ML22143A989

PV-2022-05-Post Exam Comments

ML22143A989
Person / Time
Site:	Palo Verde
Issue date:	05/19/2022
From:	Scott(Ois) Morris Region 4 Administrator
To:	Dilorenzo M Arizona Public Service Co
References
102-08411-MDD/JR
Download: ML22143A989 (35)

Text

In accordance with examination security guidance contained in NUREG 1021, Revision 12, APS requests that the material contained in the enclosures be withheld from public disclosure until after the examinations are complete.

NUREG 1021/10 CFR 55 A member of STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek 102-08411-MDD/JR May 19, 2022 S. A. Morris, Regional Administrator U.S. Nuclear Regulatory Commission, Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511

Reference:

NRC letter, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 -

Notification of NRC Initial Operating Licensing Examination, dated July 14, 2021 [Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21195A093]

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, 50-530 2022 Post-Examination Comments and Analysis Submittal Arizona Public Service Company (APS) management has completed its review of the initial operator licensing examination conducted May 2 through May 12, 2022. Per NUREG 1021, Rev 12, Section ES-4.4, this letter provides the required post examination documents. There were no substantive comments made by the applicants following the written examination.

As discussed with the Chief Examiner, APS will obtain post-examination signatures from individuals who had detailed knowledge of any part of the operating tests or written examination and electronically forward completed Form(s) 1-3.1, Examination Security Agreement, with the appropriate pre-and post-examination signatures.

In accordance with examination security guidance contained in NUREG 1021 Revision 12, APS requests that the NRC Region IV office delay public release of the proposed and final operating test, written examination and answer keys for a period of 2 years from the date of the examination completion.

No commitments are being made to the NRC by this letter.

If you have any questions or require additional information, please contact Jarred J.

Shaver, Nuclear Training Section Leader, at (623) 393-4519.

Sincerely, Michael D. DiLorenzo Department Leader, Regulatory Affairs, Compliance MDD/JR Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7636 Tel 623 393 3495 Dilorenzo, Michael D(Z99838)

Digitally signed by Dilorenzo, Michael D(Z99838)

Date: 2022.05.19 16:06:17 -07'00'

In accordance with examination security guidance contained in NUREG 1021, Revision 12, APS requests that the material contained in the enclosures be withheld from public disclosure until after the examinations are complete.

102-08411-MDD/JR S. A. Morris USNRC, Region IV Post-Examination Comments and Analysis Page 2

Enclosures:

1. Hard Copy:

o Original Written Examination Cover Sheets - UNGRADED o Copy of Written Examination Cover Sheets - UNGRADED o Written Examination Cover Sheets - GRADED with ORIGINAL ANSWER KEY o Written Examination Cover Sheets - GRADED with CORRECTED ANSWER KEY o Original Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o Copy of Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o Two Copies of Written Examination Answer Sheets - UNGRADED

2. Electronic Copy (on Compact Disc (CD)):

o Signed Facility Cover Letter o Scanned Copy of Written Examination Cover Sheets - UNGRADED o Scanned Copy of Written Examination Cover Sheets - GRADED with ORIGINAL ANSWER KEY o Scanned Copy of Written Examination Answer Sheets - UNGRADED o Scanned Copy of Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o As-Given RO and SRO Written Examinations with Provided Examination References o As-Given RO and SRO Written Examination Worksheet o ORIGINAL RO and SRO Written Examination Answer Keys o CORRECTED RO and SRO Written Examination Answer Keys o Recommended Changes to RO and SRO Written Examination Answer Keys o Questions Asked and Responses Given During Written Examination Administration o Post-Examination Applicant and Licensee Comments o Written Examination Seating Chart o Written Examination Performance Analysis o Form 1-3.1 Examination Security Agreement as of May 16, 2022 (completed copy will be emailed when available)

In accordance with examination security guidance contained in NUREG 1021, Revision 12, APS requests that the material contained in the enclosures be withheld from public disclosure until after the examinations are complete.

102-08411-MDD/JR S. A. Morris USNRC, Region IV Post-Examination Comments and Analysis Page 3 cc:

(w/o enclosure)

S. A. Morris NRC Region IV, Regional Administrator H. J. Gepford NRC Region IV, Chief, Operations Branch J. C. Kirkland NRC Region IV, Chief Examiner J. A. Bridges NRC Region IV, Licensing Assistant, Operations Branch L. N. Merker NRC Senior Resident Inspector for PVNGS (w enclosure)

J. C. Kirkland NRC Region IV, Chief Examiner

Enclosures

1. Hard Copy:

o Original Written Examination Cover Sheets - UNGRADED o Copy of Written Examination Cover Sheets - UNGRADED o Written Examination Cover Sheets - GRADED with ORIGINAL ANSWER KEY o Written Examination Cover Sheets - GRADED with CORRECTED ANSWER KEY o Original Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o Copy of Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o Two Copies of Written Examination Answer Sheets - UNGRADED

2. Electronic Copy (on Compact Disc (CD)):

o Signed Facility Cover Letter o Scanned Copy of Written Examination Cover Sheets - UNGRADED o Scanned Copy of Written Examination Cover Sheets - GRADED with ORIGINAL ANSWER KEY o Scanned Copy of Written Examination Answer Sheets - UNGRADED o Scanned Copy of Written Examination Answer Sheets - GRADED with ORIGINAL ANSWER KEY o As-Given RO and SRO Written Examinations with Provided Examination References o As-Given RO and SRO Written Examination Worksheet o ORIGINAL RO and SRO Written Examination Answer Keys o CORRECTED RO and SRO Written Examination Answer Keys o Recommended Changes to RO and SRO Written Examination Answer Keys o Questions Asked and Responses Given During Written Examination Administration o Post-Examination Applicant and Licensee Comments o Written Examination Seating Chart o Written Examination Performance Analysis o Form 1-3.1 Examination Security Agreement as of May 16, 2022 (completed copy will be emailed when available)

Questions Asked During NRC Written Exam Q#

Applicant Question and Answer 4

SRO Q: When the question is asking about the first AFW pump to be started, is this taking about the first pump post-trip or the first one to pursue after they are all declared inoperable?

A: First pump post-trip 5

SRO SRO Q: Can I assume all applicable AOP actions have been taken?

A: Yes 12 RO Q: What temperature indication is the question referring to on B04?

A: Answer as written 16 RO Q: On lowering grid frequency, both of these trip could come in so how do I know which one to choose?

A: Answer as written 18 RO RO Q: What train is the E Charging Pump aligned to?

A: Answer as written 23 SRO RO Q: What is the noun name for TE-221?

A: Regenerative HX Outlet temperature element 23 RO Q: Do all of the conditions in the stem have to be met?

A: Answer as written 27 RO Q: Is the question asking about buses that get load shed or specific loads that get load shed?

