ML23143A207

6-PV-2023-05 Form 2.3-3 Draft Operating Test Comments - Palo Verde Generating Station

ML23143A207
Person / Time
Site:	Palo Verde
Issue date:	05/11/2023
From:	Heather Gepford Operations Branch IV
To:	Arizona Public Service Co
References
Download: ML23143A207 (1)

Text

PVNGS 2023-05 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 3.6-4, Operating Test Comments, as exam is determined to be a satisfactory submittal.

Generic Comments:

1. Do we need to have separate scenario guides for the two different simulators given the different rod control systems? Or is the procedural guidance the same for both units? - I dont think we need that. The only operation of Rod Control during the scenarios is changing the mode of operation which is very simple in both systems. I can add the difference in those particular situations to each guide but I think when you see it in person youll understand. Procedurally, there are some differences (i.e. in JPM S1 - which is only being run in Sim A) but I dont think it will be an issue during scenarios.

2. For the scenario events impacting rod control, Id like to carve out some time to run them in Sim B as well to see how they respond on the old system, in addition to seeing it on Ovation CEDMCS during the main run. - Well set up a block of time to do that.

3. Id like to swap the simulators the crews are using between scenario days so that the applicants are evaluated on both, given rod control differences. Understand two SRO-Us will not be evaluated on both Sims, that is not too much of an issue since they both are licensed on the old Rod Control System, and will both get to operate Ovation CEDMCS on JPM S-1. - Will do. One SRO-U is leaving the company so everyone should get a scenario in each simulator.

4. Schedule: I prefer the Rev 0 schedule where the applicants all identify the location of JPM P-2 in-plant first, before performing it. Im strongly considering just having them perform the JPM in-plant for simplicitys sake. On schedule do not show P-2 insimulator, thats too much of a giveaway for a document that wont be controlled under exam security. Show it as P3/P2 in-plant. -

Understood. I was not planning on distributing the detailed schedule to the students at all based on cueing. I would just give them a very high overview schedule with arrival times and basically what it happening that day (i.e.

scenario, sim jpms, plant jpms). The benefit of doing this P2 in the simulator is that the equipment can actually be operated. It could be simulated in the unit, but I think there is more value actually performing it as the ADV controllers in the RSD panel operate a bit different than the CR. Ill do whatever you want after you see in person.

5. I dont have a strong opinion yet on what scenario should be the spare, but the combination 1-3 gives the most margin for beans, slightly. I do like the ESD with release outside of containment on principle though. Will know more after validation. - [Final resolution: Scen 1 is spare]

Scenario 1 (100%):

1. MAJOR: SBO

2. [GENERIC] The position block should be filled out for every step in the guide identifying which applicant is expected to perform that step.

3. [GENERIC] Every step should have the procedure step annotated, if applicable.

4. CT-1 language has changed somewhat from outline and now says Re-establish steaming and/or feeding to at least one SG, previously said restore feed to at least one SG using AFA-P01. It seems to me that if that just re-establish steaming without feeding, that hasnt satisfied the CT yet. Lets discuss. - I modified based on feedback during validations. It is possible to prevent lifting a primary safety valve, at least for a while, via steaming only. However, if feed is not established, you will eventually lose the ability to steam. In the timeframe of a scenario, Im not sure how long it would take to dryout the SGs without feed, but since restoring feed is required to recover the safety function, Im confident it will happen during the scenario and I am fine with including in the CT. What could also happen (I dont anticipate this) is that a crew could steam to keep RCS pressure below the safety lift setpoint, then restore feeding using AFN-P01 when power is restored to PBA-S03. I really dont think we will see anything other than restoring feed with AFA-P01 during SPTAs (or shortly thereafter) but its possible.

We can discuss during prep week.

5. CT-1: explicitly state in measurable performance indicator what components are expected to be used to restore feed and establish steaming. - Ill add these during prep week. Easier that way for me. [Post-Val: I dont see these added]

Added now. Since the measureable performance indicator is really whether or not the crew lifts a primary safety, I thought what was there met the intent of the CT. All switches for feeding/steaming now in CT.

6. Event 1 normal dilution does not count as an MC manual control of an automatic function. The MC criteria requires some automatic function to have failed, so it is inherently tied to an I/C/M event, but not an N or R event. - This was a misconception on my part. I thought that if the operator manually operates a system it counted as MC. Updated on all scenarios.

