IR 05000528/2015004

NRC Integrated Inspection Report 05000528/2015004, 05000529/2015004, and 05000530/2015004

ML16039A065
Person / Time
Site:	Palo Verde
Issue date:	02/08/2016
From:	Troy Pruett, Sowa J NRC/RGN-IV/DRP/RPB-D
To:	Edington R Arizona Public Service Co
Hagar R
References
EA-15-158 IR 2015004
Download: ML16039A065 (55)

Text

February 8, 2016

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000528/2015004, 05000529/2015004, and 05000530/2015004

Dear Mr. Edington:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On January 7, 2015, the NRC inspectors discussed the results of this inspection with Mr. R. Bement and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

In this report, NRC inspectors documented one licensee-identified violation which was determined to be of very low safety significance and one licensee-identified Severity Level IV violation. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.

The inspectors also reviewed Licensee Event Report 05000530/2015-001-00 which reported a condition prohibited by technical specifications resulting from a leak in the reactor coolant pressure boundary on a Unit 3 reactor coolant pump 2A suction pipe instrument nozzle. The pressure boundary leakage was discovered while the unit was shut down for a refueling outage as licensee personnel performed a scheduled boric acid walk-down inspection of the Unit 3 reactor coolant system. The cause of the leak was determined to be primary water stress corrosion cracking of the alloy 600 instrument nozzle. The licensee corrected the condition by performing a half nozzle repair and obtained a relief request from the NRC for one cycle of operation. Inspectors concluded that it was not reasonable for Palo Verde Nuclear Generating Station staff to foresee and correct this condition prior to the discovery of the leak, and, therefore, did not identify an associated performance deficiency. The NRC determined that this issue was of very low safety significance. Based on these facts, I have been authorized, in consultation with the Director, Office of Enforcement, and the Regional Administrator, Region IV to exercise enforcement discretion in accordance with NRC Enforcement Policy Section 3.5.

Violations Involving Special Circumstances, and refrain from issuing enforcement for this violation.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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 Ryan Lantz Acting for/

Troy W. Pruett Director, Division of Reactor Projects

Docket Nos. 50 528, 50 529, 50 530 License Nos. NPF 41, NPF 51, NPF 74

Enclosures:

Inspection Report 05000528/2015004, 05000529/2015004, 05000530/2015004 w/ Attachment:

Supplemental Information

REGION IV==

Docket:

05000528, 05000529, 05000530 License:

NPF-41, NPF-51, NPF-74 Report:

05000528/2015004, 05000529/2015004, 05000530/2015004 Licensee:

Arizona Public Service Company Facility:

Palo Verde Nuclear Generating Station Location:

5801 South Wintersburg Road Tonopah, AZ 85354 Dates:

October 1 through December 31, 2015 Inspectors: C. Peabody, Senior Resident Inspector D. Reinert, PhD, Resident Inspector D. You, Resident Inspector L. Carson, Senior. Health Physicist P. Elkmann, Senior Emergency Preparedness Inspector J. Kirkland, Senior Operations Engineer J. Braisted, Reactor Inspector L. Brandt, Project Engineer M. Brooks, Physical Security Inspector C. Cowdrey, Operations Engineer G. Guerra, CHP, Emergency Preparedness Inspector P. Jayroe, Reactor Inspector J. Melfi, Project Engineer N. Okonkwo, Reactor Inspector C. Smith, Reactor Inspector Approved By:

Ryan E. Lantz, Acting for Troy W. Pruett, Director Division of Reactor Projects

- 2 -

SUMMARY

IR 05000528, 529, 530/2015004; 10/01/2015 - 12/31/2015; (Palo Verde Nuclear Generating

Station) Follow-up of Events and Notices of Enforcement Discretion.

The inspection activities described in this report were performed between October 1 and December 31, 2015, by the resident inspectors at Palo Verde Nuclear Generating Station and inspectors from the NRCs Region IV office and other NRC offices. NRC inspectors documented in this report one licensee-identified violation of very low safety significance and one licensee-identified Severity Level IV violation. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas.

Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Licensee-Identified Violations

One violation of very low safety significance (Green) and one violation of Severity Level IV were identified by the licensee and have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

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

Unit 2 entered the inspection period at full power and was shutdown for refueling on October 10, 2015. Unit 2 restarted from their refueling outage on November 14, 2015, and returned to full power. On November 27-28, 2015, power was reduced to 83 percent following the failure of a heater drain pump discharge valve. Unit 2 operated at full power for the remainder of the inspection period.

