ML23145A277

10-PV-2023-05 Post-Exam Comments

ML23145A277
Person / Time
Site:	Palo Verde
Issue date:	05/17/2023
From:	Dilorenzo M Arizona Public Service Co
To:	Heather Gepford, Robert Lewis NRC Region 4
References
102-08621-MDD/JR
Download: ML23145A277 (1)

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 Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7636 Tel 623 393 3495 102-08621-MDD/JR May 1, 2023 R. J. Lewis, Acting Regional Administrator U.S. Nuclear Regulatory Commission, Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511

Reference:

Nuclear Regulatory Commission (NRC) letter, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Notification of NRC Initial Operator Licensing Examination, dated July 15, 2022 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML22196A378]

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, 50-530 2023 Post-Examination Comments and Analysis Submittal Arizona Public Service Company (APS) management has completed its review of the initial operator licensing examination conducted May 1 through May 11, 2023. 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, Dilorenzo, Michael Digitally signed by Dilorenzo, Michael D(Z99838)

D(Z99838) Date: 2023.05.17 18:42:00 -07'00' Michael D. DiLorenzo Department Leader, Nuclear Regulatory Affairs MDD/JR A member of STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 6 Given the following conditions:

Unit 1 is in MODE 4 SDC is in service on Train B using the B LPSI Pump The A LPSI Pump is OOS for emergent maintenance Subsequently:

The B Spray Pond Pump tripped (1) Per 40EP-9EO11, Lower Mode Functional Recovery, the PREFERRED action the crew should take to restore SDC flow is to (2) The REASON for the option in Part 1 being the preferred option is because (1) cross-tie Nuclear Cooling Water to Train B Essential Cooling Water 8% A. to restore cooling to the B EW Heat Exchanger (2) this alignment will restore SDC flow in the shortest amount of time (1) cross-tie Nuclear Cooling Water to Train B Essential Cooling Water to restore cooling to the B EW Heat Exchanger 0% B.

(2) this alignment will prevent making both trains of Essential Spray Pond inoperable (1) place Train A SDC auxiliaries in service and align the B LPSI 58% C. Pump to the A SDCHX (2) class equipment should be used before non-class equipment (1) place Train A SDC auxiliaries in service and align the B LPSI Pump to the A SDCHX 33% D.

(2) this alignment will prevent creating elevated dose rates outside of the Aux Building Analysis: This concept is adequately trained in both the LMFR and Introduction to EOPs lesson plans and this exact situation is explicitly stated in the LMFR lesson plan.

Student feedback was that they dont focus on the LMFR very much, especially compared to the other EOPs. They agreed that the question was fair and covered in the program.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 7 Given the following conditions:

Unit 3 is operating at 100% power RCN-PIC-100, Pressure Master Control, is in AUTO Both Proportional Heater Banks are ON Subsequently:

The feeder breaker for Proportional Heaters Bank B02/B08/B14 tripped The FIRST alarm that should annunciate is ___(1)___ and per the Alarm Response Procedure, the FIRST action the OATC should take is to

___(2)___ as needed to maintain pressure in the normal operating band.

(1) 4A01B PZR PRESS HI-LO 0% A.

(2) place RCN-PIC-100 in MANUAL and adjust the output (1) 4A01B PZR PRESS HI-LO 33% B.

(2) manually energize Backup Heater banks (1) 4A01A PZR TRBL 17% C.

(2) place RCN-PIC-100 in MANUAL an adjust the output (1) 4A01A PZR TRBL 50% D.

(2) manually energize Backup Heater banks Analysis: The conditions which bring in the PZR TRBL alarm are covered in the PPCS lesson plan. Additionally, several PPCS failures are run during the program, both in scenarios and JPMs.

Student feedback was that they werent 100% sure if the heater trip would bring in the PZR TRBL alarm but they knew that the PZR PRESS HI-LO alarm would come in so they went with that one. The two who picked C just werent sure what action was directed first in the ARP.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 21 Given the following conditions:

Unit 3 is operating at 100% power An irradiated fuel assembly was being moved in the Spent Fuel Pool when the assembly fell and is showing indication of breached cladding (1) Per 40AO-9ZZ22, Fuel Damage, the crew should ensure that _____.

(2) Under these plant conditions, changing ventilation _____ expected to result in significant changes to SFP level.

(1) an equal number of Aux Building supply and exhaust fans are 0% A. running (2) IS (1) an equal number of Aux Building supply and exhaust fans are 67% B. running (2) is NOT (1) at least one more Aux Building exhaust fan is running than supply 0% C. fans (2) IS (1) at least one more Aux Building exhaust fan is running than supply 33% D. fans (2) is NOT Analysis: The fuel damage AOP clearly indicates the required actions for operating ventilation during a fuel damage event and this is covered in the Fuel Damage lesson plan. No one missed part 2 of the question.

Student feedback was that since this is not an AOP that gets exercised in the simulator, it just gets pushed to the back of the line when it comes to studying AOPs. Without performing it in the simulator, there isnt any mental muscle memory to lean on during a written exam.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 25 Given the following conditions:

Unit 1 is operating at 100% power RCS Letdown Line Radiation Monitor, RU-155D, has just received a HIGH alarm on the RMS computer (1) The HIGH alarm on RU-155D _____ automatically isolate letdown flow.