7. Event 4 same comment about MC what automatic function associated with degraded condenser vacuum has failed? - Understoood. That does not count as MC. Guide updated.

8. Event 4 degraded condenser vacuum, if the OATC is going to perform a power reduction to go along with the BOPs load reduction, then the OATC should get credit for a C as well. We should let them do that. - We dont generally borate during a power reduction for a loss of vacuum unless the reduction was going to be very large and the vacuum degradation was going to be sustained for a extended period of time (to avoid then having to dilute later to restore to original

boron concentration). Load is reduced on the turbine and CEAs step in in automatic.

9. Event 7/8 annotate in brackets after the step where feed is expected to be restored, that AFA-P01 is expected to be started. I dont see AFA-P01 mentioned anywhere by name in the guide aside from the outline. - If not done prior to the verification of RCS Heat Removal, the BOP should do it at that point.

Added a note to the guide in RCS Heat Removal

10. Event 7/8 page 23 examiner note at end is an erroneous repeat from the loss of condenser vacuum event. Should be a scenario termination cue. Fixed

11. [Post-val: Event 5 step 54.5: Add steps from ARP to start CTMT Normal ACU.]

Step 54.5 in the AOP says to ENSURE adequate CTMT normal coolingwhich means to start ACUs if there arent enough running, therefore the AOP step gives sufficient direction. There isnt really a step in the ARP that will address this situation. Justin told the BOP to look at the ARP during prep week to find a step that addresses this situation but then he ultimately realized that since the AOP said to ENSURE adequate fans running, that the BOP should just start 2 fans to restore cooling. I recommend leaving this as is since there is adequate procedural direction in the AOP already.

12. [Post-val: Event 5: Did you research the applicability of LCO 3.8.1 A and D?]

Yes, LCO 3.8.1 A and D both apply in this situation. I believe this was Mahdis question and it was resolved during prep week.

Scenario 2 (75%):

1. MAJOR: ESD outside CTMT

2. [GENERIC] The position block should be filled out for every step in the guide identifying which applicant is expected to perform that step.

3. [GENERIC] Every step should have the procedure step annotated, if applicable.

4. Event 1: I dont believe pumping the RDT to the HUT is creditable as a MC manual control of an automatic function that failed. The rev 12 training states that to credit an event as MC, The automatic function has failed such that plant equipment will not change state in response to plant conditions without operator intervention - Fixed

5. Event 5: What automatic function has to be manually controlled in response to this events loss of non-class instrument bus? - PLCS and PPCS wont function in auto unless Channel X is selected, and SBCS wont respond in automatic on the Reactor trip, requiring the BOP to use ADVs (manual control). I think this would qualify as MC.

6. Event 6 ATWS is also a MC. - Added

7. Event 8 MSIS fails to auto actuate IS also a MC. - Added

8. Is the ESD triggered at the same time as the RCP trip? - Yes, both triggered off Key 6

9. Event 6/7/8 - where is the guidance that allows the operators to pull forward HR-2 step 15 to feed SG? PVGS EOP Operations Expectations calls out various events which require timely response, a SGTL/R with EDG to atmosphere being one of them. Additionally, The EOP writers guide and EOP user guide describe trigger steps (annotated by an asterisk) which can be performed when the conditions in the step are met (we generally refer to that as pulling a step forward).

10. I believe we need to take this event further and allow the crew to commence an RCS depressurization per HR-2 step 14. Will want to see that on validation.

(RCS cooldown is presumably already taken care of by the ESD itself) - Ok, not sure what youll want to see specifically but we can certainly run it out and see what they do.

Scenario 3 (50%):

1. MAJOR: Feed Line Break

2. [GENERIC] The position block should be filled out for every step in the guide identifying which applicant is expected to perform that step.

3. [GENERIC] Every step should have the procedure step annotated, if applicable.

4. Event 5 loss of NC, what automatic function failed that has to be manually controlled, crediting MC? - Because letdown is isolated, pressurizer level is maintained by starting or stopping charging pumps until letdown is restored, but it probably doesnt really meet the intent of MC. Removed MC from the 3.3-1.

