IR 05000528/2021001

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

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

Text

May 12, 2021

SUBJECT:

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

Dear Mrs. Lacal:

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

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

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Palo Verde Nuclear Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects

Docket Nos. 05000528 and 05000529 and 05000530 License Nos. NPF-41, NPF-51 and NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000528, 05000529 and 05000530

License Numbers:

NPF-41, NPF-51 and NPF-74

Report Numbers:

05000528/2021001, 05000529/2021001 and 05000530/2021001

Licensee:

Arizona Public Service Company

Facility:

Palo Verde Nuclear Generating Station

Location:

Tonopah, AZ

Inspection Dates:

January 1, 2021 to March 31, 2021

Inspectors:

C. Peabody, Senior Resident Inspector

E. Lantz, Resident Inspector

N. Cuevas, Resident Inspector

R. Alexander, Senior Emergency Preparedness Inspector

N. Greene, Senior Health Physicist

G. Hansen, Senior Emergency Preparedness Inspector

A. Siwy, Senior Resident Inspector

S. Hedger, Emergency Preparedness Inspector

D. Reinert, Reactor Inspector

B. Baca, Health Physicist

D. Antonangeli, Health Physicist

Approved By:

John L. Dixon, Jr., Chief

Reactor Projects Branch D

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Palo Verde Nuclear Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Correctly Classify a Condition Adverse to Quality Associated with Turbine Driven Auxiliary Feed Water Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000528, 05000529,05000530/2021001-01 Open/Closed

[H.6] - Design Margins 71111.06 The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, for the licensees failure to disposition a condition adverse to quality associated with safety-related cables in accordance with the licensees condition reporting procedure. This has led to repeated water intrusion into Class 1E electrical conduits, which could degrade cabling and affect the reliability of the turbine driven auxiliary feedwater (AFW) pump.

Additional Tracking Items

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

PLANT STATUS

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

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

Unit 3 operated at or near full power for the duration of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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

71111.04 - Equipment Alignment

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

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

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

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

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

71111.05 - Fire Protection

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

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

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

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

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

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

71111.06 - Flood Protection Measures

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

The inspectors evaluated internal flooding mitigation protections in the:

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

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

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

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

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

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

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

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

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

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

71111.13 - Maintenance Risk Assessments and Emergent Work Control

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

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

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

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

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

71111.15 - Operability Determinations and Functionality Assessments

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

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

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

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

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

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

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

71111.19 - Post-Maintenance Testing

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

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

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

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

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

71111.20 - Refueling and Other Outage Activities

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

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

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

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

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

Inservice Testing (IP Section 03.01) (1 Sample)

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

71114.01 - Exercise Evaluation

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

(1)

(Partial)

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

71114.04 - Emergency Action Level and Emergency Plan Changes

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

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

• PVNGS Emergency Plan Revisions 67 and 68

This evaluation does not constitute NRC approval.

71114.08 - Exercise Evaluation Scenario Review

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

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

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

71124.05 - Radiation Monitoring Instrumentation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(1) RU-200, Radioactive Liquid Effluent Monitor

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

(3) RU-14, Radwaste Effluent Radiation Monitor

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

Transportation

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

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

(1) Unit 1 Resin Stream for 2020

(2) Unit 2 Resin Stream for 2020

(3) Unit 2 Dry Active Waste stream for 2020

Shipping Records (IP Section 03.05) (5 Samples)

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

(1)19-RW-018, LSA - II, Dewatered Resin (2)19-RW-023, LSA - I, Concentrates (3)20-RW-012, LSA - II, Dewatered Resin (4)20-RW-031, LSA - II, Dewatered Resin (5)20-RW-034, LSA - II, Dewatered Resin

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01)===

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

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

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

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (3 Samples)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

===71153 - Followup of Events and Notices of Enforcement Discretion

Event Followup (IP Section 03.01)===

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

INSPECTION RESULTS

Failure to Correctly Classify a Condition Adverse to Quality Associated with Turbine Driven Auxiliary Feed Water Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000528, 05000529,05000530/2021001-01 Open/Closed

[H.6] - Design Margins 71111.06 The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, for the licensees failure to disposition a condition adverse to quality associated with safety-related cables in accordance with the licensees condition reporting procedure. This has led to repeated water intrusion into Class 1E electrical conduits, which could degrade cabling and affect the reliability of the turbine driven auxiliary feedwater (AFW) pump.