A: Answer as written 45 SRO Q: So the EDG trips on a loss of PKA but since the breaker doesnt, the EDG doesnt stop rotatingcan I consider the EDG tripped if it is still rotating?

A: Answer as written

45 RO Q: What does manually tripped mean?

A: Exactly what it says 53 SRO Q: Is the breaker that tripped the feeder to the load center that the proportional heaters are on or the breaker on the load center that supplies the heaters?

A: The breaker on the load center that supplies the heaters 62 RO Q: How am I supposed to know this?

A: No response provided 63 RO SRO Q: When the answers say, can be operated in manual, does that mean from the control room or in the field?

A: Answer as written 71 RO Q: I dont understand the graphs A: There is nothing to clarify 79 SRO Q: Backflow during natural circ is allowed so Im not sure how to answer A: Answer as written 84 SRO Q: A and B are both valid. Is this asking for how to steam immediately following rebound or long-term steaming on the way to SDC?

A: Answer as written 84 SRO Q: EOP Expectations provides latitude to go either way here A: Answer as written 88 SRO Q: Can I assume all EDGs are good?

A: All assumptions should be made IAW the pre-exam NUREG briefing

Post Exam Applicant Comments Comments on Examiners:

All applicants were grateful for the examiners demeanor and felt that the examiners did their best to put the applicants at ease One applicant said it was difficult to concentration during a simulator JPM due to the examiner seeming to get confused with his copy of the JPM and loudly rifling through the pages of the JPM One applicant said that he was distracted by an examiner during a JPM when the applicant voiced direction to an AO in the field to attempt to take an action but the examiner did not know how to respond and was visibly frustrated Operating Test Comments:

Most SRO applicants agreed that the graph utilized during JPM A5 was not as user friendly as it could be One applicant said that he was confused on JPM S2 since if HPSI flow was inadequate during a LOCA, the correct EOP to be in is the Functional Recovery.

He stated that he actually thought that transitioning to the FR was the desired alternate path to take during the JPM o While this could be correct if the unit was tripped to a LOCA or if the LOCA occurred during SPTAs. The initiating cue in the JPM stated that the unit was tripped in preparation for a refueling outage and that immediately following SPTAs, the LOCA occurred. While the comment is understandable, the conditions presenting in the initiating cue do not support the comment made by the applicant Multiple applicants mentioned the cue on S5 which stated that Steps 1 and 2 of the procedure had been addressed and did not like the NRC correcting the cue on the spot (although all agreed that they preferred for the cue to be clarified rather than just leave the cue as is)

On JPM S7, one of the critical steps was to start the A Emergency Chiller after cross-tying NC to support EW flow. Multiple applicants stated that on one of their written exams in the program, there was a question that stated that when NC is used for EW flow, that the Emergency Chiller would not have cooling flow.

Review of system prints indicated that this is NOT correct (JPM was correct).

The LOIT Section Leader took an action to find the question and correct it if the comments from the applicants were correct.

One applicant stated that he was attempting to invoke LCO 3.0.6 following the loss of PBB-S04 (after declaring LCO 3.8.9 inoperable) to avoid having to take the actions in LCO 3.8.4. This was not in the scenario guide but is an allowed use of LCO 3.0.6.

Feedback was given from the applicants to the LOIT staff regarding the way TS are trained in the program. Specifically regarding the loss of PBB-S04,

apparently only equipment failures which will remain inoperable are discussed (not equipment made inop during a transient situation). There was some debate between the LOIT staff and the applicants and LOIT staff took an action to look closer at this issue (not really exam related)

Written Exam Comments:

Q7 - Some applicants took issue with tripping the Main Turbine during a super ATWS. While there are contingency actions which direct this in SPTAs, the stem could have clearer regarding the status of the unit at the time that step would have been addressed. No challenge to the question though.

Q12 - One applicant stated that he would have liked to have the noun name and transmitter numbers for the Tailpipe Temperature transmitters in the step (option 3).

Q63 - Multiple applicants said they were confused by the Control Room operation portion of the stem in conjunction with the answer options which discussed manual control. They took that to mean that that if they directed an AO to locally operate SBCS valves that this would be equivalent to control room operation (since the direction came from the control room). No challenge to the question though.