5. CT-2: Add this verbiage to the CT to be consistent with previous usage of this CT: *This Critical Task and the 30 minutes time requirement meets Operations Management expectations for an Operating Crew. Modify as appropriate for other CTs using ops expectations. - Added to CT-2 on Scenario 3 as well as CT-2 for Scenario 1 (60 minutes). It did not apply to the other CTs

6. Event 4 (and generically), when a step says something like select the desired steam generator blowdown button or check the correct constant has been inserted in the center box, in brackets after the step identify for the examiner what the correct information/component should be. - Ill have to wait until Im back in the simulator to get that data but I will add that info. Maybe during prep week, might be the next time I have the simulator. Also on Event 4, the OATC may be directed to insert zero blowdown constants but I did not give them credit on the cover sheet. During validation, the crew had the BOP do it but I could see giving each operator a task (could see the CRS direct each to do one evolution)

7. Event 7/8 title says Feed Line BreakER inside containment - Fixed

8. The terminating criteria says when the crew has. Stabilized RCS temperature following rebound on SG #2. Is there going to be a rebound on this feedline break event? If so, there should be a CT associated with controlling it consistent with previous exams. - Good point. The feed line break behaves differently than a steam line break until the SG is almost dry, at which point, it acts like a steam

line break. Adding a CT for it is fine, but I dont know if RCS pressure gets low enough to have SI injection, especially enough to make PTS a valid concern (an potential for lifting a primary safety). We can look during prep week and if it seems appropriate, Ill add a CT. Just not sure if conditions warrant it off the top of my head.

GENERIC JPM Comments

1. On schedule do not show P2 being in the simulator. That would be too obvious what the task may involve. Done

2. Include procedure step numbers and letters in guide. - Done JPM S1:

1. Task standard: Begin with The applicant and rephrase standard accordingly.

2. Its not clear to me what the starting position of RG-4 is for this JPM. Rods on bottom? - Yes. On a cutback, RG-4 and RG-5 CEAs fully insert, RG-3 rods insert based on Tavg/Tref mismatch. From 100%, RG-3 CEAs insert to ~ 120.

3. Can we start this with RG-3 at 105 withdrawn so that the first 10 rod withdrawal restores RG-4 to normal overlap? - I assume its possible. Id have to tinker with the initial conditions or run the cutback, then insert RG-3 CEAs manually to 105 withdrawn. I doubt that would put any parameters out of range but CEAs would be further inserted than would normally be expected. We can ask the crew during prep week. I do like the idea of the JPM ending when the task is actually complete though.

4. Task Standard: delete (acceptable range - Done

5. Will system allow applicant to withdraw RG-4 rods more than 10 at a time? - Yes

6. Include step numbers and letters in guide. [Generic] - Done

7. Make JPM steps 3-5 one step since its just guidance. - Done JPM S-2:

1. Include step numbers and letters in guide. - Done

2. Task standard: Begin with, The applicant completed the following actions: -

Done JPM S-3:

1. Task standard: Begin with The applicant - Done

2. Add Energized at least one pressurizer backup heater to task standard and make JPM step 3 critical. - Done

3. Add procedure step numbers/letters. - Done JPM S-4:

1. Task standard: Begin with The applicant - Done

2. Add procedure step numbers/letters. - Done

3. If no action in JPM step 2 is required to be performed then it is not critical. -

Gotcha. Im always unsure about steps in which they have to diagnose an issue or they will not perform future steps which are critical. Changed to non-critical.

4. Examinee handout spells Time Critical wrong. Fixed JPM S-5:

1. Task standard: Begin with The applicant - Done

2. Add procedure step numbers/letters. - Done JPM S-6:

1. Task standard: Begin with The applicant - Done

2. Add procedure step numbers/letters. - Done

3. JPM Step 2 says Stop depressurizing the RCS but the standard says Ensured RCS pressure is NOW lowering - seems inconsistent. - Typo. Supposed to say not lowering. Fixed JPM S-7:

1. Modify this JPM such that the applicant completes the 2nd manual reduction in DG load from 75 to 50%, and then loss of PKA-M41 occurs automatically at 3.1MW. This makes JPM step 4 critical. - Im not sure if the MW meter can be used as an event trigger but we can look at that during prep week

2. What is the basis for the 5 minute time criticality? Document in guide. - I contacted engineering about this for the 2020 NRC Exam and what they said is that the fuel racks will close immediately and the EDG will be motoring the engine immediately. Amps will spike causing adverse conditions on the EDG.

