ML19098A187

NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAIs from Irab for Framatome Htp Fuel LAR and Exemption (EPIDs L-2018-LLA-0194 and L-2018-LLE-0010)

ML19098A187
Person / Time
Site:	Palo Verde
Issue date:	04/05/2019
From:	Siva Lingam Plant Licensing Branch IV
To:	Cox M Arizona Public Service Co
References
L-2018-LLA-0194, L-2018-LLE-0010
Download: ML19098A187 (4)

Text

NRR-DMPSPEm Resource From: Lingam, Siva Sent: Friday, April 5, 2019 2:43 PM To: Matthew.Cox@aps.com Cc: Pascarelli, Robert; Bowman, Gregory; Huckabay, Victoria; O'Banion (Watford), Margaret; Wengert, Thomas; Michael.Dilorenzo@aps.com; Thomas.N.Weber@aps.com

Subject:

Palo Verde 1, 2, and 3 - Official RAIs from IRAB for Framatome HTP Fuel LAR and Exemption (EPIDs L-2018-LLA-0194 and L-2018-LLE-0010)

By letter dated July 6, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18187A417), as supplemented by letters dated October 18, 2018 and March 1, 2019 (ADAMS Accession Nos. ML18296A466 and ML19060A298, respectively), Arizona Public Service (APS, the licensee) submitted a License Amendment Request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) proposing Technical Specification (TS) changes to support the implementation of Framatome Advanced Combustion Engineering 16x16 (CE-16) High Thermal Performance (HTPTM) fuel design with M5 as a fuel rod cladding material and gadolinia as a burnable absorber for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3. The Reactor Assessment and Human Factors Branch (IRAB) staff has reviewed the human performance aspects of this submittal and determined that additional information is needed to complete its review.

We transmitted the draft requests for additional information (RAIs) from our IRAB for the subject LAR on March 22, 21019, and at your request, held a clarification call on April 5, 2019. Please find the following official RAIs for the subject LAR, and provide your responses by May 17, 2019, as mutually agreed during the clarification call.

IRAB-RAI-1 Section 50.34(f)(2)(iii) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 requires, in part, that the licensee or applicant provide, for Commission review, a control room design that reflects state-of-the-art human factor principles. Section 50.34(f)(3)(i) of 10 CFR 50 requires that the licensee or applicant provide administrative procedures for evaluating operating, design, and construction experience and for ensuring that applicable important industry experiences will be provided in a timely manner to those designing and constructing the plant.

Chapter 18, Revision 3, Human Factors Engineering of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (ADAMS Accession No. ML16125A114),

provides guidance for the review of Human Factors Engineering (HFE) considerations of plant modifications and important human actions (HAs). NUREG-0711, Revision 3, Human Factors Engineering Program Review Model (ADAMS Accession No. ML12324A013), provides guidance for the NRC staffs review of HFE programs, to ensure that HFE practices and guidelines were appropriately considered and incorporated in the plant design and modifications. NUREG-1764, Revision 1, Guidance for the Review of Changes to Human Actions (ADAMS Accession No. ML072640413), provides guidance for reviewing changes to HAs, such as those that are credited in nuclear power plant safety analysis.

NUREG-0711, Review Element 11, Human Factors Verification and Validation, provides guidance for the NRC staffs evaluation of the verification and validation (V&V) activities, which comprehensively determine that the HFE design conforms to HFE design principles and that it enables plant personnel to successfully perform their tasks to assure plant safety and operational goals. Section 11.4.3, Integrated System Validation, states, in part, that the objective of the Integrated System Validation (ISV) review is to verify that the applicant validated, using performance-based tests, that the integrated system design supports the safe operation of the plant.

1

Section 4.4 of the Enclosure to APS letter dated July 6, 2018, states that although the TS changes do not involve any plant modifications that could affect system reliability, component performance, or the possibility of operator error, there is a new time requirement for an existing operator action. Specifically, Section 7.2 of 0 to the licensees letter dated July 6, 2018, identifies the affected operator action as the manual action to stop all Reactor Coolant Pumps (RCPs) when pressurizer pressure drops below the RCP net positive suction head limits, during a small break loss of coolant accident.