1 2

3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RO SRO Total A

B C

C D

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

85.33%

85.33% RO B

B C

C D

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

94.67%

94.67% RO A

B C

D D

C B

B D

C D

D C

B A

A D

A D

B A

D D

A D

94.67%

94.67% RO A

B C

C D

C B

B D

C D

B C

B A

A D

A D

B A

D D

A D

93.33%

93.33% RO A

B C

C D

C B

B D

C D

B C

B A

A D

A D

B A

D C

A D

90.67%

90.67% RO A

B C

D C

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

92.00%

92.00% RO A

B C

C D

C B

B D

C D

B C

B A

A D

A D

B A

D D

A D

85.33%

85.33% RO A

B C

D D

C B

B D

C D

C C

B A

B D

A D

A C

D C

A D

90.67%

90.67% RO B

B C

C D

C A

B D

C D

B C

B A

A D

A D

B A

D C

A D

80.00%

80.00% RO B

B C

C C

C B

B D

C D

B C

B A

A D

A D

B A

D B

B D

89.33%

89.33% RO A

B C

D C

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

93.33%

88.00%

92.00% SRO A

B C

C C

C B

B D

C D

D C

B A

A D

A D

B A

D C

A B

88.00%

92.00%

89.00% SRO A

B C

C D

C B

B D

C D

B C

B A

A D

A D

B B

D D

A D

92.00%

96.00%

93.00% SRO A

A C

C D

C B

B D

C D

B C

B A

A D

A D

B A

D A

A D

97.33%

100.00%

98.00% SRO A

B C

C D

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

94.67%

92.00%

94.00% SRO A

D C

C D

C B

B D

C D

C C

B A

A D

A D

B A

D C

A D

90.67%

88.00%

90.00% SRO B

B C

C D

C B

B D

C D

D C

B A

A D

A D

B A

D C

A D

90.75%

92.67%

90.75% % A 75%

6%

0%

0%

0%

0%

6%

0%

0%

0%

0%

0%

0%

0%

100%

94%

0%

100%

0%

6%

88%

0%

6%

94%

0%

% B 25%

88%

0%

0%

0%

0%

94%

100%

0%

0%

0%

44%

0%

100%

0%

6%

0%

0%

0%

94%

6%

0%

6%

6%

6%

% C 0%

0%

100%

75%

25%

100%

0%

0%

0%

100%

0%

13%

100%

0%

0%

0%

0%

0%

0%

0%

6%

0%

63%

0%

0%

% D 0%

6%

0%

25%

75%

0%

0%

0%

100%

0%

100%

44%

0%

0%

0%

0%

100%

0%

100%

0%

0%

100%

25%

0%

94%

RO SRO Total 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 85.33%

85.33% RO D

D B

D D

B B

A D

C A

D C

D A

A A

D C

C B

C D

D C

94.67%

94.67% RO D

D B

D D

D B

A D

D A

C C

D A

A A

D C

C B

C D

C A

94.67%

94.67% RO D

D D

D D

B B

A D

C A

D C

D A

A A

D C

C B

C D

D C

93.33%

93.33% RO D

D B

D D

B B

A D

C A

D C

D A

A A

D C

C B

C D

D B

90.67%

90.67% RO D

D B

D D

A B

A D

C A

D C

D A

A A

D C

C B

C D

D C

92.00%

92.00% RO D

D B

D D

B A

A D

C A

C C

D A

A A

D C

C B

C D

D C

85.33%

85.33% RO D

D B

D D

D A

A D

C A

D C

D A

A A

D C

C B

C D

D C

90.67%

90.67% RO D

D D

D D

B B

A D

C A

D C

D A

D A

B C

C D

C D

D C

80.00%

80.00% RO D

D C

D C

B B

A D

D A

D C

D A

A A

C C

C B

C D

D C

89.33%

89.33% RO D

D B

D D

B B

A D

C A

C C

D A

A A

D C

D B

C D

D B

93.33%

88.00%

92.00% SRO D

D B

D D

B D

A D

D A

D C

D A

A A

D C

C B

C D

D C

88.00%

92.00%

89.00% SRO D

D B

D D

B B

A D

C A

D C

D A

A A

D C

C B

C D

D A

92.00%

96.00%

93.00% SRO D

D B

D D

D B

A D

C A

C C

D A

A A

D C

C B

C D

D B

97.33%

100.00%

98.00% SRO D

D B

D D

D B

A D

C A

C C

D A

A A

D C

C B

C D

D C

94.67%

92.00%

94.00% SRO D

D B

D D

B B

A D

C A

C C

D A

A A

D C

C B

C D

D A

90.67%

88.00%

90.00% SRO D

D B

D D

B B

A D

D A

D C

D A

A A

D C

C B

D D

D C

90.75%

92.67%

90.75% % A D

D B

D D

D B

A D

C A

C C

D D

A A

B C

C B

C D

D C

% B 0%

0%

0%

0%

0%

6%

13%

100%

0%

0%

100%

0%

0%

0%

94%

94%

100%

0%

0%

0%

0%

0%

0%

0%

19%

% C 0%

0%

81%

0%

0%

63%

81%

0%

0%

0%

0%

0%

0%

0%

0%

0%

0%

13%

0%

0%

94%

0%

0%

0%

19%

% D 0%

0%

6%

0%

6%

0%

0%

0%

0%

75%

0%

44%

100%

0%

0%

0%

0%

6%

100%

94%

0%

94%

0%

6%

63%

100%

100%

13%

100%

94%

31%

6%

0%

100%

25%

0%

56%

0%

100%

6%

6%

0%

81%

0%

6%

6%

6%

100%

94%

0%

RO SRO Total 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 85.33%

85.33% RO A

C A

A A

C/D B

C C

B B

C B

C B

A C

D A

A B

D B

B C

94.67%

94.67% RO A

C C

A A

C B

C C

B A

C B

C B

B C

D A

A A

D D

B C

94.67%

94.67% RO A

C A

A A

D B

C C

B B

C B

D B

A C

D A

A B

D B

B C

93.33%

93.33% RO A

C A

A A

C B

C C

B B

C B

C B

B C

D A

A B

D B

B C

90.67%

90.67% RO A

C C

A A

C B

C C

B B

C B

C A

A C

C A

A B

D B

B C

92.00%

92.00% RO A

C A

A A

D B

C C

B B

C B

C B

A D

C A

A B

D D

B C

85.33%

85.33% RO A

C A

A A

C B

C C

B B

C B

C A

A C

D A

A A

D B

B C

90.67%

90.67% RO A

C A

A A

C B

C D

B B

C A

C B

A C

D A

A B

D B

B C

80.00%

80.00% RO A

C A

A A

D B

C C

B B

C B

C B

A C

D A

A B

D B

B C

89.33%

89.33% RO A

C A

A A

C B

C D

B A

C B

C B

B C

C A

B B

B D

B C

93.33%

88.00%

92.00% SRO A

C A

A A

C B

C C

B B

A B

D B

A D

C A

A B

D B

B C

88.00%

92.00%

89.00% SRO A

C A

A A

D B

C C

B B

C B

C A

A C

D A

B B

D B

B C

92.00%

96.00%

93.00% SRO A

C A

A A

D B

C C

B B

C B

C B

B C

D A

A A

D D

B C

97.33%

100.00%

98.00% SRO A

C A

A A

D B

C C

B B

C B

C B

A C

D A

C B

D B

B C

94.67%

92.00%

94.00% SRO A

C A

A A

D B

C C

B B

C B

C B

A C

D A

A B

D B

B C

90.67%

88.00%

90.00% SRO A

C A

A A

D B

C C

B B

C B

C B

A C

D A

A B

D B

B C

90.75%

92.67%

90.75% % A A

C A

A A

C B

C A

B B

C B

C B

A C

D A

A B

D D

B C

% B 100%

0%

88%

100%

100%

0%

0%

0%

6%

0%

13%

6%

6%

0%

19%

75%

0%

0%

100%

81%

19%

0%

0%

0%

0%

% C 0%

0%

0%

0%

0%

0%

100%

0%

0%

100%

88%

0%

94%

0%

81%

25%

0%

0%

0%

13%

81%

6%

69%

100%

0%

% D 0%

100%

13%

0%

0%

0%

0%

100%

81%

0%

0%

94%

0%

88%

0%

0%

88%

25%

0%

6%

0%

0%

0%

0%

100%

0%

0%

0%

0%

0%

100%

0%

0%

13%

0%

0%

0%

0%

13%

0%

0%

13%

75%

0%

0%

0%

94%

31%

0%

0%

RO SRO Total 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 85.33%

85.33% RO C

B A

B C

C B

A A

B C

D A

D C

B C

D C

D D

B D

B A

94.67%

94.67% RO 94.67%

94.67% RO 93.33%

93.33% RO 90.67%

90.67% RO 92.00%

92.00% RO 85.33%

85.33% RO 90.67%

90.67% RO 80.00%

80.00% RO 89.33%

89.33% RO 93.33%

88.00%

92.00% SRO 88.00%

92.00%

89.00% SRO C

B A

B C

C B

A A

B C

C A

D C

B C

D C

D D

B D

D B

92.00%

96.00%

93.00% SRO A

B A

B C

A B

A A

B C

D A

D C

B C

D C

D D

B D

B A

97.33%

100.00%

98.00% SRO C

B A

B C

C B

A A

B D

D A

D C

B C

D C

D D

B D

B A

94.67%

92.00%

94.00% SRO C

B A

B C

C B

A A

B C

D A

D C

B C

D C

D D

B D

B A

90.67%

88.00%

90.00% SRO C

B A

B C

C B

A A

B C

D A

D C

B C

D C

D D

D D

D A

90.75%

92.67%

90.75% % A A

B A

B C

C B

A C

B C

D A

D C

B C

D C

D D

B D

D A

% B 33%

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83%

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83%

% C 0%

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0%

2022 NRC Written Exam

Recommended Changes to the 2022 PVNGS NRC Initial Written Exam Question 56 (Keyed as only D correct, recommend accepting both C and D as correct)