The specific time until damage would occur was unknown (as this is not an evolution that is tested). The 5 minute time critical standard (which the Ops Rep agreed with) was based on the applicant would having 1 minute to diagnose the event, 1 minute to determine the appropriate ARP section to address, 1 minute to address the steps in the ARP, 1 minute to obtain and address the steps in the AOP, and 1 minute to direct an AO to trip the EDG output breaker locally (for a total of 5 min).

3. Post-val: Edit beginning of task standard to LOWERED EDG load to 3.6-4.4 MW, Done. JPM S7 is now Rev 4

4. JPM step 4 is now critical which is why we changed the task standard. Added

• to step 4.

JPM S-8:

1. Task standard: Begin with The applicant and rephrase standard accordingly.

- Done

2. Add procedure step numbers/letters. - Done

3. Post-val: I wrote down that this should be resnapped to a lower starting power.

Was that determined to be necessary, done? Brian and I looked at this and

realized that we had reset to the wrong IC. We looked at the correct IC for this JPM and power was low enough as snapped. That being said, we will look at this when we see if we can run P2 concurrent with S8 and will snap a new IC to accommodate this schedule change. At that point, we will re-verify that power is low enough to run S8 without issue.

JPM P-1:

1. Task standard: The applicant established hot leg injection by - Done, but slightly reworded to The applicant simulated establishing hot leg JPM P-2:

1. During validation week, well bring this copy of the JPM into the plant with us, I want to see how long it would take if we do it in-plant. I am considering if it is just simpler to do it in-plant, since the applicant will already have to transit to the location. - No problem. It works either way, but I think there is more value in the simulator.

2. If we decide to do it on the simulator, well have 2 cue sheets. The first one will be given in-plant, and it will simply say, The CRS directs you to station yourself at the Remote Shutdown Panel, without giving guidance as to the task to be performed. 2nd cue sheet given on simulator panel. Ok, well see what you want to do after prep week. I went ahead and made two versions, the version that would be done in the simulator has two cue sheets as directed. The one in the plant changed the Task Standard and the standard on each step from perform to simulate. The plant version does not have examiner cues as the JPM was not developed or validated that way, but if you decided to run in the plant, Ill add examiner cues as appropriate.

JPM P-3:

1. The examiner note at the beginning of the guide doesnt reflect how we do in-plant JPMs: The status of breakers during validation are listed in red. Breaker status may be different during JPM administration. Since the position of each breaker during exam administration is not known at this time, every step is marked critical even though some positions will already be in the required end state. The initial position should be how we expect the plant to be aligned per the JPM initial conditions, not how it is actually aligned on administration day, and cued if need be. The critical steps are only those steps for which something actually needs to be manipulated based on expected conditions. - I completely understand the comment, however breakers for equipment such as duct heaters may be open or closed based on the weather. Ill set it up however you want, but not all of the breakers have a standard position. We can discuss what you want the verbiage to be and Ill make it happen.

2. For the examiner cue for each step, lets keep it simple and instead of including a the component is as you see it alternative, just include a single cue for what the final end state of the component is. - Do you mean breaker is open/closed? I

feel like that sort of cue has been forbidden since Ive been writing license exams. I prefer it though, TBH.

3. [Post-val: delete the first paragraph of examiner note before step 1: the status of breakers during validation are listed in red. Breaker status may be different Done

4. The step 1 NOTE you added is good, but needs to also address the trip pushbutton that is on the upper left portion of the cubicle. The trip pushbutton on the upper left of the breaker cubicle is the electrical trip pushbutton.

Since loadcenters get their control power from non-class DC, this trip would still be enabled and would work to trip the breaker. Added this info to the note on JPM step 1 as well as the cue on JPM step 1.

5. Step 1 add asterisk next to NGN-L25C3 and D4 only to show that these are the only critical parts of the step. Done Also, since were in a SBO, verify if any lamps would be illuminated. The indicating lights will be available on the LC (NGN-L25) since control power and indication comes from non-class DC power (batteries still available).

6. Step 2: We are just going to simulate that the breaker is closed as-found so get rid of all that verbiage about what to do if the breaker is found open. Its going to be closed on arrival for this JPM. I understand. Modified the cue (in case the breaker is open) to say, red light is illuminated, green light is extinguished. This step also says red light is illuminated, but were in a SBO so verify if this is correct for this step. Indications will be available on the LC, but not on the MCC (MCC control power comes off an internal 480v to 120v transformer and would thus not be available on the MCC).