Description:

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

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

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

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

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

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

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

Performance Assessment:

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

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

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

(1) was not a design deficiency,

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

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

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

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

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

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

Enforcement:

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

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

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

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

Description:

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

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

10 CFR 37.51 requires, in part,

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

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

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

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

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

Corrective Action References: CR-21-03309

EXIT MEETINGS AND DEBRIEFS

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

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

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

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

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

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

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Drawings

01-M-SIP-001

P& I Diagram Safety Injection & Shutdown Cooling System

2

71111.04

Drawings

01-M-SIP-002

P& I Diagram Safety Injection & Shutdown Cooling System

044

71111.04

Drawings

03-M-SPP-001

P& I Diagram Essential Spray Pond System

071

71111.04

Drawings

03-M-SPP-002

P& I Diagram Essential Spray Pond System

019

71111.05

Miscellaneous

PVGS Pre-Fire Strategies Manual

71111.05

Miscellaneous

USAR Section 9B

Fire Hazards Analysis

71111.06

Calculations

13-MC-ZA-0807

MSSS 100 Elevation Flooding Evaluation

71111.06

Calculations

13-MC-ZA-0808

MSSS 81 Elevation Flooding Evaluation

71111.06

Corrective Action

Documents

Condition Reports

21-00013, 21-00016, 21-00021, 20-03848, 20-16841, 19-

10684

71111.11Q Miscellaneous

NLR21S020201

Licensed Operator Training Simulator Scenario: LOCA /

Loss of Class Instrument / Rapid Downpower

2/24/2021

71111.12

Corrective Action

Documents

Condition Reports

20-15752, 20-15757, 20-15943, 20-15954, 20-16314

71111.12

Miscellaneous

20-15752-003

MRFF Evaluation

71111.12

Miscellaneous

20-15752-004

Level 3 Evaluation Report

71111.12

Miscellaneous

20-15757-003

MRFF Evaluation

71111.12

Miscellaneous

20-15757-004

Level 3 Evaluation Report

71111.12

Miscellaneous

Level 3

Evaluation Report

Maintenance Rule Expert Panel Meeting 633

2/04/2021

71111.12

Miscellaneous

SI-2503

Maintenance Rule (a)(1) Issue Tracking Form

71111.12

Procedures

70DP-0MR01

Maintenance Rule

71111.13

Corrective Action

Documents

Condition Reports

21-00853

71111.13

Miscellaneous

U1 MSIV RICT Projection Details

2/04/2021

71111.13

Miscellaneous

U1 MSIV Risk Management and Readiness Plan

2/03/2021

71111.13

Miscellaneous

EOOS 4.1

Weekly Schedulers Evaluation for PV Unit 3 Mar 8-14

2/17/2021,

03/8/2021

71111.13

Miscellaneous

EOOS 4.1

Weekly Schedulers Evaluation for PV Unit 3 Mar 22-28

03/25/2021

71111.13

Miscellaneous

Phoenix Risk

Monitor

WW 2112 Schedule Evaluation (3/22-28/2021)

03/23/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.13

Miscellaneous

Phoenix Risk

Monitor

WW 2110 Schedule Evaluation (3/8-14/2021)