Given the following conditions:

• Unit 3 is in MODE 6

• A fuel offload is in progress

• 10 fuel assemblies have been placed in the Spent Fuel Pool

• Startup Channel NI #1 has just failed off-scale low The fuel offload A.

may continue since LCO 3.3.12 is only impacted on a loss of a Safety Channel NI B.

may continue since LCO 3.9.2 in only impacted on a loss of a Safety Channel NI C.

must be immediately suspended to comply with LCO 3.3.12, Boron Dilution Alarm System D.

must be immediately suspended to comply with LCO 3.9.2, Nuclear Instrumentation

Proposed Answer:

D Explanations:

A.

Plausible since Safety Channel NIs are required to comply with TS, however LCO 3.3.12 and 3.9.2 require Startup Channel NIs, not Safety Channel NIs.

B.

Plausible since Safety Channel NIs are required to comply with TS, however LCO 3.3.12 and 3.9.2 require Startup Channel NIs, not Safety Channel NIs.

C.

Plausible since the fuel offload must be suspended, however this is to comply with LCO 3.9.2, not 3.3.12.

D.

Correct.

Question Source:

X New Bank Modified Previous NRC Exam Cognitive Level:

Memory or Fundamental Knowledge X

Comprehension or Analysis Level of Difficultly:

4 10CFR55.41:

13 Reference Provided:

N Learning Objective:

Given a set of plant conditions, apply the one hour or less LCO and TLCO action statements of T.S. 3.9 IAW Tech Spec 3.9

Technical

Reference:

PVNGS Technical Specifications Fuel Offload is not considered a positive reactivity addition

Technical

Reference:

PVNGS Technical Specifications

Technical

Reference:

PV Technical Specification Bases Although PPS Tech Specs use Safety Channel NIs, both 3.3.12 and 3.9.2 use Startup Channel NIs.

Facility Position:

We believe question 56 has two correct answers, C and D.

A and B are clearly incorrect due to the statement that LCOs 3.3.12, Boron Dilution Alarm System, or 3.9.2, Nuclear Instrumentation, are only impacted on a loss of a Safety Channel NI. This statement is false (LCOs 3.3.12 and 3.9.2 both use Startup Channel NIs for operability), therefore A and B are clearly incorrect.

The failure of a Startup Channel NI results in the failure to meet both LCO 3.3.12 and LCO 3.9.2. LCO 3.9.2, Nuclear Instrumentation, contains a required action to suspend CORE ALTERATIONS when one required SRM is inoperable (stated in the stem of the question). LCO 3.9.2 also contains a note which states, Enter applicable Conditions and Required Actions of LCO 3.3.12, Boron Dilution Alarm System (BDAS) for BDAS made inoperable by SRMs. Due to this note, the provisions of LCO 3.0.6 would not be applicable, therefore the actions for LCO 3.3.12 are required to be taken.

While the required actions for LCO 3.3.12 (for one channel of BDAS inoperable) do not directly require the cessation of CORE ALTERATIONS, the supporting procedures used to comply with the Required Action for LCO 3.3.12, Condition A, do, making answer C an additional correct answer.

73DP-9ZZ14, Surveillance Testing, refers to the site-controlled cross-reference table (Master Surveillance Test List - or MSTL) for STs used to comply with Technical Specification - both SRs and Conditional STs (in this case, used to comply with the Required Action for not meeting the LCO). The MSTL specifies the use of 40ST-9ZZ24, Boron Dilution Alarm System Inoperable, to comply with LCO 3.3.12, Condition A, Action A.1. Additionally, the Performance Interval for 40ST-9ZZ24 is Immediately after loss of one or both BDAS channels, therefore that are two distinct paths to drive the performance of 40ST-9ZZ24.

40ST-9ZZ24 contains two sections. Section 6.1, One or Both BDAS Channels Inoperable in Modes 3, 4, 5, or 6, and Section 6.2, One or Both BDAS Channels Inoperable in Mode 6 Due to Inoperable Startup Range Monitor. Section 6.1 contains direction for sampling the RCS to determine boron concentration. Section 6.2 contains direction to stop CORE ALTERATIONS and to stop positive reactivity additions. If the reason for one channel of BDAS being inoperable was due to any reason OTHER THAN a failed Startup Channel NI, CORE ALTERATIONS would NOT have to be stopped. However when 40ST-9ZZ24 is performed, the sections required to be performed are based on the reason for the inoperability of BDAS. In this case, both sections 6.1 and 6.2 must be performed. Since the method for compliance with LCO 3.3.12, Condition A, Action A.1 results in the cessation of CORE ALTERATIONS, answer C is also correct.

Exam Author Perspective:

When I wrote the question, I believed that D was the only correct answer. While LCOs 3.3.12 and 3.9.2 are both NOT met following a loss of a Startup Channel NI, only LCO 3.9.2 explicitly directs the immediate stoppage of CORE ALTERATIONS. However, upon further review following the exam, I learned of the existence and use of the Master Surveillance Test List (MSTL). Seeing the application of the MSTL and the application of its use to Question 56, I agree that both C and D are correct answers as complying with the Required Actions of either LCO 3.3.12 or LCO 3.9.2 would result in the immediate cessation of CORE ALTERATIONS, which would include stopping the fuel offload.

Facility Recommendation:

As described above, the only path to compliance with LCO 3.3.12 Condition A without the cessation of CORE ALTERATIONS would be the improper implementation of approved site procedures, thus both answers C and D should be accepted as correct.

Per NUREG 1021, Rev 12, Section 4.4, Grading and Documenting Written Examinations, Step C.3.c:

Despite the extensive reviews performed by both the NRC and the facility licensee before examination administration, it is possible that errors may be discovered only after an examination has been administered. The NRC will consider examination changes for the following types or errors, if identified and adequately justified by the facility licensee or an applicant:

• (3rd bullet) Newly discovered technical information that supports a change in the answer key Since the existence and use of the Master Surveillance Test List (MSTL) was not known to the exam author during the development and administration of the written examination, and the use of the MSTL as directed by site procedures makes both C and D correct, we believe that this question meets the intent of NUREG 1021, Section 4.4, Step C.3.c and thus have both answers C and D accepted as correct.

