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05000528/FIN-2018008-0330 September 2018 23:59:59Palo VerdeLicensee-identifiedLicensee-Identified ViolationThis violation of very low safety-significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.Violation: 10 CFR 50.73(a)(2)(i)(B) requires, in part, that the holder of an operating license shall submit an licensee event report within 60 days of discovery of the event, which includes any operation or condition which was prohibited by technical specifications. Contrary to the above, the licensee failed to submit a licensee event report within 60 days of April 23, 2016, after discovering that the Unit 1 channel C excore was in a condition which was prohibited by technical specifications. The detector was found in a configuration without o-rings at two electrical connection interfaces. Condition Report 16-06735 documented the non-conforming condition, but was closed without performing a reportability review. Significance/Severity Level: This violation was considered as traditional enforcement because the failure to notify the NRC had the potential for impacting the NRCs ability to perform its regulatory function. Consistent with the guidance in Section 6.9, Paragraph d.9, of the NRC Enforcement Policy, the failure to report the condition prohibited by technical specifications was determined to be a Severity Level IV violation. Corrective Action Reference(s): Condition Report 18-02569
05000528/FIN-2014404-1131 March 2015 23:59:59Palo VerdeLicensee-identifiedLicensee-Identified Violation
05000528/FIN-2013003-0430 June 2013 23:59:59Palo VerdeLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.59(c)(1) requires, in part, that a licensee may make changes in the facility as described in the final safety analysis report without obtaining a license amendment pursuant to Section 50.90 only if a change to the technical specifications incorporated in the license is not required. Contrary to the above, between 2003 and March 8, 2013, the licensee made changes to the reactivity of fuel discharged to the spent fuel pool without obtaining a license amendment. Specifically, the licensee received license amendments for power uprates in 2003 and 2005, but did not recognize the impact of the power uprates relative to spent fuel pool criticality. Consequently, the licensee did not update the spent fuel pool criticality analysis of record and did not request a license amendment to revise the affected Technical Specifications 3.7.17 and 4.3.1.1. On March 8, 2013, the licensees engineering staff discovered that the spent fuel pool analysis of record had not been updated to account for the replacement steam generator power uprate. The power uprate required higher moderator and fuel temperatures within the core, thereby increasing plutonium production, which in turn increases the reactivity of the spent fuel. This condition resulted in Technical Specifications 3.7.17 and 4.3.1.1 being non-conservative. The licensee initiated PVAR 4363316 to document the condition and issued an Event Notification to the NRC to report an unanalyzed condition. The licensee also performed a prompt operability determination to show that despite the non-conservative technical specifications, the fuel in the spent fuel pool remains in a safe configuration. The licensee planned corrective actions to revise the spent fuel pool analysis of record using updated methodology and input parameters. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. Assessing the violation in accordance with Enforcement Policy, the team determined it to be of Severity Level IV because it resulted in a condition evaluated by the SDP as having very low safety significance.
05000528/FIN-2013002-0331 March 2013 23:59:59Palo VerdeNRC identifiedFailure to Maintain the Updated Final Safety Analysis Report for Radwaste Systems and ProcessesThe inspectors identified a Severity Level IV violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, with two examples for the failure to restore compliance within a reasonable time after a previous Severity Level IV non-cited violation of 10 CFR 50.71(e) was identified. The violation was identified because the licensee failed to periodically update the Updated Final Safety Analysis Report (UFSAR) with all changes made in the facility or procedures. Specifically, Example 1: From 1988 to 2013, the licensee did not update Chapter 11.2.2.3, Liquid Radwaste System, with a description of the temporary adsorption tanks and their use. The licensee has entered this violation into their corrective action program as PVAR 3075089. Example 2: From December 2003 to January 2013, the licensee made changes to the facility and procedures as described in the UFSAR, and performed safety analyses and evaluations in support of these changes, but failed to update the UFSAR to include these changes. Specifically, the licensee built the old steam generator storage facility used for long-term storage of radioactive waste (six replaced steam generators and three reactor vessel heads) on the owner controlled site until decommissioning. The licensee has entered this violation into their corrective action program as Condition Report (CR) 3398042 and PVAR 4330483. This violation is more than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Because this issue affected the NRCs ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The issue was characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy because the erroneous information in the UFSAR was not used to make an unacceptable change to the facility or procedures. A cross-cutting aspect was not assigned because the violation was handled through traditional enforcement.