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

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

• October 27, 2015, Unit 2 spent fuel cooling system trains A and B

• November 17, 2015, Unit 1 containment spray train A

• December 22, 2015, Unit 2 A emergency diesel generator during electrical breaker testing for the B emergency diesel generator The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On November 19, 2015, the inspectors performed a complete system walk-down inspection of the Unit 2 containment purge system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

• October 21, 2015, Unit 3 main control room, Fire Zone 17

• November 2, 2015, Unit 1 4kV switchgear room train A, Fire Zone 5A

• November 17, 2015, Unit 3 auxiliary feedwater pump rooms, Fire Zone 72 and 73

• November 18, 2015, Unit 2 class battery rooms train A and C, Fire Zone 8A and 9A For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

.2 Annual Inspection

a. Inspection Scope

On November 17, 2015, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an unannounced fire drill for quarterly proficiency on November 16, 2015.

During these drills, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On October 16, 2015, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose a plant area containing risk-significant structures, systems, and components that were susceptible to flooding:

• Units 1, 2, and 3 emergency diesel generator rooms

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constitute completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:

• Unit 1 shutdown cooling heat exchanger train B

• Unit 1 spray pond heat sink train A

• Unit 2 diesel jacket water heat exchanger train A

• Unit 3 essential cooling water heat exchanger train A

The inspectors verified whether testing, inspection, maintenance, and chemistry control programs are adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, utilized proper industry heat exchanger guidance. Additionally, the inspectors verified that the licensees chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensees heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four triennial heat sink inspection samples as defined in Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

Sections

.1 through.5, below constitute completion of one sample as defined in

Inspection Procedure 71111.08

.1 Non-destructive Examination (NDE) Activities and Welding Activities

a. Inspection Scope

The inspectors observed six nondestructive examination activities and reviewed 10 nondestructive examination activities that included three types of examinations. The licensee did not identify any relevant indications accepted for continued service during the nondestructive examinations.

The inspectors directly observed the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Safety Injection Pipe to Elbow, 2-022-014 Dye Penetrant Reactor Vessel Bottom Mounted Instrumentation Nozzles (1-61)

Visual Safety Injection 2PSIEL176, Report 15-1089 Radiography Safety Injection 2PSIEL176, Report 15-1090 Radiography Steam Generator 15-MT-2013, 2-065-017 Magnetic Particle Reactor Vessel Reactor Vessel Upper Head nozzles 1 - 97 Visual

The inspectors reviewed records for the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Steam Generator 15-UTE-2052, Nozzle to Vessel Ultrasonic Steam Generator 15-UTE-2053, Nozzle to Vessel Ultrasonic Steam Generator 15-UTE-2054, Nozzle to Vessel Inner Radius Ultrasonic Steam Generator 15-UTE-2055, Nozzle to Vessel Inner Radius Ultrasonic Steam Generator 15-UTE-2058, Tubesheet to Head Ultrasonic Safety Injection VE-15-003, 1A Safety Injection Phased Array Ultrasonic Safety Injection VE-15-004, 1B Safety Injection Phased Array Ultrasonic Safety Injection VE-15-005, 2A Safety Injection Phased Array Ultrasonic Safety Injection VE-15-006, 2B Safety Injection Phased Array Ultrasonic Reactor Coolant 15-1008 2A RCP Suction Instrumentation Nozzle Bare Metal Visual

During the review and observation of each examination, the inspectors verified that activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also verified the qualifications of all nondestructive examination technicians performing the inspections were current.

The inspectors directly observed a portion of the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Instrument Air 4201037-1 and 4201037-2 shielded-metal arc weld Flex Mod to RCS 4418137-30 gas-tungsten arc weld

The inspectors verified that the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX, requirements. The inspectors also verified that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications. Specific documents reviewed during this inspection are listed in the attachment.

b. Findings

No findings were identified.

.2 Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

No vessel upper head inspection was required during this refueling outage, however, the licensee identified boric acid on top of the reactor vessel head, dripping down from a graylock-hub connection associated with the heated junction thermocouple train B. The inspectors reviewed the results of the licensees bare metal visual inspection of the reactor vessel upper head penetrations to determine whether the licensee identified any evidence of boric acid challenging the structural integrity of the reactor head components and attachments. The inspectors also verified that the required inspection coverage was achieved and limitations were properly recorded.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control Inspection Activities

a. Inspection Scope

The inspectors evaluated the implementation of the licensees boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walkdown as specified in Procedure 73DP-9ZC01, Boric Acid Corrosion Control Program, Revision 7, and Procedure 70TI-9ZC01, Boric Acid Walkdown Leak Detection, Revision 18. The inspectors verified that the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and that engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors confirmed that corrective actions taken were consistent with the ASME Code, and 10 CFR 50, Appendix B requirements. Specific documents reviewed during this inspection are listed in the attachment.

b. Findings

No findings were identified.