Question 56 Analysis Given the following conditions:

D. must be immediately suspended to comply with LCO 3.9.2, Nuclear Instrumentation The conditions in the stem show that the unit is in MODE 6, a fuel offload is in progress, and that Startup Channel NI #1 has failed low. The failure of the Startup Channel NI requires entry into LCO 3.3.12, Condition A, and LCO 3.9.2, Condition A C. must be immediately suspended to comply with LCO 3.3.12, Boron Dilution Alarm System A. may continue since LCO 3.3.12 is only impacted on a loss of a Safety Channel NI (incorrect)

Required Action - Determine RCS boron concentration immediately Per 73DP-9ZZ14, Surveillance Testing, refer to the Master Surveillance Task List (MSTL) to determine the procedure to use to comply with LCO 3.3.12 Action A.1 The MSTL lists 40ST-9ZZ24, Boron Dilution Alarm System Inoperable, as the ST performed to comply with LCO 3.3.12, Action A.1 40ST-9ZZ24 directs Chemistry to sample the RCS to determine boron concentration AND (if one BDAS channel is inoperable due to an inoperable Startup Channel NI) directs stopping CORE ALTERATIONS The fuel offload B. may continue since LCO 3.9.2 is only impacted on a loss of a Safety Channel NI (incorrect)

LCO 3.3.12, Condition A LCO 3.9.2, Condition A Required Action - Suspend CORE ALTERATIONS immediately AND Suspend positive reactivity additions immediately

- Unit 3 is in MODE 6

- A fuel offload is in progress

- 10 fuel assemblies have been placed in the Spent Fuel Pool

- Startup Channel NI #1 has just failed off-scale low

==

Conclusion:==

Given the conditions in the question, CORE ALTERATIONS, and thus the fuel offload, must be immediately suspended to comply with BOTH LCO 3.3.12 and LCO 3.9.2, making both answer C and answer D correct.

Outage GOP 40OP-9ZZ23 Page 360 of 527 Revision PALO VERDE PROCEDURE 87 Appendix Q - Refueling Activities and Evolutions Evolution/Activity Fuel Movement Reactivity Change Possible Fuel Damage (Note 1)

Core Alteration RV Head Removal or Installation No No No No UGS Lift Rig Installation No No No No CEA Coupling or Uncoupling No Yes No Yes UGS Removal/Installation No No Yes No Fuel, CEA, or Source Movement Yes Yes (Note 2)

Yes Yes (Note 2)

Test Specimen Movement No No No No Core Mapping with TV Camera No No No No Refueling Machine, Mast Ops, Hoist Box Movement Over RV without Grappling No No No No Core Alignment Checks or Position Verification No No No No Fuel Realignment After Fuel Position Verification Yes Yes Yes Yes Incore Detector, or HJTC Removal or Installation with the UGS Installed No No No No ISI Inspection Device Installation, Operation, or Removal No No No No UGS Lift Rig CEA Support Plate Raise or Lower without CEAs Latched No No No No UGS Lift Rig CEA Support Plate Raise or Lower with CEAs Latched No Yes No Yes CEA Drag Test No Yes No Yes Metal Recovery from Reactor Vessel after Core Offload NA NA NA No Metal Recovery from Reactor Vessel removing debris from top of core No No No No

____ Note 1: Damage which could result in release of radioactive material such that Containment closure and Containment Purge Isolation should be required.

Appendix Q Page 1 of 2

Outage GOP 40OP-9ZZ23 Page 361 of 527 Revision PALO VERDE PROCEDURE 87 End of Appendix Q

____ Note 2: Does NOT apply to the last fuel bundle removed from the Reactor Vessel or to the first fuel bundle inserted into the Reactor Vessel. (CRDR 3721627)

Core Alteration is the movement or manipulation of any fuel, sources, or reactivity control components (excluding control element assemblies (CEAs) withdrawn into the upper guide structure), within the Reactor Vessel with the Reactor Vessel Head removed and fuel in the Reactor Vessel. Suspension of Core Alterations does NOT preclude movement of a component to a safe position.

Cessation of Core Alteration Brief administrative holds of core alterations are NOT formally considered Suspension of Core Alterations unless declared so by the Shift Manager or Refueling SRO. Core Alterations are considered to be administratively suspended when the movement or manipulation of any fuel, sources or reactivity control component within the Reactor Pressure Vessel has ceased, and the Refueling SRO has communicated the cessation of core alterations to the Control Room. As long as No actual movement of any fuel, sources or reactivity control component within the Reactor Vessel is occurring, communications may be terminated as long as a communications check is performed prior to resuming core alterations. During these intervals, the individuals associated with the core alteration can be contacted using the Plant Page System.

Evolution/Activity Fuel Movement Reactivity Change Possible Fuel Damage (Note 1)

Core Alteration Appendix Q Page 2 of 2 The question asks which of the LCOs would require the suspension of the fuel offload. The pages from Outage GOP are simply to show that fuel movements are considered a core alteration, therefore when an action states, "stop CORE ALTERATIONS", this is directing the stoppage of the fuel offload.

Panel B04A Alarm Responses 40AL-9RK4A Page 211 of 420 Revision PALO VERDE PROCEDURE 4A12A 56 AUTOMATIC ACTIONS Auto Motion Inhibit if neutron flux signal is selected to average on SFN-C03, NSSS Control System Cab (Reactor Regulating System)

Auto Motion will happen if neutron flux signal is selected to the failed channel on SFN-C03, NSSS Control System Cab (Reactor Regulating System)

MANUAL ACTIONS

___ 1. Place SFN-UIC-6, CEDM CONTROL PANEL, MODE SELECT SWITCH to MS (Manual Sequential).

___ 2. Check ALL of the following to determine which channel is failed:

SEN-JI-5, L) STARTUP CHANNEL 1 SEN-JI-5, R) STARTUP CHANNEL 2 SEN-JR-5, L) CONTROL/SU CHANNEL 1 SEN-JR-5, R) CONTROL/SU CHANNEL 2 SEN-JI-7, L) CONTROL CHANNEL 1 SEN-JI-7, R) CONTROL CHANNEL 2

___ 3. Notify the SM/CRS BOTH of the following LCOs may be impacted:

LCO 3.3.12, Boron Dilution Alarm System (BDAS)

LCO 3.9.2, Nuclear Instrumentation Response Section 4A12A Startup and Control Channel Trouble SU AND CNTRL CH TRBL Point ID Description Setpoint SEJS5 Start-Up Control Channel 1 Trouble NA SEJS6 Start-Up Control Channel 2 Trouble NA Page 1 of 3 The 4A12B Alarm Response Procedure would be Path 1 to the affected LCOs and the performance of 40ST-9ZZ24, Boron Dilution Alarm System Inoperable

Panel B04A Alarm Responses 40AL-9RK4A Page 212 of 420 Revision PALO VERDE PROCEDURE 4A12A 56

___ 4. IF the Unit is in Mode 3, 4, 5, or 6, THEN REFER TO 40ST-9ZZ24, Boron Dilution Alarm System (BDAS) Inoperable.

___ 5. IF BOTH of the following conditions exist:

The Unit is in Mode 6 Both BDAS channels are inoperable THEN notify Chemistry to perform 74ST-9ZZ01, Refueling Boron Surveillance Test, due to BOTH of the following:

Both BDAS channels are inoperable LCO SR 3.9.1.1, Verify boron concentration

___ 6. IF the Unit is in Mode 6, THEN stop BOTH of the following:

Core alterations Positive reactivity additions

___ 7. Monitor Feedwater Control System for proper operation.

___ 8. Select the unaffected control channel input at SFN-C03, NSSS Control Systems Cab (Reactor Regulating System).

___ 9. IF the SM/CRS directs restoring CEDMCS control system, THEN place SFN-UIC-6, CEDM Control Panel, Mode Select switch to the SM/CRS directed position.