05000528/FIN-2012003-0730 June 2012 23:59:59Palo VerdeNRC identifiedFailure to Provide Complete and Accurate Information Regarding Safety Related Roof Drainage CapabilitiesThe inspectors identified a Severity Level IV violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the failure of the licensee to provide complete and accurate information in all material respects in response to Generic Letter 88-20, Supplement 4. Specifically, the licensee asserted that roofs are equipped with roof drains and scuppers as backup. As a result, the licensee concluded roof ponding considerations were not applicable to the Palo Verde Nuclear Generating Station site. Inspectors determined that there are no roof drains installed. The licensee initiated corrective actions to provide an accurate depiction of the roof drainage capabilities to the NRC. This finding has been entered into the licensees corrective action program as PVAR 3952605. The failure of the licensee to provide complete and accurate information for safety related building roof drainage was a performance deficiency. The Significance Determination Process is not suited to assess the significance of the performance deficiency because it affected the ability of the NRC to perform its regulatory oversight function and as such, it was assessed using traditional enforcement. This issue was determined to be a Severity Level IV violation in accordance with NRC Enforcement Policy examples provided in Section 6.9. No crosscutting aspect was assigned because the performance deficiency was assessed using traditional enforcement
05000528/FIN-2012301-0131 March 2012 23:59:59Palo VerdeNRC identifiedFailure to Request an Experience Waiver for a Reactor Operator License ApplicantAn NRC-identified non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, was identified for failure to request an experience waiver on NRC Form 398 for a Reactor Operator license applicant who did not have three years of responsible nuclear power plant experience as required by NUREG 1021, Revision 9, Supplement 1, ES-202.D.1.a.(1). Upon discovery, the facility licensee submitted a revised NRC Form 398, which included the waiver request, and entered this issue into their corrective action program as Condition Report 4080143. The examiners evaluated this issue using the traditional enforcement process because the performance deficiency had the potential for impacting the NRC s ability to perform its regulatory function. This performance deficiency was determined to be Severity Level IV because it fits the SL-IV example of Enforcement Policy Section 6.4.d, Violation Examples: Licensed Reactor Operators. This section states, Severity Level IV violations involve, for example ... cases of inaccurate or incomplete information inadvertently provided to the NRC that does (sic) not contribute to the NRC making an incorrect regulatory decision as a result of the originally submitted information or an unqualified individual performing the functions of an operator or senior operator... . Because the performance deficiency was corrected before the issuance of a license and an experience waiver was ultimately granted, it did not cause the NRC to make an incorrect regulatory decision. There is no Cross-Cutting Aspect associated with this violation because it was processed using Traditional Enforcement. This violation is described in greater detail in section 4OA5.1.b of this report.
05000528/FIN-2012301-0231 March 2012 23:59:59Palo VerdeNRC identifiedInaccurate Identification of an Open-Reference Initial Licensing Exam Question as Closed-ReferenceAn NRC-identified non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, was identified for submitting a final written exam question to the NRC which was identified and approved as Closed Reference, but administered by the licensee as Open Reference by supplying the applicants with an unapproved Technical Specification. On evaluation, the NRC determined that it would not have approved the question had it been properly identified as openreference on submittal, because the reference made the question a direct lookup and the information in the reference was of a nature that licensed operators are expected to have memorized. No licensing decisions were affected and the facility licensee entered this issue into their corrective action program as Condition Report 4144197. The examiners evaluated this issue using the traditional enforcement process because the performance deficiency impacted the NRCs ability to perform its regulatory function. This performance deficiency was determined to be Severity Level IV because it fits the SL-IV example of Enforcement Policy Section 6.4.d, Violation Examples: Licensed Reactor Operators. This section states, Severity Level IV violations involve, for example ... cases of inaccurate or incomplete information inadvertently provided to the NRC that does (sic) not contribute to the NRC making an incorrect regulatory decision as a result of the originally submitted information or an unqualified individual performing the functions of an operator or senior operator... . The performance deficiency did not cause the NRC to make an incorrect regulatory decision because it did not affect the number of applicants who passed. There is no Cross-Cutting Aspect associated with this violation because it was processed using Traditional Enforcement. This violation is described in greater detail in section 4OA5.2.b of this report.