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

No eddy current inspections were required or planned for refueling outage U2R19.

However, due to previous concerns with foreign objects in the steam generators, the licensee initiated Foreign Object Search and Retrieval (FOSAR) inspections on both Steam Generators. The licensee defines a classification system for foreign objects to determine where retrieval efforts should be applied if foreign material is discovered in the steam generator. Category 1 items are foreign objects that experience or analysis could be expected to cause tube wear to exceed 50 percent through wall in one or two operating cycles. The following areas were inspected:

• Hot and cold leg top of tubesheet annulus region (approximately 5 tube rows into the bundle were viewed from the annulus.

• Hot and cold leg blowdown lanes (approximately 2 rows deep were viewed from the lane).

The FOSAR inspection results for Category I items were as follows:

• One foreign object in Steam Generator 21, which was removed.

• Two items were identified as foreign objects in Steam Generator 22, both of which were removed.

The licensee determined, due to lack of object wear marks found on either the foreign objects or on tubes in the vicinity of the removed objects, than no eddy current examinations were required. Other foreign objects identified in the steam generators are not expected to cause tube damage.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems

a. Inspection scope

The inspectors reviewed 18 condition reports which dealt with inservice inspection activities and found the corrective actions were appropriate. From this review the inspectors concluded that the licensee has an appropriate threshold for entering issues into the corrective action program and has procedures that direct a root cause evaluation when necessary. The inspectors also determined the licensee had an effective program for applying industry operating experience. Specific documents reviewed during this inspection are listed in the attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On November 23, 2015, the inspectors observed a portion of an annual requalification test for licensed operators. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity. The inspectors observed the operators performance of the following activities:

• October 9, 2015, Unit 2 shutdown for planned refueling outage

• November 9, 2015, Unit 2 notice of unusual event for a fire alarm in containment

In addition, the inspectors assessed the operators adherence to plant procedures, including Conduct of Shift Operations and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Review of Requalification Examination Results

a. Inspection Scope

The inspector conducted an in-office review of the annual requalification training program to determine the results of this program.

On December 18, 2015, the licensee informed the inspector of the following Palo Verde Units 1, 2, and 3 operating test results:

• 21 of 21 crews passed the simulator portion of the operating test

• 109 of 109 licensed operators passed the simulator portion of the operating test

• 109 of 109 licensed operators passed the job performance measure (JPM)portion of the operating test

• One reactor operator and one senior reactor operator have not yet been tested due to short term disabilities and will be tested separately prior to returning to licensed duties

No remediation was performed for any operating examination.

The inspector completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

.4 Biennial Review of Requalification Program

a. Inspection Scope

Every year, either an annual review or a biennial review is performed on the licensed operator requalification program. For this year, an annual review was completed and the biennial review was not performed. See the Annual Review Section for details on the licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):

• December 11, 2015, Unit 2 containment airlock, extended a(1) monitoring due to additional test failures

• December 10, 2015, Non-class 1E 480V, a(2) routine monitoring

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

• October 16, 2015, Unit 2 night shift shutdown safety function assessment yellow risk management action levels for reactivity control and spent fuel pool decay heat removal

• October 19, 2015, Unit 3 online weekly risk assessment

• October 28, 2015, Unit 2 day shift shutdown safety function assessment for the reactor vessel head removed and reactor coolant system above reactor vessel flange The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

These activities constitute completion of three maintenance risk assessment inspection samples, as defined in Inspection Procedure 71111.13

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed seven operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):

• October 15, 2015, Unit 2 operability determination of vital electrical busses during essential ventilation outage

• October 21, 2015, Unit 3 operability determination of containment sump water level (wide range) train A following a change in water level trends

• November 13, 2015, Unit 3 operator work around for spent fuel pool local temperature alarm failure

• November 23, 2015, Unit 2 operator work around for two low pressurizer pressure setpoint reset switch not lowering pressure when operated

• December 9, 2015, Unit 3 operability determination of safety injection tank 2A fill and drain valve failure to meet stroke time criteria

• December 10, 2015, Unit 1, 2, and 3 operability determination of reactor coolant system piping loads due to updated analysis in support of next generation fuel

• December 22, 2015, Unit 2 operability determination for containment spray pump motor space heater failing to energize The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.

These activities constitute completion of seven operability and functionality review samples, which included two operator work-around samples, as defined in Inspection Procedure 71111.15

b. Findings

No findings were identified.

1R18 Plant Modifications

Temporary Modifications

a. Inspection Scope

On October 31, 2015, the inspectors reviewed a temporary modification to the Unit 2 refueling machine to support removal of a damaged fuel assembly.