___ 10. Initiate a Condition Report for Maintenance to correct the cause of the alarm.

PROBABLE CAUSES Loss of high voltage Loss of low voltage Module removal Test circuit energized Calibrate controls NOT in operate position Page 2 of 3

Operations MODE 6 Surveillance Logs 40ST-9ZZM6 Page 13 of 80 Revision PALO VERDE PROCEDURE 26

6.1.3 Startup Channel and BDAS Channel Checks A. Perform Startup Channel 1 Channel Checks in the Startup Range Monitor (SRM) Channel Checks table:

1. IF BOTH of the following speaker volumes are audible:

Startup Channel 1 Control Room Speaker volume Startup Channel 1 Containment Speaker volume THEN place an initial in the Yes column for speaker volume Acceptance Criteria Met?.

2. IF one of the speaker volumes is NOT audible, THEN place an initial in the No column for speaker volume Acceptance Criteria Met?.

3. IF BOTH of the following:

Annunciator SU AND CONT CH TRBL (4A12A) is in alarm.

Startup Channel 1 is NOT the cause of the alarm.

THEN place an initial in the Yes column for the annunciator Acceptance Criteria Met?.

4. IF the HV LOW light is OFF on the Startup Channel 1 Control Drawer, THEN place an initial in the Yes column for Startup/Control Drawer Acceptance Criteria Met?.

5. IF the HV LOW light is ON, THEN place an initial in the No column for Startup/Control Drawer Acceptance Criteria Met?.

NOTE If this section is being performed prior to MODE 6 entry, then alternative monitoring may be required.

The pages from 40ST-9ZZM6, specifically the shiftly surveillance for Startup Channel and BDAS Channel Checks, indicate Path 2 to the affected LCOs and the performance of 40ST-9ZZ24, Boron Dilution Alarm System Inoperable

Operations MODE 6 Surveillance Logs 40ST-9ZZM6 Page 14 of 80 Revision PALO VERDE PROCEDURE 26 B. Perform Startup Channel 2 Channel Checks in the Startup Range Monitor (SRM) Channel Checks table:

1. IF BOTH of the following speaker volumes are audible:

Startup Channel 2 Control Room Speaker volume Startup Channel 2 Containment Speaker volume THEN place an initial in the Yes column for speaker volume Acceptance Criteria Met?.

2. IF one of the speaker volumes is NOT audible, THEN place an initial in the No column for speaker volume Acceptance Criteria Met?.

3. IF BOTH of the following:

Annunciator SU AND CONT CH TRBL (4A12A) is in alarm.

Startup Channel 2 is NOT the cause of the alarm.

THEN place an initial in the Yes column for the annunciator Acceptance Criteria Met?.

4. IF the HV LOW light is OFF on the Startup Channel 2 Control Drawer, THEN place an initial in the Yes column for Startup/Control Drawer Acceptance Criteria Met?.

5. IF the HV LOW light is ON, THEN place an initial in the No column for Startup/Control Drawer Acceptance Criteria Met?.

C. Perform BDAS Channel Checks in the BDAS Channel Checks table:

1. Record Startup Channel 1 and 2 count rates from ONE of the following for BOTH channels:

SEN-JI-5, Startup Channel, on B04 SQN-C02, Cabinet NSSS Radiation Monitoring, on Startup Channel 1 and 2 Control Drawers Step 6.1.3, Continued

Operations MODE 6 Surveillance Logs 40ST-9ZZM6 Page 15 of 80 Revision PALO VERDE PROCEDURE 26

2. IF either Startup Channel count rate is below the indicating range on SEN-JI-5 and on the Startup Channel Control Drawer meter, THEN record Startup Channel 1 and 2 count rates from ONE of the following for BOTH channels in Appendix F - Alternative Monitoring Data Sheets:

PMS Points SENIS1C and SENIS2C ERFDADS Points SENIS1 and SENIS2

3. Insert the lowest Startup Channel value into the Startup Channel Value Acceptance Criteria Calculation.

4. Calculate the acceptance criteria value of 2.5 times the lowest reading channels value.

5. Compare the highest reading Startup Channel value against the calculated acceptance criteria.

6. IF the reading of the highest reading channel is less than or equal to the calculated acceptance criteria, THEN place an initial in the Yes column under Acceptance Criteria Met?

for the values of Startup Channels 1 and 2.

7. Record flux reading from Boron Dilution Alarm SEN-NI-005.

8. Check that the center decimal indicator on SEN-NI-005 is flashing at about one flash per second.

9. Record flux reading from Boron Dilution Alarm SEN-NI-006.

10. Check that the center decimal indicator on SEN-NI-006 is flashing at about one flash per second.

11. Determine the difference in flux readings between SEN-NI-005 and SEN-NI-006.

12. Record calculated flux difference calculation.

13. IF the difference in flux readings is less than or equal to 0.8 VDC, THEN place an initial in the Yes column under Acceptance Criteria Met?

for the flux reading difference.

Step 6.1.3.C, Continued

Operations MODE 6 Surveillance Logs 40ST-9ZZM6 Page 16 of 80 Revision PALO VERDE PROCEDURE 26

D. IF BOTH Startup Range Monitor/BDAS Channels are inoperable, THEN perform the following:

1. Immediately stop BOTH of the following:

Core alterations Positive reactivity additions

2. Initiate actions immediately to restore one Startup Range Monitor Channel to OPERABLE.

3. Direct Chemistry to immediately determine RCS boron concentration using redundant methods.

4. Comply with the action requirements of BOTH of the following LCOs:

LCO 3.3.12 Condition B, Boron Dilution Alarm System (BDAS) - One Required Channel Inoperable LCO 3.9.2 Condition B, Refueling Operations - Nuclear Instrumentation

5. Initiate performance of 40ST-9ZZ24, Boron Dilution Alarm System (BDAS) Inoperable.

E. IF ONE Startup Range Monitor/BDAS Channel is inoperable, THEN perform the following:

1. Immediately stop BOTH of the following:

Core alterations Positive reactivity additions

2. Direct Chemistry to immediately determine RCS boron concentration.

3. Comply with the action requirements of ALL applicable LCOs:

LCO 3.3.12 Condition A, Boron Dilution Alarm System (BDAS) - One Required Channel Inoperable LCO 3.9.2 Condition A, Refueling Operations - Nuclear Instrumentation

4. Initiate performance of 40ST-9ZZ24, Boron Dilution Alarm System (BDAS) Inoperable.

Step 6.1.3, Continued

Surveillance Testing 73DP-9ZZ14 Page 4 of 66 Revision PALO VERDE PROCEDURE 30 1.0 PURPOSE AND SCOPE 1.1 Purpose

1.1.1 This procedure describes the methodology and responsibilities for implementing PVNGS Technical Specifications (TS) and Technical Requirements Manual (TRM)

Surveillance Requirements.