05000528/FIN-2011003-0330 June 2011 23:59:59Palo VerdeNRC identifiedFailure to Submit an LER for a Condition Prohibited by the Plants Technical SpecificationS.The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a)(1) for failure to submit a Licensee Event Report within 60 days following discovery of a condition prohibited by Technical Specifications. The licensee made a procedure change in 1986 to Procedure 41OP-1HJ01, Control Room Handswitch/Valve Checklist, to maintain control room outside air dampers normally closed instead of the normally open position stipulated in the final safety analysis report. The inspectors concluded that the incorrect alignment of the dampers was a condition prohibited by Technical Specification 3.3.9, Control Room Essential Filtration Actuation Signal and that the licensee failed to adequately evaluate the issue for reportability. The licensee entered the issue into the corrective action program as Palo Verde Action Request 3791486. The inspectors concluded the failure of Arizona Public Service to report a condition prohibited by Technical Specifications was a performance deficiency. The inspectors evaluated this performance deficiency using the traditional enforcement process because the failure to submit a required report affected the NRCs ability to perform its regulatory function. Consistent with the guidance in Section 2.2.2 and Section 6.9.d of the NRC Enforcement Policy, the inspectors concluded the finding was a Severity Level IV violation because the licensee failed to make a timely written report that resulted in no or relatively inappreciable potential safety consequences.
05000528/FIN-2011002-0131 March 2011 23:59:59Palo VerdeNRC identifiedFailure to Perform a 10 CFR Part 21 EvaluationThe inspectors identified a Severity Level IV noncited violation of 10 CFR Part 21 after Palo Verde Nuclear Generating Station failed to evaluate an identified deviation within 60 days of discovery to determine if there was a substantial safety hazard. On November 23, 2010, the licensee completed an apparent cause evaluation for a failure of the Unit 3 train B spent fuel pool cooling pump and concluded the cause of the failure was a misalignment by the vendor of the bell alarm bracket within the K-600S 480 VAC Class 1E circuit breaker. Additionally, the apparent cause evaluation identified similar failures of the same type of breaker dating back to April 29, 2009. On December 7, 2010, the extent of condition review identified 76 breakers, including some in safety related applications, installed in the three units that could be impacted by the same failure mechanism. The inspectors questioned whether the licensee should have performed an evaluation in accordance with 10 CFR Part 21 to determine if a defect existed. On February 15, 2011, the licensee completed an evaluation of prior deviations related to the alignment of bell alarm switches and concluded the deviations were defects that were reportable per 10 CFR Part 21. The licensee subsequently submitted Part 21 Report 2011-07-00 on February 24, 2011. The licensee entered the performance deficiency into the corrective action program as Palo Verde Action Request 3593672 and has not completed corrective actions for this issue. The inspectors concluded that the failure to perform the substantial safety hazard evaluation within 60 days as required by 10 CFR 21.21(a)(1) was a violation of NRC requirements. The inspectors evaluated this violation using the traditional enforcement process because the failure to submit a required report affected the NRCs ability to perform its regulatory function. Consistent with the guidance in Section 2.2.2 and Section 6.9.d of the NRC Enforcement Policy, the inspectors concluded the violation was a Severity Level IV because the licensee failed to make a timely written report that resulted in no or relatively inappreciable potential safety consequences.
05000528/FIN-2010005-0331 December 2010 23:59:59Palo VerdeNRC identifiedFailure to Ensure All License Conditions Are Met for Licensed OperatorsThe inspectors identified a Severity Level IV violation of 10 CFR 55.3, License Requirements, for the failure of the licensee to ensure that all individuals authorized by a license to operate the controls of the facility met all the conditions of their licenses as defined in 10 CFR 55.3. Specifically, the requirement to have a biennial physical completed and certified by the facilitys physician during the continuous two year period for all licensed operators was not met for three licensed operators. Two of these licensed operators performed licensed operator duties 42 times between February 8 and March 25, 2010, after the deadline for their biennial examinations had passed. Upon discovery, the licensee removed these individuals from watchstanding duties pending follow-up medical evaluations. This issue was entered into the licensees corrective action program as Condition Report Disposition Request 3526981. The failure of the licensee to ensure that all individuals authorized by a license to operate the controls of the facility met all the conditions of their licenses as defined in 10 CFR 55.3 is a performance deficiency. Specifically, the requirement to have a biennial physical completed and certified by the facilitys physician during the continuous two year period for all licensed operators (as required in 10 CFR 55.21) was not met for three licensed operators, two of which were standing watch with expired medical examinations. The finding was evaluated using the traditional enforcement process because the failure to determine an operators medical condition and general health has the potential to impact the NRCs ability to perform its regulatory function; the