2/17/2021,

03/8/2021

71111.13

Miscellaneous

RICT-U1-2021-01

Risk Informed Completion Time Summary

2/04/2021

71111.13

Miscellaneous

Risk Challenge

Meeting

Risk Challenge Meeting for U1 MSIV-171 Repair

2/03/2021

71111.13

Procedures

2DP-0RS01

Online Integrated Risk

71111.13

Procedures

40DP-9RS01

Operations Department Online Nuclear Risk Determination

in Modes 1 and 2

71111.13

Procedures

40DP-9RS03

Risk Management Actions

71111.13

Work Orders

5310300

71111.15

Corrective Action

Documents

Condition Reports

21-01818, 21-02855, 21-02888

71111.15

Miscellaneous

Updated Final Safety Analysis Report

20B

71111.15

Miscellaneous

21-01818-002

Engineering Evaluation

71111.15

Miscellaneous

EEQ-N007-001

Namco EA180 Limit Switches

71111.15

Procedures

40DP-9OP26

Operations Condition Reporting Process and Operability

71111.15

Procedures

40DP-9ZZ17

Control of Doors, Hatches, and Floor Plugs

71111.15

Procedures

73ST-9XI15

CP (Power Access Purge) Valves - Inservice Test

71111.15

Work Orders

5159840

71111.19

Procedures

2MT-9ZZ74

Molded Case Circuit Breaker Test

71111.19

Work Orders

5062359, 5202497

71111.22

Miscellaneous

Plant Review

Board

STRIDE PRB Approval Meeting for CEA Operability Checks

01/12/2021

71111.22

Procedures

01DP-0RS01

Surveillance Frequency Control Program

71111.22

Procedures

01DP-0RS02

Surveillance Test Risk Informed Documented Evaluation

(STRIDE) Process

71111.22

Procedures

70DP-0RA06

PRA Methodology for Evaluating Changes to Surveillance

Test Intervals

71111.22

Procedures

PVN-N-0034

STRIDE for One-Time Change for DEA Operability Checks

71114.01

Corrective Action

Documents

Condition Reports

19-03672, 19-03691, 19-05088, 19-08356, 19-13385, 19-

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

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

15510, 20-16537, 20-16863

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71114.01

Miscellaneous

2-05627

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2,

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

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

Information Regarding Implementation Details for the Phase

and 3 Mitigation Strategies

01/11/2007

71114.01

Procedures

16DP-0EP31

Emergency Preparedness Equipment Out of Service

71114.01

Procedures

40AO-9ZZ23

Loss of SFP Level or Cooling

71114.01

Procedures

40AO-9ZZ24

Deliberate Acts Against PVNGS

71114.01

Procedures

40MG-9ZZ05

Extensive Damage Mitigation Guidelines

71114.01

Procedures

40MG-9ZZ05-001

EDMG Command and Control

71114.01

Procedures

40MG-9ZZ05-002

Mitigating Guidelines Supplemental Strategies

71114.01

Procedures

40MG-9ZZ07

FLEX Support Guidelines

71114.01

Procedures

40MG-9ZZ07-001

FLEX Support Guidelines, Modes 1, 2, 3, or 4

71114.01

Procedures

EP-0900

Emergency Response Organization (ERO) Position

Checklists

71114.01

Procedures

EP-0901

Classifications

71114.01

Procedures

EP-0905

Protective Actions

71114.04

Miscellaneous

PVNGS Emergency Plan

67, 68

71114.04

Miscellaneous

Emergency Plan Evaluation - Medical Support During a

Public Health Emergency

2/17/2020

71114.04

Miscellaneous

20-001e

Emergency Plan Revision 67 Effectiveness Evaluation Form

05/05/2020

71114.04

Miscellaneous20-002s

Transitioning the Operations Advisor - STSC position to a

pooled position Screening Evaluation Form

03/17/2020

71114.04

Miscellaneous

20-003e

Emergency Plan Revision 68 Effectiveness Evaluation Form

2/16/2020

71114.04

Miscellaneous

20-003e,

Revision 1

Emergency Plan Revision 68 Effectiveness Evaluation Form

2/16/2020

71114.04

Miscellaneous20-003s

Emergency Plan Revision 67 Screening Evaluation Form

05/01/2020

71114.04

Miscellaneous20-004s

Emergency Plan Revision 68 Screening Evaluation Form

07/30/2020

71114.04

Miscellaneous20-005s

Update to the Palo Verde Emergency Planning Zone (EPZ)

population Screening Evaluation Form

2/10/2020

71114.08

Miscellaneous

1904 ERO Mini Drill - ERO Green Team (June 4, 2019);

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

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

10/29/2019

71114.08

Miscellaneous

1907 ERO Mini Drill - ERO Red Team (September 10,

10/23/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

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

24, 2019)

71114.08

Miscellaneous

1910 ERO Mini Drill Report - ERO White Team (December

10, 2019)

01/2/2020

71114.08

Miscellaneous

240-02859

CS/SW

1901 Full-Scale Dress Rehearsal - ERO Gold Team

(February 2019)