The inspectors verified that the licensee had installed and removed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant structures, systems, or components (SSCs):

• October 20, 2015, Unit 2 essential spray pond train B pump post maintenance test following cable replacement

• October 24, 2015, Unit 2 containment sump isolation train B valve SIB-UV-675 post maintenance test following valve actuator refurbishment

• November 23, 2015, Unit 2 channel C log power post maintenance test following repair and troubleshooting of the channel failing low

• December 10, 2015, Station blackout generator 1 post maintenance test after planned maintenance The inspectors reviewed licensing-and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the Unit 2 refueling outage that concluded on November 14, 2015, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

• Review of the licensees outage plan prior to the outage

• Review and verification of the licensees fatigue management activities

• Monitoring of shut-down and cool-down activities

• Verification that the licensee maintained defense-in-depth during outage activities

• Observation and review of reduced-inventory and mid-loop activities

• Observation and review of fuel handling activities

• Monitoring of heat-up and startup activities

These activities constitute completion of one refueling outage sample, as defined in Inspection Procedure 71111.20

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed three risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:

Containment isolation valve surveillance tests:

• October 26, 2015, Unit 2 containment penetration 9 leak test

• November 10, 2011, Unit 2 containment integrated leak rate test

Other surveillance tests:

• December 11, 2015, Unit 2 control element assembly operability test

The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of three surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspectors performed in-office reviews of Palo Verde Nuclear Generating Station Emergency Plan, Revision 55, and Procedure EP-0905, Protective Actions, Revision 7; and an on-site review of changes to Procedure EP-0900, Emergency Response Organization Position Checklists, Revision 12. These revisions:

• deleted a shelter-in-place protective action recommendation within a two mile radius of the plant at a site area emergency classification;

• provided additional details about conducting sweeps in the owner-controlled-area as part of the evacuation of non-essential personnel from site;

• specified the liaisons dispatched to an Incident Command Post when one is established;

• provided additional details about how to call out the emergency response organization to alternate emergency response facilities;

• provided guidance to contact the Buckeye, Arizona, police department to provide security at the Emergency Operations Facility/Joint Information Center; and

• made other administrative changes.

These revisions were compared to their previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that the revisions did not reduce the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.

These activities constitute completion of three emergency action level and emergency plan change samples as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP7 Exercise Evaluation - Hostile Action Event

a. Inspection Scope

The inspectors observed the September 16, 2015, biennial emergency plan exercise to verify the exercise acceptably tested the major elements of the emergency plan, provided opportunities for the emergency response organization to demonstrate key skills and functions, and demonstrated the licensees ability to coordinate with offsite emergency responders. The scenario simulated:

• an explosion at the security owner controller access checkpoint;

• an armed land-based attack against the protected area;

• explosives placed at the station blackout generators;

• a complete loss of offsite power to the station;

• a Unit 1 diesel generator failure; and

• injured and deceased plant employees.

The simulations were performed to demonstrate the licensees capability to implement its emergency plan under conditions of uncertain physical security.

During the exercise the inspectors observed activities in the Control Room Simulator and the following emergency response facilities:

• Alternate Technical Support Center

• Alternate Operations Support Center

• Emergency Operations Facility

• Central Alarm Station

• Incident Command Post

• Joint Information Center

The inspectors focused their evaluation of the licensees performance on event classification, offsite notification, recognition of offsite dose consequences, development of protective action recommendations, staffing of alternate emergency response facilities, and the coordination between the licensee and offsite agencies to ensure reactor safety under conditions of uncertain physical security.

The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision-making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of plant employees and emergency workers in an uncertain physical security environment, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensees primary and alternate emergency response facilities, and procedures for the performance of associated emergency and security functions.

The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management.

The specific documents reviewed during this inspection are listed in the attachment.

The inspectors reviewed the scenarios of the 2011 and 2013 biennial exercises and the scenarios of licensee drills conducted between January 2013 and August 2015 to determine whether the September 16, 2015, exercise was independent and avoided participant preconditioning, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(g). The inspectors also compared observed exercise performance with corrective action program entries and after-action reports for drills and exercises conducted January 2013 and August 2015 to determine whether identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14), and 10 CFR 50, Appendix E, IV.F.