NRC was not notified nor allowed an opportunity to review the specific medical conditions of the two operators whose medical qualifications had expired while they were standing watch or eligible to stand watch. Using the NRCs Enforcement Policy, section 6.4.d, Severity Level IV violation examples, this finding is similar to example 1 which states, in part that an unqualified individual performing the functions of an operator or senior operator. Two licensed operators stood watch without a certified medical examination within the two year period that the medical examination is required to be completed and certified by the physician. Because: (1) the medical conditions of the two licensed operators did not change when they received their medical examinations in recent weeks; (2) the finding did not cause any plant events or transients while the individuals were on watch; (3) it was not repetitive or willful; and (4) it was entered into the corrective action program, the finding was determined to be of very low safety significance and is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding has a crosscutting aspect in the area of human performance associated with the work practices component because medical staff supervisors did not oversee the biennial physical examination due dates such that nuclear safety was supported (H.4(c))(Section 1R11.2).
05000528/FIN-2009005-0431 December 2009 23:59:59Palo VerdeNRC identifiedFailure to Periodically Update the UFSARThe inspectors identified a noncited violation of 10 CFR 50.71 Maintenance of Records, because the licensee failed to update their updated final safety analysis report with submittals that include the effects of a change made to the facility. Specifically, the licensee built the old steam generator storage facility on the owner controlled area for long-term radwaste storage of six decommissioned steam generators and three reactor vessel heads and failed to update the updated final safety analysis report to include these changes to the facility and all safety analyses and evaluations performed. This issue was entered in the licensees corrective action program as CRDR 3398042. This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is more than minor because it has a material impact on licensed activities in that the six decommissioned steam generators and the Unit 2 reactor vessel head, with a significant radioactive source term have been relocated from the plant radiological controlled area to the owner controlled area. In addition, the radwaste management program was affected because the licensee determined that this low-level radwaste facility will store these large components until the site is decommissioned. The finding is characterized as a Severity Level IV, noncited violation in accordance with NRC Enforcement Policy, Supplement I, and was treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. This finding was reviewed for crosscutting aspects and none were identified because the performance deficiency is not indicative of current performance (Section 2OS2)
05000528/FIN-2009003-0530 June 2009 23:59:59Palo VerdeNRC identifiedFailure by a Security Officer to Conduct Required Hourly Fire Watch Tours Due to Careless DisregardThe inspectors identified a noncited Severity Level IV violation of License Condition 2.C.(7) when a security officer willfully failed to complete fire- 5 Enclosure watch tours on September 1, 2008. The inspectors concluded that the officer failed to complete the required fire watch tours due to a careless disregard for the regulations on the part of the individual. This issue was entered into the licensees corrective action program as Palo Verde Action Request 3219290.The failure to conduct two required hourly fire watch tours is a performance deficiency. This issue was dispositioned using traditional enforcement due to the willful aspects of the performance deficiency. In accordance with Section IV.A.4of the Enforcement Policy, this issue is considered more than minor due to the willful aspects of the performance deficiency. In accordance with the guidance in Supplement I of the Enforcement Policy, this issue is considered a Severity Level IV noncited violation because it was identified by the licensee, involved isolated acts of a low-level individual, and was addressed by appropriate remedial action. There were no crosscutting aspects associated with this performance deficienc
05000528/FIN-2007012-1831 December 2007 23:59:59Palo VerdeNRC identifiedFailure to Periodically Update the Updated Final Safety Analysis ReportThe team identified a Severity Level IV NCV of 10 CFR 50.71(e) for the failure of the licensee to periodically update the UFSAR with all changes made in the facility or procedures. While conducting a review of the Unit 2 liquid radiological waste system, the team found that the system was not being operated in accordance with the description provided in the UFSAR. Specifically, evaporator concentrate was being pumped to one of the high total dissolved solids (TDS) holdup tanks rather than the concentrate monitor tanks as specified in Section 11.2.2 of the UFSAR. The licensee stated that the Unit 2 concentrate monitor system had been out of service since 2002. The teams review of corrective action documents related to the system determined that the concentrate monitor tanks were not being used because of equipment/maintenance issues with the concentrate monitor system. The UFSAR stated in Section 11.2.2.4.1.2, that flow from the high TDS holdup tank can be terminated or diverted to an alternate path by operator action based on evaporator or holdup pump