1.1.2 This procedure supports the implementation of the Operations Program (PR-0101) within the Operate the Plant Program Area (PA-0100).

1.2 Scope 1.2.1 This procedure applies to PVGS personnel responsible for administering and performing surveillance tests.

1.2.2 This procedure ensures that equipment necessary for safe and reliable plant operation will perform within required limits to satisfy regulatory, ASME code (Section XI pump and valve test program), and other testing deemed appropriate by plant management.

A. In conjunction with the aforementioned requirements, surveillance testing is implemented by specific testing procedures, supported by a scheduling mechanism, and conducted and analyzed in a manner that provides assurance that all equipment needed for safe and reliable plant operation will perform as required.

1.2.3 The Surveillance Testing Program should establish necessary coordination among ALL the following departments:

the Operations Department for equipment operability and limiting conditions for operation.

The Maintenance Department for surveillance retesting following maintenance.

The Outage Planning Department for inclusion of SRs in outage schedules.

The Licensing Department for Technical Specification and other commitment changes.

The Engineering Department for assurance that test procedures verify equipment capabilities and are updated as necessary to incorporate plant modifications.

73DP-9ZZ14 is the administrative procedure governing the implementation of Technical Specification Surveillance Requirements

Surveillance Testing 73DP-9ZZ14 Page 5 of 66 Revision PALO VERDE PROCEDURE 30

1.2.4 The objectives of the Surveillance Testing Program are ALL of the following:

Maintain and improve equipment availability, Confirm compliance with operational limits and conditions.

Detect and correct any abnormal condition before the condition can give rise to significant consequences for safety.

1.2.5 The abnormal conditions which are of relevance to the Surveillance Testing Program include NOT only deficiencies in SSCs and software performance, procedural errors and human errors, but also trends within the accepted limits, an analysis of which may indicate that the plant is deviating from the design intent.

A. Over the plants operating lifetime, SSCs should be examined for possible deterioration so as to determine whether they are acceptable for continued safe operation or whether remedial measures should be taken.

2.0 RESPONSIBILITIES

2.1 Director, Operations Maintains overall responsibility for providing a Surveillance Testing Program.

Provides oversight of the Surveillance Testing Program to enhance program effectiveness, productivity, and integrity.

2.2 Surveillance Test Program Owner

Functions as the administrative single point of accountability for Surveillance Testing Program control.

Reviews changes to the Surveillance Testing Program resulting from changes to the TS and TRM.

Maintains a thorough knowledge of Surveillance Testing Program requirements and implementation.

Provides clarification or interpretation of Surveillance Testing Program, regulatory, or code requirements.

Maintains an in-depth knowledge of TS and TRM requirements.

Trends Surveillance Testing Program performance and analyzes data to identify any programmatic performance trends.

Surveillance Testing 73DP-9ZZ14 Page 11 of 66 Revision PALO VERDE PROCEDURE 30 3.0 DEFINITIONS

3.1 Aborted Surveillance Test Performance Phrase used to identify when the performance of a surveillance test (ST) has been stopped or cannot be completed due to an extenuating circumstance or unexpected condition occurring during the performance of the ST. A reasonable expectation for operability/functionality of the structure, system, or component is maintained.

3.2 Acceptable Preconditioning The alteration, variation, manipulation, or adjustment of the physical condition of a structure, system, or component before Technical Specification surveillance or ASME Code testing for the purpose of protecting personnel or equipment or to meet the manufacturers recommendations.

3.3 Channel Calibration The adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The Channel Calibration shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the Channel Functional Test. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in-place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required Channel Calibration shall include an in-place cross calibration that compares the other sensing elements with the recently installed sensing element. The Channel Calibration may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

3.4 Commencement Date Date when first surveillance testing activity to satisfy surveillance test acceptance criteria is performed.

3.5 Completed Surveillance Test Performance Phrase used to identify that all equipment identified in a specific surveillance package (required to be tested by a procedure to meet surveillance program requirements) has been tested.

3.6 Conditional Surveillance Tests Surveillance tests (STs) performed to meet Technical Specification Surveillance Requirements when certain plant conditions or combination of conditions are met (for example, an ST dependent on the number of equipment operating hours or number of thermal cycles). Conditional STs do NOT have a defined surveillance test interval.

3.7 Credited ST An ST performance record established by reference to another completed ST performance record that has fully satisfied the SRs of the ST being credited, where test crediting is specifically permitted by the subject test procedure.

Surveillance Testing 73DP-9ZZ14 Page 12 of 66 Revision PALO VERDE PROCEDURE 30 3.8 CRS Control Room Supervisor 3.9 Delayed Surveillance Test Performance Phrase used to identify when the performance of a surveillance test (ST) has been suspended for a period of time, such as when waiting until appropriate plant conditions to perform the ST are established, and will be resumed when plant conditions permit the ST to be performed safely. A reasonable expectation for operability/functionality of the structure, system, or component being tested is maintained.

3.10 Failed Surveillance Test Any surveillance test (ST) where the final ST acceptance criteria are NOT met, or where there is no longer a reasonable expectation for operability/functionality of the system, structure, or component being tested while the ST is being performed.

3.11 Fire Test (FT) A surveillance test that is specific to Fire Protection Systems and features.

3.12 Implementing Personnel Person(s) involved in the surveillance test process from initiation of a surveillance package to archiving the package.

3.13 M&TE Measuring and Test Equipment

3.14 Master Surveillance Schedule A schedule which reflects the status of all planned in-plant surveillance tests (STs) and inspections, including in-service inspections.

3.15 Master Surveillance Test List (MSTL) Cross reference of Surveillance Requirements to the procedure(s) satisfying the requirements.

3.16 MMS Master Monthly Schedule 3.17 NRA Nuclear Regulatory Affairs 3.18 OCS Operations Computer Systems 3.19 Partial Surveillance Test Performance Phrase used to identify that NOT all equipment identified in a specific surveillance package (required to be tested by a procedure to meet surveillance program requirements) has been tested.