These activities constituted completion of one exercise evaluation sample as defined in Inspection Procedure 71114.07.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the September 16, 2015, biennial exercise to the NRC on December 18, 2014, in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(b). The biennial exercise had been rescheduled from March 4, 2015. The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan and provide opportunities for the emergency response organization to demonstrate key skills and functions.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee:

(1) to monitor areas, materials, and workers to ensure a radiologically safe work environment, and

(2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

• Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

• Selected instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection

These activities constitute completion of one sample of radiation monitoring instrumentation as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2014 through September 30, 2015, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for heat removal systems for Units 1, 2, and 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2014 through September 30, 2015 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for residual heat removal systems for Units 1, 2, and 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of October 1, 2014, through September 30, 2015, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for cooling water support systems Units 1, 2, and 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors reviewed the licensees evaluated exercises and selected drill and training evolutions that occurred between January 2014 and June 2015, to verify the accuracy of the licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and PARs to verify their timeliness and accuracy. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the drill/exercise performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training evolutions between January 2014 and June 2015 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.

The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors reviewed the licensees records of alert and notification system tests conducted between January 2014 and June 2015 to verify the accuracy of the licensees data for siren system testing opportunities. The inspectors reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the alert and notification system reliability performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors reviewed corrective action program documentation associated with the following licensee-identified trend:

• From mid-2013 to mid-2015, the licensee experienced an increase in inadequate maintenance activities requiring rework. Inadequate work practices have resulted in exceeding Limiting Condition of Operation (LCO) durations and have challenged equipment reliability [CR 15-09661-004].

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments For the declining trend involving inadequate maintenance requiring rework, the licensee performed a high level review of data over a two year period to determine if a common cause beyond those identified in the event-specific causal analyses could be identified.

The evaluation examined 21 maintenance related events occurring during the past two years. Fifteen of the events were attributed to procedures or instructions that were either unclear or not technically accurate. The corrective actions for six of the events required additional steps to be added to the maintenance instructions.

The licensees evaluation concluded that the increase in the level of detail required in work instructions indicates a change in the knowledge and experience level of their maintenance work force. The licensees data also indicated that human performance error rates tend to decrease and performance improves when front line supervisors spend time in the field with workers. However, the licensee also noted that their maintenance department currently has a large population of front line supervisors with limited leadership experience.

The licensee recognized the need to ensure that the level of detail in work instructions is regularly monitored and re-evaluated as the experience level within the maintenance shops changes. The licensee has issued action items to ensure that a post-job critique is conducted when work is performed on safety-related equipment, and to update the station rework procedure to provide clear guidance for when and how to conduct a human performance evaluation for maintenance requiring rework.

The licensee also revised their maintenance department procedure addressing front line supervisor observation and mentoring activities to ensure that front line supervisors take into consideration individual worker capabilities such as a lack of proficiency or experience when determining which tasks to observe. The licensee will also update this procedure to require maintenance leadership to identify potential high-consequence activities during the work planning process and to name an observer to be present for those targeted high-consequence maintenance activities.

The inspectors considered that in response to this trend, the licensee had completed an appropriate evaluation and had developed appropriate corrective actions.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

On October 13, 2015, the inspectors selected for follow-up the issue of the reliablility of continuously energized ARD relays.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to ensure that discrepancies in the manufacturing process will not adversely affect the performance of safety related equipment.

This activity constitutes completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

These activities constitute completion of four event follow-up samples, as defined in Inspection Procedure 71153.

.1 NRC Event Number 51522:

Notice of Unusual Event Due to Containment Fire Alarm On November 9, 2015, at 5:33 a.m. Mountain Standard Time (MST), Palo Verde Unit 2 received a containment fire alarm in Fire Zone 63B (Steam Generator 2) while pressurizing containment for integrated leak rate testing (ILRT) in Mode 5. Control room operators noted that containment temperature and pressure were 72 degrees Farenheit and 13 psig, respectively. Personnel were unable to enter containment to validate the fire alarm since containment pressure was greater than 0.5 psig. As a result the station declared an Unusual Event (HU2.1) at 5:47 a.m. MST for a fire in containment which was unable to be validated within 15 minutes of receipt. No safety functions were impacted due to the fire alarm. No automatic or manual RPS or ESF actuations occurred and none were required. Containment was entered at 8:17 a.m. MST following depressurization. Licensee inspection of containment and Fire Zone 63B identified no indication of fire or smoke. The fire alarm was determined to be invalid. The Unusual Event was terminated on November 9, 2015, at 9:01 a.m. MST. The inspectors responded to the control room to verify that the information provided by the Emergency Notification System (ENS) communicator was complete and accurate and no further Agency response was warranted. When licensee personnel entered containment after depressurization, no evidence of combustion was identified. Further reviews of the Technical Requirements Manual revealed a note indicating that the fire alarms inside containment should be bypassed during ILRT sequences, because the higher pressure, more dense air inside containment can disrupt the detectors monitoring stream in a manner similar to smoke particulates. The ILRT was reperformed satisfactorily with the fire alarms in bypass.