malfunction, high-pressure drop across the adsorption bed or ion exchangers, an exhausted resin bed, or when the radiological waste section leader determines it is necessary. The UFSAR did not specify the alternate flow path nor the allowed duration. The team concluded that operating outside of the UFSAR design basis for approximately 5 years was not the intent of UFSAR Section 11.2.2.4.1.2. Analysis: The team determined that the failure to update the UFSAR to reflect changes made to the facility was a performance deficiency. This issue was subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV violation because the erroneous information in the UFSAR was not used to make an unacceptable change to the facility or procedures. The cause of this finding had a crosscutting aspect associated with resources of the human performance area in that the licensee failed to ensure that personnel and equipment were available and adequate to maintain radiological safety by minimization of long-standing equipment issues (H.2.(a)). Enforcement: 10 CFR 50.71(e) requires that the licensee periodically update the USFAR with all changes made in the facility or procedures. Contrary to the above, in 2002 the licensee made a change to the facility and procedures as described in the UFSAR and failed to update the UFSAR. Specifically, the licensee began operating the Unit 2 liquid radiological waste system in a manner different than that specified by UFSAR when they commenced pumping evaporator concentrate to the high TDS holdup tanks rather than the concentrate monitor tanks as specified in UFSAR Section 11.2.2. The failure to update the UFSAR was characterized as a Severity Level IV violation. The finding was of very low safety significance because the change in operation of the total dissolved solids holdup tanks did not result in an increase in the likelihood of a release of radioactive material. This issue was entered in the licensees CAP as PVAR 3075089. This violation was treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000529/2007012-18, Failure to Periodically Update the Updated Final Safety Analysis Report
05000528/FIN-2006004-0730 September 2006 23:59:59Palo VerdeNRC identifiedFailure to Submit Complete Revisions to the Updated Final Safety Analysis Report for Permanent ModificationsThe inspectors identified a violation of 10 CFR 50.71(e)(4), for which enforcement discretion was exercised, that involved the failure to file revisions to the Updated Final Safety Analysis Report. Specifically, for the reporting period between January 2003 and December 2005, licensing personnel failed to submit a revision to the Updated Final Safety Analysis Report reflecting core protection calculator system modifications. The issued was entered into the licensees corrective action program as Condition Report/Disposition Request 2894635. The performance deficiency associated with this finding involved the failure of licensee personnel to submit revisions to the Updated Final Safety Analysis Report reflecting modifications installed in Unit 2 for more than 24 months. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees failure to revise the Updated Final Safety Analysis Report in a timely manner. Normally, the violation would be categorized at Severity Level IV in accordance with Section D.4 of Supplement I of the NRC Enforcement Policy. However, in accordance with Section VII.B.6 of the NRC Enforcement Policy, the NRC is refraining from taking enforcement action because of the NRC action taken in 1993 to issue and then retract a similar occurrence and the low safety significance of the finding (EA-06-267). The finding is not suitable for evaluation using the significance determination process, but has been reviewed by NRC management and is determined to be a finding of very low safety significance.
05000528/FIN-2006011-0330 September 2006 23:59:59Palo VerdeNRC identified10 CFR 50.59 Reviews not performed or Inadequate for multiple changes to spray pond chemistry control procedureA noncited violation of 10 CFR 50.59 was identified for making nine revisions to Procedure 74DP-9CY04, System Chemistry Specification, a procedure described in the Updated Final Safety Analysis Report between 1998 and 2004. Specifically, the licensee failed to perform evaluations for Revisions 3, 6, 8, 10, 12, 24, 28, 32, and 36 and performed inadequate evaluations for Revisions 10 and 36, to assess the potential impact of the changes on the safety-related components in the spray pond system. Each of these changes revised spray pond chemistry parameter limits which were subsequently determined to have contributed to heat exchanger fouling. Failure to adequately evaluate the impact of changes to the Chemistry Control Program was a performance deficiency. Because this violation had the potential to impact the NRC?s regulatory function, and because the associated significance was determined to be Green using Phase 3 of the significance determination process, this violation is being treated as a Severity Level IV violation. This issue was entered into the Corrective Action Program under CRDR 2902498. Because this violation was of very low safety significance and has been entered into the corrective action program, it is being treated as a noncited violation consistent with Section VI.A of the Enforcement Policy: NCV 05000528; 05000529; 05000530/2006011-03, 50.59 Reviews Not Performed or Inadequate for Multiple Changes to Spray Pond Chemistry Control Procedure.
05000528/FIN-2005005-0431 December 2005 23:59:59Palo VerdeNRC identifiedFailure to Submit LER to Report Shutdown Required by Technical Specifications