06/13/2019

71114.08

Procedures

EP-0905

Protective Actions

71124.05

Calibration

Records

WO 04908361

RU-143 Plant Ventilation Monitor, Low Range - Unit 3

2/19/2019

71124.05

Calibration

Records

WO 05091219

RU-143 Plant Ventilation Monitor, Low Range - Unit 3

06/25/2020

71124.05

Calibration

Records

WO 4904815

RU-143 Plant Ventilation Monitor, Low Range - Unit 2

01/03/2019

71124.05

Calibration

Records

WO 4906938

RU-143 Plant Ventilation Monitor, Low Range - Unit 1

01/03/2019

71124.05

Calibration

Records

WO 4925134

RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit

04/27/2018

71124.05

Calibration

Records

WO 4981791

RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit

2/12/2019

71124.05

Calibration

Records

WO 4981791

RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit

2/12/2019

71124.05

Calibration

Records

WO 5005338

RU-14 Radwaste Building Ventilation Exhaust Monitor - Unit

05/01/2020

71124.05

Calibration

Records

WO 5027206

RU-151 Radiation Monitor

10/26/2019

71124.05

Calibration

Records

WO 5027531

RU-141 Radiation Monitor

11/18/2019

71124.05

Calibration

Records

WO 5037715

RU-30 Radiation Monitor

11/12/2019

71124.05

Calibration

Records

WO 5074919

RU-157 Radiation Monitor

2/27/2020

71124.05

Calibration

Records

WO 5081319

RU-143 Plant Ventilation Monitor, Low Range - Unit 2

06/19/2020

71124.05

Calibration

WO 5085209

RU-143 Plant Ventilation Monitor, Low Range - Unit 1

06/22/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Records

71124.05

Calibration

Records

WO 5086713

RU-150 Radiation Monitor

04/09/2020

71124.05

Calibration

Records

WO 5111166

RU-145 Fuel Building B Ventilation Exhaust Monitor, Low

Range - Unit 3

07/15/2020

71124.05

Calibration

Records

WO 5111180

RU-146 Fuel Building B Ventilation Exhaust Monitor, High

Range - Unit 3

10/16/2020

71124.05

Calibration

Records

WO 5145645

RU-15 Waste Gas Area Combined Ventilation Exhaust

Monitor - Unit 1

09/22/2020

71124.05

Calibration

Records

WO 5151446

RU-1 Radiation Monitor

11/07/2020

71124.05

Calibration

Records

WO 5151451

RU-148 Radiation Monitor

11/12/2020

71124.05

Corrective Action

Documents

Condition Reports

19-00740, 19-01086, 19-02060, 19-02467,

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

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

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

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

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

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

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

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

71124.05

Miscellaneous

2018 Annual Radioactive Effluent Release Report

04/16/2019

71124.05

Miscellaneous

2019 Annual Radioactive Effluent Release Report

04/17/2020

71124.05

Miscellaneous

Offsite Dose Calculation Manual PVNGS Units 1, 2, and 3

71124.05

Miscellaneous

Portal Monitors (PM) and Personal Contamination Monitors

(PCM) Alarm Setpoints

01/05/2021

71124.05

Miscellaneous

Instrument Calibration Data Point Sheet

10/18/2020

71124.05

Miscellaneous

Unit 1 2019-2020 Inoperable Effluent Monitor Logs

2/31/2020

71124.05

Miscellaneous

Unit 2 2019-2020 Inoperable Effluent Monitor Logs

2/31/2020

71124.05

Miscellaneous

Unit 3 2019-2020 Inoperable Effluent Monitor Logs

2/31/2020

71124.05

Miscellaneous

Special Report 1-

SR-2019-001-00

Palo Verde Nuclear Generating Station (PVNGS) Unit 1,

Docket No. STN 50-528 /License No. NPF 51, Special

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

04/26/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

building ventilation system high range radioactive gaseous

effluent monitor for more than 7 days

71124.05

Procedures

74DP-0CH02

Analytical Instrument Quality Control (QC)