Please provide additional information regarding the V&V activities that were conducted to provide reasonable assurance that the HAs can be accomplished within the newly established time 2

limits. In your response, provide information that addresses the applicable criteria described in Section 11.4.3 of NUREG-0711.

IRAB-RAI-2 NUREG-0711, Review Element 3, Operating Experience Review, provides guidance for the NRC staffs evaluation of the operating experience review (OER) that would be performed by an applicant or licensee, as part of the HFE program, to identify HFE-related safety issues. Section 3.4, Review Criteria, states, in part, that the applicants OER should include information about relevant human factors issues in the predecessor plant(s) or highly similar plants, systems, and human-system interfaces (HSIs), recognized industry HFE issues, related HSI technology, issues identified by plant personnel, and important HAs. Further, Section 3.4.3, Plant Modifications, states that, in addition to other considerations, the applicants OER should provide information on the plants systems, HSIs, procedures, or training that are being modified, and account for the operating experience of the plant that will be modified, including experiences with the systems that will be changed.

Please provide additional information regarding the OER that was performed by APS, as it relates to the proposed change establishing a new time requirement to stop all RCPs within 5 minutes following loss of subcooling margin. In your response, please describe whether the review identified any human performance issues associated with the procedural guidance, training, and any human performance issues associated with the subject operator action, by reviewing operating experience at APS and applicable industry experience, as appropriate.

IRAB-RAI-3 NUREG-0711, Review Element 10, Training Program Development, provides guidance for the NRC staffs evaluation of the licensees training program. NUREG-1764, Section 3.9, Training Program Design, states, in part, The objective of this review is to verify that the licensees training program results in adequate training for the HAs. The review should verify that appropriate training has been developed and conducted for the HAs.

Section 7.2 of Attachment 10 to the letter dated July 6, 2018, states, in part, The commitment to enter the new time requirement into the time critical action program ensures that any needed changes to the operator training program due to the new time requirement are addressed.

Please provide additional information about the process of updating the operator training program, to clarify specifically how the commitment to enter the new time requirement into the time critical action program results in the necessary changes to the operator training program being implemented.

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Grand Gulf Nuclear Station Location: O-9E22; Mail Stop: O-9E03 Telephone: 301-415-1564 E-mail address: Siva.Lingam@nrc.gov 3

Hearing Identifier: NRR_DMPS Email Number: 914 Mail Envelope Properties (BYAPR09MB3608CCD6C87F19D13DBF0B9FF6510)

Subject:

Palo Verde 1, 2, and 3 - Official RAIs from IRAB for Framatome HTP Fuel LAR and Exemption (EPIDs L-2018-LLA-0194 and L-2018-LLE-0010)

Sent Date: 4/5/2019 2:43:10 PM Received Date: 4/5/2019 2:43:00 PM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients:

"Pascarelli, Robert" <Robert.Pascarelli@nrc.gov>

Tracking Status: None "Bowman, Gregory" <Gregory.Bowman@nrc.gov>

Tracking Status: None "Huckabay, Victoria" <Victoria.Huckabay@nrc.gov>

Tracking Status: None "O'Banion (Watford), Margaret" <Margaret.O'Banion@nrc.gov>

Tracking Status: None "Wengert, Thomas" <Thomas.Wengert@nrc.gov>

Tracking Status: None "Michael.Dilorenzo@aps.com" <Michael.Dilorenzo@aps.com>

Tracking Status: None "Thomas.N.Weber@aps.com" <Thomas.N.Weber@aps.com>

Tracking Status: None "Matthew.Cox@aps.com" <Matthew.Cox@aps.com>

Tracking Status: None Post Office: BYAPR09MB3608.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 7330 4/5/2019 2:43:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

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