The inspectors identified a noncited Severity Level IV violation of 10 CFR 50.73 for the failure to submit a licensee event report within 60 days to report the completion of a plant shutdown required by the Technical Specifications. A second similar example of a violation of the same regulation was identified by the licensee. Specifically, the licensee was required to submit a licensee event report by May 17, 2005, to report the completion of a plant shutdown required by the Technical Specifications that occurred on March 18, 2005. This licensee event report was submitted on November 7, 2005. Additionally, the licensee was required to submit a licensee event report by April 10, 2005, to report the completion of a plant shutdown that occurred on February 9, 2005. A revised licensee event report was submitted on January 6, 2006. This issue was entered into the licensee's corrective action program as Condition Report/Disposition Requests 2829976 and 2844019.

The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform this regulatory function was potentially impacted by the licensees failure to report the event. The finding was determined to be a Severity Level IV violation in accordance with Section D.4 of Supplement I of the NRC Enforcement Policy. The finding is not suitable for evaluation using the significance determination process, but has been reviewed by NRC management and is determined to be a finding of very low safety significance. The cause of the finding is related to the crosscutting element of problem identification and resolution in that the transportability review, conducted by regulatory affairs personnel, failed to identify an additional example of a missed reportable event that was subsequently identified by the NRC.

05000528/FIN-2005004-0830 September 2005 23:59:59Palo VerdeNRC identifiedIncomplete and Inaccurate Information Associated with the Ex-Core Safety ChannelsThe inspectors identified a noncited Severity Level IV violation of 10 CFR 50.9 for providing incomplete or inaccurate information to the NRC. Specifically, the licensee provided incomplete and inaccurate information regarding the design control of ex-core safety channel log power instrument setpoints. This information was determined to be material in that it affected the NRC's ability to determine compliance with NRC requirements. This issue was entered into the licensee's corrective action program as Condition Report/Disposition Request 2829051 This finding was not assessed via NRC Manual Chapter 0609, Significance Determination Process, because the licensees actions impeded the regulatory process. Therefore, this finding was assessed in accordance with the NRC Enforcement Policy. The finding is associated with the mitigating systems cornerstone. The inspectors determined that engineering personnel had additional information, including the subsequently corrected revision of the calculation going through final verification, and additional explanatory setpoint procedures, which were not referenced or provided during the original correspondence by the licensee. Had the complete and accurate information been supplied at the time of the original request in 2003, the NRC would have identified a design control violation at that time. The safety consequence of this issue is of very low safety significance, in that there was no actual loss of a safety function.
05000528/FIN-2005002-0631 March 2005 23:59:59Palo VerdeNRC identifiedFailure to Obtain Prior NRC Approval for a Design Change to the Facility