71124.05

Procedures

74RM-9EF43

Actions For Non-Functional Radiation Monitors: Preplanned

Alternate Sampling Program

71124.05

Procedures

74ST-9SQ10

Train "A" Radiation Monitoring Quarterly Functional Test

Procedure

71124.05

Procedures

74ST-9SQ20

RU-1 Calibration Test

71124.05

Procedures

74ST-9SQ21

Radiation Monitoring Calibration Test for Baseline Process

Monitors

71124.05

Procedures

74ST-9SQ22

Train "A" Radiation Monitoring Calibration Test for Baseline

Area Monitors

71124.05

Procedures

74ST-9SQ23

Train "A" Radiation Monitoring Calibration Test for

Containment New Scope Area Monitors

71124.05

Procedures

74ST-9SQ27

Radiation Monitoring Calibration Test for RU-144

71124.05

Procedures

75RP-9EQ13

Canberra Whole Body Counting System Calibration

71124.05

Procedures

75RP-9EQ22

Calibration of Counter Scalers

71124.05

Procedures

75RP-9EQ56

Calibration of the RO-2 and RO-20A Ion Chambers

71124.05

Procedures

75RP-9ME20

Canberra APEX - In Vivo Whole Body Counting System

Calibration

71124.05

Self-Assessments IPA-RP2020S1

Integrated Performance Assessment Report: Radiation

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

09/02/2020

71124.05

Self-Assessments SR-20-0021

NAD Surveillance Report: 2020 Radiation Safety

Performance Evaluation

07/23/2020

71124.05

Work Orders

5010217

74ST9SQ042 Effluent Monitor Monthly Source Checks Unit

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

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

Monitor

08/15/2019

71124.05

Work Orders

5010218

74ST9SQ043 Effluent Monitor Monthly Source Checks Unit

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

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

Monitor

08/15/2019

71124.05

Work Orders

5011137

74ST9SQ041 Effluent Monitor Monthly Source Checks Unit

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

08/15/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

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

Monitor

71124.05

Work Orders

5030412

74ST9SQ042 Effluent Monitor Monthly Source Checks Unit

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

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

Monitor

10/17/2019

71124.05

Work Orders

5030413

74ST9SQ043 Effluent Monitor Monthly Source Checks Unit

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

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

Monitor

10/21/2019

71124.05

Work Orders

5031145

74ST9SQ041 Effluent Monitor Monthly Source Checks Unit

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

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

Monitor

10/17/2019

71124.08

Corrective Action

Documents

Condition Reports

19-02590, 19-07431, 19-11705, 19-18567, 20-02759, 20-

2763, 20-14858

71124.08

Miscellaneous

December 2020 Radwaste Inventory

2/2/2020

71124.08

Miscellaneous

Waste /Material Characteristic Summary for Part 61 Waste

Stream Analysis - Unit 1 DAW - 2020

2/17/2020

71124.08

Miscellaneous

Waste /Material Characteristic Summary for Part 61 Waste

Stream Analysis - Unit 1 DAW - 2020

2/17/2020

71124.08

Miscellaneous

Waste /Material Characteristic Summary for Part 61 Waste

Stream Analysis - Unit 2 DAW -2020

05/12/2020

71124.08

Miscellaneous

Waste /Material Characteristic Summary for Part 61 Waste

Stream Analysis - Unit 1 Resin - 2020

05/14/2020

71124.08

Miscellaneous

Waste /Material Characteristic Summary for Part 61 Waste

Stream Analysis - Unit 2 Resin - 2020

2/09/2020

71124.08

Miscellaneous

75ST-9ZZ02

Radioactive Source Leak Test Surveillance Sheet

01/26/2020

71124.08

Miscellaneous

75ST-9ZZ02

Radioactive Source Leak Test Surveillance Sheet

01/15/2019

71124.08

Procedures

20DP-0SK77

Security Miscellaneous Testing

71124.08

Procedures

75RP-9RP09

Control of Vehicles, Equipment and Material

71124.08

Procedures

75RP-9RP15

Control and Storage of Radioactive Material and Radioactive

Wastes

71124.08

Procedures

76DP-0AP12

Low Level Radioactive Material Storage Facility Overview

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71124.08

Procedures

76DP-0RP02

Radioactive Waste Minimization Program Overview

71124.08

Procedures

76DP-0RP03

Radwaste Process Control Program

71124.08

Procedures

76DP-0RP05

Radwaste Control and Management Activities

71124.08

Procedures

76RP-0RW05

Packaging and Classification of Radioactive Waste

71124.08

Procedures

76RP-0RW06

Packaging of Radioactive Material

71124.08

Procedures

76RP-0RW07

Shipping Radioactive Materials

71124.08

Procedures

76RP-0RW08

High Integrity Container Receipt, Handling, Use, and

Closure

71124.08

Shipping Records 19-RW-018

Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08

Shipping Records 19-RW-023

Shipping paperwork package for the LSA-I concentrates

shipment

71124.08

Shipping Records 20-RW-012

Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08

Shipping Records 20-RW-031

Shipping paperwork package for the LSA-II dewatered resin

shipment

71124.08

Shipping Records 20-RW-034

Shipping paperwork package for the LSA-II dewatered resin

shipment

71151

Corrective Action

Documents

Condition Reports

20-01508, 20-01734, 20-07606, 20-08679

71151

Miscellaneous

NRC Performance Indicator Data; Emergency Preparedness

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

Quarter 2020

01/01/2020 -

2/31/2020

71151

Miscellaneous

NRC Performance Indicator Data; Emergency Preparedness

- ERO Readiness 1st Quarter 2020 - 4th Quarter 2020

01/01/2020 -

2/31/2020

71151

Miscellaneous

NRC Performance Indicator Data; Emergency Preparedness

- Alert and Notification System Reliability; 1st Quarter 2020

- 4th Quarter 2020

01/01/2020 -

2/31/2020

71153

Corrective Action

Documents

Condition Reports

21-02209