.2 (Closed) Licensee Event Report 05000530/2015-001-00, Leakage From Reactor

Coolant Pump 2A Suction Pipe Instrument Nozzle (Closed) Unresolved Item (URI)05000530/2015002-04, TAC Number MF6276 - NOED Number 15-4-01. Notice of Enforcement Discretion of Technical Specification 3.5.3 Emergency Core Cooling System - Operating Conditions B and C On April 7, 2015, during the Unit 3 Refueling Outage 18, the licensee discovered reactor coolant system pressure boundary leakage at instrument nozzle 18 on the 2A reactor coolant pump suction piping. The leakage was discovered during a planned visual inspection of Unit 3 hot and cold leg nozzles. Isotopic analysis of the leak deposits indicated that the leak had occurred between 6 and 10 months prior to discovery. The leak was not detectable while the unit was operating either by the licensee's reactor coolant system leak rate determination procedure or by containment atmospheric radiation monitor trend reviews. The leak was not detectable visually during the previous refueling outage. Visual evidence of the leakage was consistent with a small leak of short duration with no popcorn buildup of boric acid at the leakage site. The licensee determined that the cause of the leakage was primary water stress corrosion cracking of the alloy 600 instrument nozzle. The licensee corrected the leakage using a half nozzle repair method and installed a new alloy 690 nozzle with alloy 52M weld material. After completing the repair, the licensee submitted a relief request to allow operation with uncharacterized flaws in the remnant j-groove weld and nozzle left in place after the half nozzle repair. The relief request was for operation through the end of refueling cycle 3R19.

The inspectors reviewed the circumstances surrounding the discovery of the leak, observed portions of the repair activity during the refueling outage, and reviewed the licensees apparent cause evaluation of the leak. The inspectors determined that reactor coolant system boundary leakage is a Severity Level IV violation of Limiting Condition of Operation (LCO) 3.4.14.a which requires that reactor coolant system operational leakage shall be limited to no pressure boundary leakage. If pressure boundary leakage exists, required action 3.4.14.B requires the licensee to place the unit in operational Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and within operational Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Based on a review of the event, the inspectors concluded that the leakage existed for a period that began on an unknown date that was more than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> before April 4, 2015, and ended when the reactor shut down on April 4, 2015. The reactor coolant system operational leakage was not limited to no pressure boundary leakage, and the licensee did not place the unit in operational Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and within operational Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The issue was evaluated using the traditional enforcement process because no performance deficiency was associated with the violation of NRC requirements.

Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Section 0612-09, states, in part, that such violations are dispositioned using traditional enforcement and may warrant enforcement discretion. The inspectors reviewed NRC Enforcement Policy, Section 6.1 (Reactor Operations) to evaluate the significance of this violation. This violation was more-than-minor and best characterized as Severity Level IV (very low safety significance) because it is similar to the example in the NRC Enforcement Policy, Section 6.1.d.1. Additionally, a qualitative assessment of the observed reactor coolant system leakage condition concluded the risk was of very low safety significance (Green).

The basis for this qualitative risk determination was that the leakage rate was very small with little boron residue accumulation and no appreciable accumulation on nearby components. Any leakage was within the capability of reactor coolant system makeup systems.

The NRC is exercising enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and not issuing an enforcement action for the violation of Technical Specification 3.4.14.a (EA-15-158) for the following reasons: this issue is of very low safety significance (Green); the NRC determined that this issue was not within the licensees ability to foresee and correct; the licensee's actions did not contribute to the degraded condition, and; the actions taken were reasonable to identify and address this matter. Further, because the licensees actions did not contribute to this violation, it will not be considered in the assessment process or the NRCs Action Matrix. Specific documents reviewed during this inspection are listed in the attachment.

Licensee Event Report 05000530/2015-001-00 is closed.

Unresolved item 05000530/2015002-04 is closed.

.3 (Closed) Licensee Event Report 05000530/2015-002-00, Condition Prohibited by

Technical Specification 3.0.4 Due to an Inoperable Atmospheric Dump Valve (ADV)

On May 2, 2015, following completion of refueling activities, Unit 3 commenced testing of atmospheric dump valves (ADVs). Testing determined that ADV 178 would not stroke more than 13 percent open. Operators declared ADV 178 inoperable and entered LCO 3.7.4 Condition A. The licensee determined that ADV 178 had been inoperable when Unit 3 entered Mode 4 and continued to Mode 3, and issued the licensee event report to report a condition prohibited by Technical Specifications.

The licensee determined that internal piston rings were improperly re-assembled during maintenance performed during the refueling outage. The licensee concluded the apparent cause of the incorrect piston ring installation was human error by maintenance personnel and inadequate procedure instructions. To prevent recurrence, the licensee initiated actions to provide detailed guidance on the proper orientation of the piston rings and to require verifications of proper re-assembly.