A Severity Level IV non-cited violation of 10 CFR 50.59 requirements was identified for the failure to obtain a license amendment for a permanent modification to all six station emergency diesel generators. The inspectors determined that there were two modifications performed on the jacket water system of each emergency diesel generator. Condition Report/Disposition Request (CRDR) 130208, in 1993, directed the abandonment of the jacket water surge tank makeup valves on both emergency diesel generators of all three units. A recent modification, Design Modification Work Order 220055 in 2003, removed the surge tank low level alarm on both emergency diesel generators of all three units. The licensee replaced these two automatic actions (automatic makeup and low level alarm) with a manual operator action to fill, as necessary, every 12 hours during rounds. The inspectors reviewed the updated final safety analysis report (UFSAR) and design basis documents, and found that the automatic jacket water surge tank makeup, and the low level alarm, were both shown in UFSAR descriptions, drawings, and design value tables.

The issue was determined to be more than minor, through Inspection Manual Chapter 0612, Appendix B, in that it affected the mitigating systems cornerstone attribute of equipment performance, and was repeated for all of the station emergency diesel generators. The issue was determined to result in more than a minimal increase in the consequences of a malfunction of an structure, system, or component important to safety evaluated in the UFSAR, since jacket water leakage could go undetected for up to 12 hours and affect diesel operability. Thus, a license amendment was required. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the significance determination process. Therefore, this issue was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the result of a 10 CFR 50.59 violation can be assessed significance through the significance determination process. The lead inspector and the Region IV senior reactor analyst discussed the significance of this finding. An SDP Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of the mitigating system safety function. The licensee entered this issue into its corrective action program as CRDR 2711244.