3.20 Preconditioning The alteration, variation, manipulation, or adjustment of the physical condition of a structure, system or component before Technical Specification or Technical Requirements Manual surveillance or ASME Code testing. [Also see Step 3.36) 3.21 RT Routine Task 3.22 SM Shift Manager

Procedure Procedure Description Surveillance Requirement Surveillance Requirement Description Notes Rev 38 (2/7/2022) 3.1.8.1 Part Length Control Element Assembly (CEA) Insertion Limits 3.3.3 Action A.2.1 3.3.3 Action B.2.2 3.3.3 Action B.2.5 3.3.12 Action A.1 3.3.12 Action B.1 40ST-9ZZ25 REMOTE SHUTDOWN DISCONNECT SWITCH AND CONTROL CIRCUIT OPERABILITY - ALL MODES 3.3.11.2 Remote Shutdown System 40ST-9ZZ35 PDIL ALARM CIRCUIT OPERABILITY SURVEILLANCE 3.1.7.3 Regulating Control Element Assembly (CEA) Insertion Limits 40ST-9ZZ37 INOPERABLE POWER SOURCES ACTION STATEMENT 3.8.1 Actions A through G AC Sources - Operating No SR, but LCO actions 3.1.105.1 TRM - Borated Sources - Operating 3.1.5.1 3.1.5.2 3.1.6.1 Shutdown Control Element Assembly (CEA)

Insertion Limits 3.1.7.1 3.1.7.2 3.1.8.1 Part Length Control Element Assembly (CEA) Insertion Limits 40ST-9ZZ24 BORON DILUTION ALARM SYSTEM (BDAS) INOPERABLE Control Element Assembly (CEA) Alignment Regulating Control Element Assembly (CEA) Insertion Limits Boron Dilution Alarm System (BDAS) 40ST-9ZZ23 Control Element Assembly Calculators (CEACs)

CEA Position Data Log This is an excerpt from the Master Surveillance Test List. To comply with LCO 3.3.12 Action A.1, performance of 40ST-9ZZ24, Boron Dilution Alarm System Inoperable, is required.

Boron Dilution Alarm System (BDAS) Inoperable 40ST-9ZZ24 Page 4 of 37 Revision PALO VERDE PROCEDURE 16 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1 The purpose of this procedure is to verify that the required actions are taken when BDAS channels are inoperable in Modes 3, 4, 5 and 6.

1.2 Scope 1.2.1 General A. This procedure provides actions to be taken for ANY of the following conditions:

In Mode 3, 4, 5 or 6 and one or both channels of BDAS are inoperable due to a problem with the channel(s).

In Mode 6 and one or both channels of BDAS are inoperable due to inoperable Startup Range Monitor(s).

1.2.2 Technical Specifications Requirements A. Limiting Condition for Operation (LCO) 3.3.12, Boron Dilution Alarm System (BDAS) 3.9.2, Nuclear Instrumentation 1.2.3 Plant Modes A. Mode 3, 4, 5, and 6 1.2.4 Performance Interval A. Immediately after loss of one or both BDAS channels.

B. At the monitoring frequency specified in the COLR.

End of Section 1.0

Boron Dilution Alarm System (BDAS) Inoperable 40ST-9ZZ24 Page 5 of 37 Revision PALO VERDE PROCEDURE 16 2.0 RESPONSIBILITIES 2.1 Control Room Operators 2.1.1 A Control Room Operator is responsible for ALL of the following:

Functioning as Test Leader Directing test performance Ensuring test is conducted per 73DP-9ZZ14, Surveillance Testing 2.2 Chemistry is responsible for obtaining and analyzing boron samples when directed by Operations.

End of Section 2.0 3.0 PRECAUTIONS AND LIMITATIONS 3.1 Precautions 3.1.1 None 3.2 Limitations 3.2.1 None End of Section 3.0

Boron Dilution Alarm System (BDAS) Inoperable 40ST-9ZZ24 Page 7 of 37 Revision PALO VERDE PROCEDURE 16 5.0 PREREQUISITES AND INITIAL ACTIONS 5.1 Prerequisites 5.1.1 None 5.2 Initial Actions

___ 5.2.1 Record the following:

___ 5.2.2 Ensure this copy of the procedure is the current revision and includes all effective Temporary Approved Procedure Actions (TAPAs).

___ 5.2.3 Ensure Section 2.0, Responsibilities, and Section 3.0, Precautions and Limitations, have been read and understood.

___ 5.2.4 Indicate the procedure section(s) to be performed:

___ 5.2.5 SM/CRS/WCSRO Provide permission to perform this test.

Signature

_____________________________________ Date ____________

SM/CRS/WCSRO End of Section 5.0 Plant Status Unit (circle) 1 2

3 Date Mode (circle) 3 4

5 6

Check or N/A Section(s)

Test Description 6.1 One or Both BDAS Channels Inoperable in Modes 3, 4, 5, or 6 (LCO 3.3.12) 6.2 One or Both BDAS Channels Inoperable in Mode 6 Due to Inoperable Startup Range Monitor(s) (LCO 3.9.2)

Boron Dilution Alarm System (BDAS) Inoperable 40ST-9ZZ24 Page 8 of 37 Revision PALO VERDE PROCEDURE 16 6.0 INSTRUCTIONS 6.1 One or Both BDAS Channels Inoperable in Modes 3, 4, 5, or 6 (LCO 3.3.12)

___ 6.1.1 IF one BDAS channel is inoperable, THEN direct Chemistry to perform the following:

___ A. Obtain an RCS boron sample as follows:

___ 1. IF ONE of the following:

At least one RCP is in operation Natural Circulation conditions are established THEN obtain the RCS boron sample from the hot leg.

___ 2. IF BOTH of the following:

Shutdown Cooling is in service NO RCPs are in operation THEN obtain the RCS boron sample from the discharge line of the pump operating in the SDC mode.

___ B. WHEN analysis is complete, THEN notify the SM/CRS of the sample results.

___ 6.1.2 IF both BDAS channels are inoperable, THEN direct Chemistry to collect and analyze two samples by performing the following:

___ A. Obtain two RCS boron samples as follows:

___ 1. IF ONE of the following:

At least one RCP is in operation Natural Circulation conditions are established THEN obtain the RCS boron sample from the hot leg.

Boron Dilution Alarm System (BDAS) Inoperable 40ST-9ZZ24 Page 11 of 37 Revision PALO VERDE PROCEDURE 16 6.2 One or Both BDAS Channels Inoperable in Mode 6 Due to Inoperable Startup Range Monitor(s) (LCO 3.9.2)

___ 6.2.1 Perform the following:

___ A. Stop CORE ALTERATIONS.

___ B. Stop positive reactivity additions.

___ C. GO TO Section 6.1, One or Both BDAS Channels Inoperable in Modes 3, 4, 5, or 6 (LCO 3.3.12).

End of Section 6.2 End of Section 6.0