ML21020A098

2020-11 Draft Operating Test Comments

ML21020A098
Person / Time
Site:	Palo Verde
Issue date:	12/10/2020
From:	Greg Werner Operations Branch IV
To:	Arizona Public Service Co
References
Download: ML21020A098 (5)

Text

Palo Verde 2020-11 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 301-7, Operating Test Review Worksheet, because the licensees operating test submittal was reviewed and overall deemed SATISFACTORY.

Generic Scenario Changes

• Added There are no personnel to Containment for all scenarios

• Added operator positions for all events Scenario 1:

• Driver Setup - Added note to place Protected Equipment placard over AFB-P01 and AFN-P01

• Crew Turnover - Added that AFB-P01 and AFN-P01 are protected

• Event 1 - No changes

• Event 2 - Specify CS Header valve number o Added valve number

• Event 2 - Include Appendix C checklist o Included checklist

• Event 2 - Added LCO 3.7.11 if Essential Filtration fans are stopped

• Event 3 - Not a separate component failure o Removed event as a separate component failure. Adjusted 301-5 and 301-6

• Event 3 - Specify DNBR limit for TS 3.2.4 entry o Added the POL indication that the examinee will be looking at

• Event 5 - Specify MSIS and CSAS actuation setpoints o Added setpoints

• Event 5 - Add critical task for securing RCPs o Added critical task

• Event 5 - Terminate after entering ESD procedure o Updated termination criteria Scenario 2:

• Driver Setup - Added taking CEDMCS Mode Selector Switch to Auto Sequential.

Added note to place Protected Equipment placard over AFB-P01 and AFN-P01

• Crew Turnover - Added that AFB-P01 and AFN-P01 are protected. Added the status of MFPs

• Event 1 - Specify affected SG o Specified affected SG

• Event 1 - Proceed to next event once DFWCS alarms reset o Adjusted the point to move to the next event

• Event 2 - Added the specific battery charger breaker to the Driver Cue

• Event 3 - Actions to take load off the turbine/borate o Added an Examiner Note that says that if the crew is slow to stop the boration that they will need to take load off the Main Turbine to raise pressure

• Event 3 - Added breaker noun names to Driver Note

• Event 4 - No changes

• Event 5 - Add TS call 3.1.5 cond A, 3.2.4 A, 3.2.1 A, 3.2.3 A o Added all LCOs. Also added note to the Driver to record POL values. Added Examiner Note to ask the CRS to evaluate Tech Specs post scenario.

• Event 5 - Removed boration steps since a boration will not be needed

• Event 6 - Added driver note for the Attachment 58A performance Scenario 3:

• Driver Setup - Added note to place Protected Equipment placard over AFB-P01 and AFN-P01

• Crew Turnover - Added that AFB-P01 and AFN-P01 are protected

• Event 1 - No changes

• Event 2 - Specify unaffected channel o Specified 100Y

• Event 3 - Add applicable RM alarms o Added all applicable RM alarms

• Event 3 - Specify steps to isolate letdown o Included valves that will isolate letdown

• Event 4 - Removed move changing blowdown constants from move on point

• Event 5 - Specify procedural source for guidance provided o Added procedural source for guidance

• Event 6 - Add RM alarms expected o Added expected RM alarm

• Event 6 - Containment sump, humidity info, sump, temp info o Added Containment parameters to expected indications

• Event 6 - Determine leak rate steps and add o Added appendix for leak rate determination

• Event 6 - TS expand 3.4.14 A o Expanded TS information

• Event 7 - Add note that operator will have to manually start HPSI A o Added Examiner note

• Event 7 - Add SIAS setpoint and time 30 minute clock starts o Added setpoint and when time starts

• Event 7 - Add when LOCA starts for 30 minute clock on H2 Analyzers o Added start time

• Event 7 - Add additional leak rate from Event 6 o Added leak rate Scenario 4:

• Driver setup - Added SG feed rate and RCS temperature

• Crew turnover - Added detail to the turnover

• Event 1 - Added wait time for Driver Cue

• Event 2 - Add RCP AOP steps o Added steps

• Event 3 - Add AFW valve numbers and note that they will close the valves o Added valve numbers and that the valves will be closed

• Event 3 - LCO 3.3.6 need I&C cue fuses blown o Added cue

• Event 3 - Add table C2 from Appendix C o Added appendix

• Event 3 - TS 3.6.3 applies o Verified with Operations 3.6.3 does not apply and removed from the scenario

• Event 4 - Add note to what unaffected channel is expected to be switched to (Tave 2) and volts (4.3v) o Added the expected channel and voltage

• Event 4 - Add note to specify CEDMCS desired mode of operation (manual sequential) o Added note

• Event 4 - Auto trigger Event 5 when report made o Changed Event 5 initiation to when report to CRS is made

• Event 7 - Specify to feed using AFA-P01

• Added JPM S1:

• Where does 11 minute time limit come from?

• The site has an agreement with NERC that says the site will lower Main Turbine load up to 600 MW within 15 minutes of the request. It will take 4 minutes from receiving the phone call from the ECC to get to the step when action is actually taken (start time of the JPM), therefore 11 minutes.

JPM S-2:

• Where does 5 minute time limit come from?

• 5 minutes is a Time Critical Action from the time a RAS initiates to ensure that HPSI suction has shifted to the Containment sump and to ensure that RWT Outlet isolation valves have closed.

JPM S-3:

• Changed validation time to 5 minutes JPM S-4:

• Possible to somehow time compress Step 4?

o Discussed and determined not to time compress

JPM S-5:

• In task standard, FVIW should be FWIV.

o Revised

• Changed step 9 to one set, step 12 to OR, 13 to one set, 18 to OR JPM S-6:

• JPM has wrong title (remotely start)?

• This is not the title of the JPM, this is the task used from our Master Task List

• Where does 5 minute time limit come from?

• 5 minutes was determined from engineering data that would be a conservative estimate of when damage would occur from reverse motoring a diesel.

JPM S-7:

• Changed validation time to 7 minutes. Added another operator will complete procedure at termination JPM P-1:

JPM P-2:

JPM P-3:

• What method should be used to communicate with local operator in step 6?

• The cue indicates that the operator will be contacted using a radio JPM A-1:

• Initiating cue provides student with specific reference needed to arrive at correct answer. Change to per Palo Verde administrative procedural requirements.

o Changed cue to per Palo Verde administrative procedural requirements.

JPM A-2:

• Is providing student with what specific reference is required to evaluate answer necessary?

• Changed cue to per plant procedural requirements

• Change validation time from 5 minutes to 10 minutes?

• Discussed during Prep Week and determined to keep validation time 5 minutes JPM A-3:

• In initiating cue, change Per LCO 3.4.12, Pressurizer Vents, to Per Technical Specifications.

• Changed cue to per Technical Specifications

• Corrected task standard to only include critical steps

• Added handout with Pressurizer Vent drawing JPM AS-4:

• Removed unisolable from cue.

• Used Auxiliary Operator for position instead of AO JPM A-5:

• Run this first on administration day so all operators have same start time o Scheduled

• Corrected task standard to only include critical steps

• Add time critical requirement in critical step.