The inspectors reviewed the licensee event report and documented a licensee-identified violation in Section 4OA7 of this report.

Licensee event report 05000530/2015-002-00 is closed.

.4 (Closed) Licensee Event Report (LER) 05000530/2015-003-00, Damaged High Pressure

Safety Injection Pump Motor Journal Bearing On May 30, 2015, emergent maintenance on the Unit 3 train A high pressure safety injection (HPSI) pump motor outboard journal bearing performed under Nuclear Regulatory Commission (NRC) approved Notice Of Enforcement Discretion 15-4-01 exceeded the Technical Specification Limiting Condition for Operation (LCO) completion time for LCO 3.5.3, Emergency Core Cooling Systems - Operating, Condition C.1. The high pressure safety inspection (HPSI) pump A had been removed from service on May 27, 2015, at 6:28 a.m., for planned routine maintenance. During maintenance, it was discovered that the motor outboard journal bearing was damaged. The bearing was replaced and the pump was declared operable on May 30, 2015, at 5:10 p.m.

The root cause was work instruction weaknesses which resulted in improper reassembly of the HPSI pump motor during planned maintenance in the Unit 3 spring 2015 refueling outage. Immediate corrective actions replaced the damaged outboard motor bearing and properly reassembled the pump and motor. To prevent recurrence, the licensee plans to revise maintenance procedures to provide enhanced guidance for pump and motor reassembly.

The licensee notified the inspectors about the issue shortly after the condition was discovered. The inspectors visually examined the failed journal bearing and interviewed maintenance personnel and a vendor representative regarding the physical configuration and sequence of events that led to damage and how the replacement bearing when properly installed would have adequate clearances to function as designed. When the licensee was preparing to request a NOED, the inspectors walked down the risk-management actions associated with the corresponding risk assessment, which included pre-staging certain diverse and flexible (FLEX) mitigating equipment that are capable of performing the safety-injection function in the event of a primary LOCA. The NRC granted the NOED, and while the NOED was in effect the inspectors regularly monitored the progress of the repairs through interactions with the control room and work control center staff. The inspectors reviewed the post-maintenance testing documentation that returned the pump to service. Following the event, the inspectors reviewed the cause evaluations and other corrective action documentation, including the vendors post-mortem evaluation of the failed journal bearing.

No findings or violations of NRC requirements were identified.

Licensee event report 05000530/2015-003-00 is closed.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On February 6, 2015, the inspectors discussed the in-office review of the preliminary scenario for the March 4, 2015, biennial exercise, submitted December 18, 2014, with Mr. J. Fearn, Manager, Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented. The March 4, 2015, biennial exercise was subsequently rescheduled to September 16, 2015.

On October 2, 2015, the inspectors presented the results of the onsite and in-office inspection of the biennial emergency preparedness exercise conducted September 16, 2015, including the results of the in-office inspection of changes to the licensees emergency plan and implementing procedures, to Mr. R. Edington, Chief Nuclear Officer, and other members of the licensee staff.

The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On October 23, 2015, the inspectors presented the inspection results to Mr. R. Bement, Senior Vice President, Nuclear Operations and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On October 30, 2015, the inspector presented the radiation safety inspection results to Mr. G. Andrews, Director, Nuclear Regulatory Affairs, and other members of the licensee staff.

The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On November 19, 2015, the inspectors presented the final inspection results to Mr. J. Cadogan, Vice President of Nuclear Engineering, Ms. M. Lacal, Vice President of Regulatory Oversight, Mr. M. McLaughlin, General Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On December 22, 2015, the inspector briefed Mr. G. Andrews and other members of the licensee's staff of the results of the licensed operator requalification program inspection. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On January 7, 2016, the inspectors presented the inspection results to Mr. R. Bement and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA7 Licensee-Identified Violations

Listed below is one violation of very low safety significance (Green) and one violation of Severity Level IV that were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.

• Technical Specification 3.0.4 requires, in part, that when an LCO is not met, entry into a mode or other specified condition in the applicability shall only be made when the associated actions in the mode permit continued operation; a risk assessment is performed and accepted for the inoperable components; or when an allowance is stated.

Technical Specification 3.7.4, Atmospheric Dump Valves, requires that four ADV lines shall be operable in Modes 1, 2, 3, and 4 when the steam generator is relied upon for heat removal. Contrary to the above, on May 1, 2015, Unit 3 operators entered a mode with an LCO not met. Specifically, one atmospheric dump valve line was not operable as required by Technical Specification 3.7.4 prior to entering Mode 3.