05000528/FIN-2004014-0331 December 2004 23:59:59Palo VerdeNRC identifiedFailure to Perform Written Safety Evaluation in Accordance with 10 CFR 50.59 Requirements

The team identified three examples of a noncited, Severity Level IV violation of 10 CFR 50.59 requirements involving the failure to perform written safety evaluations prior to implementing changes to the facility. The first example involved a change for using manual actions in lieu of automatic actions as compensatory measures to support the safety functions of the high pressure safety injection and containment spray systems during postulated design basis loss-of-coolant accident conditions following a recirculation actuation signal. The second example involved operation of emergency core cooling systems with a 10-20 cubic foot void in the suction piping. The third example involved the failure to perform a written safety evaluation for changes involving filling the containment sump with borated water to a level above the containment sump safety injection recirculation piping. These changes were implemented in response to identifying that the safety injection system was not being maintained full of water

In accordance with Inspection Manual Chapter 0612, Appendix B, \"Issue Disposition Screening,\" the team determined that traditional enforcement applied because this finding may have impacted the NRC\'s ability to perform its regulatory function. The severity level of this finding was assessed as having very low safety significance reflective of a Severity Level IV violation. This determination was based in part on use of the significance determination process.

05000528/FIN-2004003-0630 June 2004 23:59:59Palo VerdeNRC identifiedFailure to Perform a Complete Shut Down Cooling Heat Exchanger Temperature LOOP Channel Calibration

A Severity Level IV noncited violation of Technical Specification 3.3.11 was identified for the failure to include the resistance temperature detectors in the channel calibration for the shutdown cooling heat exchanger temperature instruments. Specifically, prior to the implementation of Improved Technical Specifications, the licensee did not perform testing of the resistance temperature detectors. Following the implementation of Improved Technical Specifications, the licensee did not perform an in-place qualitative assessment of the resistance temperature detectors' behavior. This issue was entered into the corrective action program as CRDR 280178

The failure to perform a complete shutdown cooling heat exchanger temperature loop channel calibration is determined to have greater than minor significance because the licensee's failure to report the condition impacted the NRC's ability to perform it's regulatory function. Therefore, this finding was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, the finding can be assessed using the significance determination process. Using the Phase 1 worksheet in Manual Chapter 0609, "Significance Determination Process," this finding is determined to be of very low safety significance because it only affected the mitigating system cornerstone and the resistance temperature detectors were found to be within calibration.

05000528/FIN-2004006-0230 June 2004 23:59:59Palo VerdeNRC identifiedFailure to Provide an Evaluation of a Change to the Facility as Described in the UFSAR, Under 10 CFR 50.59 Requirements

The team identified a Severity Level IV violation of 10 CFR 50.59 requirements for failing to evaluate a modification to spent fuel storage in the spent fuel pools. The team reviewed CRDR 2524176, regarding the lack of a criticality analysis to support the use of rod capture tubes, which hold individual harvested fuel pins, in the spent fuel rack. The team reviewed the licensee's process of storing individual fuel pins, removed from a parent fuel assembly, and placed in rod capture tubes to be located in guide tubes of another host assembly. This resulted in a component that had nuclear fuel pins, of varying enrichment and depletion, stored as a regular fuel assembly in the spent fuel pools. The team noted that Section 9.1 of the UFSAR specifically described the storage of spent fuel in regions based upon fuel assembly initial enrichment, actual burnup, and actual decay time. The UFSAR does not describe the storage of individual pins in these regions. The licensee previously interpreted this as meaning the UFSAR did not prohibit such storage, and would not require consideration of enrichment, burnup, and decay of individual pins. The licensee failed to provide an evaluation of a change to the facility as described in the UFSAR, under 10 CFR 50.59 requirements. The licensee subsequently performed an evaluation of the criticality under station procedure 72DP-9NF01, "Control of SNM Transfer and Inventory," which was found acceptable

The issue was determined to be more than minor, through Inspection Manual Chapter 0612, Appendix B, in that it affected the barrier integrity cornerstone attribute of human performance, and could have represented a more significant issue if left uncorrected. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the significance determination process. Therefore, this issue was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the result of a 10 CFR 50.59 violation can be assessed significance through the significance determination process. The team leader and the Region IV senior reactor analyst discussed the significance of this finding. An SDP Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of the barrier integrity function. The licensee entered this issue into its corrective action program as CRDR 2711241.

05000528/FIN-2004003-0230 June 2004 23:59:59Palo VerdeNRC identifiedContainment Purge Penetration Nonconformance

A Severity Level IV noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified for the failure to correct a nonconforming condition in a timely manner. Specifically, since June 2001, the licensee discontinued implementation of required Technical Specification surveillance testing for the containment purge valves by declaring the valves inoperable and installing blind flanges. This issue was entered into the corrective action program as CRDR 2711167

The finding is greater than minor because the licensee's failure to submit a license amendment to correct the nonconforming condition impacted the NRC's ability to perform its regulatory function. Therefore, this finding was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, the finding can be assessed using the significance determination process. Using the Phase 1 worksheet in Manual Chapter 0609, "Significance Determination Process," the finding is determined to have very low safety significance because it only affected the barrier integrity cornerstone and the installation of blind flanges adequately maintained containment integrity.