7. Step 4: We dont have the pictures referenced for NHN-D03. Provide. I printed and laminated those for both units. Added to Box though so you have a pdf copy.

8. Step 5: During validation the RO said that since he was in SBO, all lamps would be extinguished. But step still says green lights illuminated. Verify and correct.

Fixed. On the MCC, all lights would be extinguished. Corrected the examiner note to reflect this.

JPM A-1:

1. Task standard: Begin with The applicant [Generic]

2. Include a cover sheet that just says JPM A-1 etc at front of every JPM for visual security. [Generic] Cover sheets made, but Ill wait until all comments are resolved prior to adding to each PDF

3. Post-val: Step 2 standard, add,only to end. DONE

4. Step 3 examiner note, modify both sentences to If the applicant Incorrectly uses That is how it already readsnot sure what Im missing here. It actually looks like this comment is intended to have JPM step 4 say, If the applicant incorrectly uses to be consistent with the note in JPM step 3.

Added incorrectly to the note on JPM step 4 and made no change to JPM step 3. If Im missing something, let me know and Ill change again.

JPM A-2:

1. No comments at this time.

JPM A-3:

1. The Task documented on the cover sheet of the JPM should match the task on the outline, and be more specific than Perform a surveillance test - Done

2. Direct the applicant in cue to calculate the leak rate to 3 decimal places.

Otherwise somebodys going to round up. - 2nd bullet in the cue already says that. Is there something Im missing?

JPM A-4:

1. Include a marked up App B key for examiner during validation and exam week. -

Once the Admin JPMs are approved, Ill make an answer key for each JPM for each day.

JPM A-5:

1. No comments at this time.

JPM A-6:

1. Rephrase the first question Did the site satisfy minimum manning requirements of 40DP-9OP02, Conduct of Operations, during the timeline of events? - Done

2. Rename Ace D. Generate to something else. Nothing cute on an NRC exam. -

Changed JPM A-7:

1. - Rephrase cue to require applicant to identify the LATEST time the LCO is required to be entered this is to address the comment you included in JPM step 5 about misunderstanding the time the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> concurrent inoperability clock is started. - Done. Updated the Task Standard to reflect the change to the cue and deleted the note in step 5.

JPM A-8:

1. Meteorlogical is misspelled in initial conditions.

2. Task standard does not include a time limit.

3. Initial Conditions should clarify that this is the INITIAL PAR after the GE declaration. - JPM is being replaced

4. My branch chief and I discussed the use of a PAR for a radiation protection JPM, and we both agree that while the nexus to KA 2.3.14 makes sense, this is fundamentally an E-Plan JPM which overlaps with A-9. Specific comments:

Since the cue states that there are no dose assessments available (other than below federal limits), all the applicant has to do is look at the digital readouts provided for RU-148 and RU-149, and compare it against the values provided in the PAR flowchart to determine whether or not the accident is rapidly progressing. I would argue that isnt really analysis/interpretation of the radiation readings. More fundamentally, the JPM doesnt require the applicant to demonstrate any knowledge of the radiation hazards associated with the accident. Request a different JPM with more direct nexus to RP knowledge and abilities. - In the process of developing a replacement. There isnt a lot to choose from at PV as we are zero liquid release plant. One release evolution we do is the release of Waste Gas Decay Tanks. We had a JPM on the previous exam (2022) in which a loss of power took out the Plant Vent RMs and the applicant had to determine whether or not the release could continue and if so, what was required to continue/re-initiate the release. Im looking at a JPM in which RU-12, the Waste Gas Decay Tank monitor, is OOS and the tank needs to be released. It would be a new JPM as the actions are different than the actions for Plant Vent without the required RMs. Another option would be a post-accident situation in which the applicant has to select an operator to perform high exposure work (protection of equipment or life-saving actions) and determine whos approval is required (or when it would be required). This would be a modification of A4 from the 2020 PVNGS NRC Exam. Not sure if you have a preference, or something else in mind. Feel free to weigh in here. Trying to put this together prior to prep week and we have the Audit Exam next week.

JPM A-9:

1. No comments at this time.