The licensees investigation concluded that the valve failure was a result of inadequate reassembly following maintenance. The licensee reported this condition in Licensee Event Report 05000530/2015-002-00 as a condition prohibited by Technical Specifications due to entering a mode in the applicability of LCO 3.7.4 while the LCO was not met.

The inspectors concluded that the finding is of very low safety-significance (Green)because it was not a design or qualification deficiency, did not result in a loss of safety function, did not result in a loss of function of a train of safety equipment out greater than its allowed outage time, or a loss of function of high importance maintenance rule equipment greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee has entered the issue in the corrective action program as CRDR 4654422.

• Title 10 CFR 55.49, Integrity of examinations and tests, requires, in part, that facility licensees shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. Contrary to the above, during the week of November 9, 2015, the licensee caused a compromise of examination integrity when two licensed operators, who had previously validated portions of the 2015 annual operating test and had signed the examination security agreement, administered emergency preparedness (EP) job performance measures (JPMs) to a total of three licensed operators who had not yet taken their annual operating test. Specifically, the two licensed operators validated and/or approved simulator scenarios and EP JPMs for the annual operating test and then subsequently administered JPMs to three other licensed operators for the purpose of supporting EP program indicators. If not for detection, this activity could have affected the equitable and consistent administration of the annual operating examination.

The failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process because it impacted the ability of the NRC to perform its regulatory oversight function. This resulted in assignment of a Severity Level IV violation because it involved a nonwillful compromise of examination integrity and is consistent with Section 6.4.d of the NRC Enforcement Policy.

The associated performance deficiency was screened as Green because it had no actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59, Requalification. The licensee entered this issue into their corrective action program as Condition Report 15-10910.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

N. AaronsCooke, Nuclear Regulatory Affairs

J. Allison, Examination and Simulator Group Section Leader

G. Andrews, Director, Nuclear Regulatory Assurance

R. Bement, Senior Vice President, Nuclear Operations

D. Bence, Manager, Operations

R. Black, Engineer, RMS Systems

B. Bolf, Section Leader, Engineering

P. Bury, Director, Nuclear Training

J. Cadogan, Vice President, Engineering

R. Carbunneau, Department Leader, Nuclear Assurance

C. Coles, Department Leader, Security

R. Davis, Director, Emergency Preparedness

E. Dutton, Director, Nuclear Assurance

R. Eddington, Chief Nuclear Officer

M. Fallon, Director, Communications

J. Fearn, Manager, Emergency Preparedness

Z. Goldwasser, Operations Training Manager (Acting)

T. Gray, Superintendent, Radiation Protection Technical Support

K. Graham, Assistant Plant Manager, Operations

R. Harley, Program Engineer, Heat Exchangers

D. Heckman, Senior Compliance Consultant, Regulatory Affairs

J. Jenkins, System Engineer, Spray Pond and Essential Cooling Water

G. Jones, Supervisor, Radiation Protection

M. Karbassian, Director, Engineering

C. Kharrl, General Plant Manager, Operations

M. Lacal, Vice President, Operations Support

S. Lantz, Dosimetry Section Leader, Radiation Protection

T. Marco, Director, Human Relations

M. McGhee, Department Leader, Nuclear Regulatory Assurance

M. McLaughlin, General Plant Manager, Operations Support

M. Meyer, Design Engineer, Civil

D. Mims, Senior Vice President, Nuclear Regulatory Affairs and Oversight

C. Moeller, Director, Technical Support (Acting)

R. ONeal, Senior Technician, Radiation Protection

F. Oreshac, Consultant, Regulatory Affairs

R. Quick, Examination Developer

R. Routollo, Manager, Radiation Protection (Acting)

G. Sowers, Leader, RMS Systems

B. Thiele, Department Leader, Engineering

R. Vega, Design Engineer, Mechanical

J. Waid, Director, Executive Projects

T. Weber, Department Leader, Nuclear Regulatory Affairs

NRC Personnel

C. Peabody, Sr. Resident Inspector

D. Reinert, Resident Inspector

D. You, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000530/2015-001-00 LER Leakage From Reactor Pump 2A Suction Pipe Instrument Nozzle (Section 4OA3.2)

05000530/2015-002-00 LER Condition Prohibited by Technical Specification 3.0.4 Due to an Inoperable Atmospheric Dump Valve (ADV) (Section 4OA3.3)

05000530/2015-003-00 LER Damaged High Pressure Safety Injection Pump Motor Journal Bearing (Section 4OA3.4)

05000530/2015002-04 URI Notice of Enforcement Discretion of Technical Specification 3.5.3 Emergency Core Cooling System - Operating Conditions B and C (Section 4OA3.2)