomplish operator

actions associated with the basic events credited in your PRA.

15. Lists of permanent and temporary modifications performed in the past 5 years to

structures, systems, and components sorted by component identified in Item 1.

16. List of root cause evaluations associated with component failures or design issues

initiated/completed in the last 5 years.

17. A list of any common-cause failures of components in the last 3 years.

18. A copy of any internal/external self-assessments and associated corrective action

documents generated in preparation for this inspection.

19. A copy of engineering/operations-related audits completed in the last 2 years.

20. Electronic copies of the Technical Specifications, Technical Specifications Bases,

and the Final Safety Analysis Report, as updated.

21. A copy of the Individual Plant Examination of External Events, if available

electronically.

22. One-line drawings of emergency core cooling system, ultimate heat sink, emergency

feedwater, safety-related electrical systems.

23. A copy of condition reports associated with inspection findings from the previous

NRC Inspection Procedure 71111.21 (or 71111.21 Attachment M inspection).

24. A list of licensee contacts for the inspection team with phone numbers.

25. A copy of the current management and engineering organizational charts.

2

II. Information Requested to be provided throughout the inspection.

1. Electronic copies of the design bases documents for selected components and

modifications.

2. Electronic copies of the system health notebooks for selected components and

modifications.

3. A list of the design calculations that provide the design margin information for

selected components.

4. Calculations and drawings associated with selected components.

5. Modification documentation associated with modifications selected from Item I.15,

this includes:

a. Post-modification testing, including performance characteristics affected,

assumptions, and acceptance criteria associated with modifications selected.

b. Updated maintenance and surveillance procedures associated with

modifications.

c. Updated operation procedures and training plans associated with the

modifications.

6. Copies of any corrective action documents generated as a result of the teams

questions or queries during this inspection.

7. Copies of the list of questions submitted by the team members and the

status/resolution of the information requested (provide daily during the inspection to

each team member).

Inspector Contact Information:

Gerond A. George

Senior Reactor Inspector

817-200-1562

Gerond.George@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Gerond A. George

1600 East Lamar Blvd.

Arlington, TX 76011-4511

3

ML18341A025

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

By: GAG Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:EB1 C:EB1

NAME GGeorge TFarnholtz

SIGNATURE /RA/ /RA/

DATE 11/27/2018 12/03/2018