(2) The HIGH alarm on RU-155D _____ cause 3A10B, LD PROCESS MON TRBL, to annunciate.

(1) SHOULD 0% A.

(2) SHOULD (1) SHOULD 0% B.

(2) should NOT (1) should NOT 58% C.

(2) SHOULD (1) should NOT 42% D.

(2) should NOT Analysis: The conditions to bring in the 3A10B alarm are covered in the CVCS Letdown System lesson plan. No one missed the first part of the question.

Student feedback was that they didnt think that RU-155D alarm would bring in 3A10B, but the noun name of the alarm made it seem like it had to. Some also said that they were hesitant to choose (should NOT / should NOT) as an answer.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 29 Given the following conditions:

Unit 2 is cooling down for a refueling outage Both LPSI Pumps are OOS for a common cause issue Per 40OP-9SI01, Shutdown Cooling Initiation, in order to place a CS Pump in service for SDC, RCS temperature must be less than or equal to a MAXIMUM of ___(1)___ and RCS pressure must be less than or equal to a MAXIMUM of ___(2)___ .

(1) 185°F 67% A.

(2) 210 psia (1) 185°F 0% B.

(2) 250 psia (1) 200°F 0% C.

(2) 210 psia (1) 200°F 33% D.

(2) 250 psia Analysis: The 185/210 entry conditions for SDC on CS are values used during EOPs, however during normal operations, 200/250 are the required values. This is covered in the Safety Injection lesson plan.

Student feedback was that they generally knew the values for SDC entry conditions (A and D) but that they couldnt remember which values were for normal entry and which were for entry from an EOP. Those that got it wrong all thought that the less restrictive values would be used during an EOP. They acknowledged that this is well trained, however it was mainly studied during systems phase which concludes ~ 1 year before the NRC Exam.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 30 (1) Per 40EP-9EO03, Loss of Coolant Accident, hot leg injection should NOT be commenced until a MINIMUM of _____ hours have elapsed since the start of the LOCA.

(2) The reason for waiting the amount of time in Part 1 to align hot leg injection is to PREVENT...

(1) 2 67% A. (2) borated water injected into the hot leg being entrained in the steam being released through the break (1) 2 33% B. (2) excessive boron injection from causing boron precipitation from occurring in the coolant flow channels (1) 3 0% C. (2) borated water injected into the hot leg being entrained in the steam being released through the break (1) 3 0% D. (2) excessive boron injection from causing boron precipitation from occurring in the coolant flow channels Analysis: This concept is adequately covered in the LOCA lesson plan. B(2) is the basis for terminating hot leg injection prior to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the start of the LOCA. No one missed part 1 of the question.

Student feedback was that they just got confused with the overall intent for hot leg injection and the reason for not starting it until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> has elapsed.

Training on this topic is adequate.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 84 Given the following conditions:

Unit 1 is operating at 100% power A SGTL has occurred in SG #1 Chemistry has just confirmed a qualitative leak rate of 75 gpd and stable This leak rate requires the unit to be in MODE 3 within a MAXIMUM of

___(1)___ per ___(2)___ .

(1) 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 0% A.

(2) LCO 3.4.14, RCS Operational LEAKAGE (1) 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 60% B. (2) 40AO-9ZZ02, Excessive RCS Leakrate, Appendix F, Steam Generator Tube Leak Guidelines (1) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0% C.

(2) LCO 3.4.14, RCS Operational LEAKAGE (1) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 40% D. (2) 40AO-9ZZ02, Excessive RCS Leakrate, Appendix F, Steam Generator Tube Leak Guidelines Analysis: While detailed knowledge about Appendix F from memory could be considered beyond the scope of a closed book written exam, if the applicant knows that LCO 3.4.14 has a limit of 150 gpd per SG and that the required time to be in MODE 3 for exceeding LCO 3.4.14 is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, then they should know that Appendix F should be applicable and that a leakrate of < 150 gpd with no rising trend should have a less restrictive time to be in MODE 3.

The SROs who missed this question thought that LCO 3.4.18, SG Tube Integrity, would apply making 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> correct, but not to comply with LCO 3.4.14, RCS Leakage. During the review, they acknowledged that 3.4.18 doesnt apply until 150 gpd is reached in a SG so their thought process was incorrect.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 92 Given the following conditions:

Unit 1 is in MODE 6 78ST-9FH01, Refueling Machine Load Test and 78ST-9FH02, Fuel Building Crane Travel, are being performed to ensure TRM requirements are met prior to commencing the core offload The Refueling Machine hoist overload interlock actuated at 1575 lbs The Fuel Building Crane hoist overload interlock actuated at 2000 lbs Based on the surveillance test results, the Refueling Machine ___(1)___

FUNCTIONAL and the Fuel Building Crane ___(2)___ FUNCTIONAL.

(1) IS 20% A.

(2) IS (1) IS 20% B.

(2) is NOT (1) is NOT 60% C.

(2) IS (1) is NOT 0% D.

(2) is NOT Analysis: This KA is a bit beyond the scope of what SROs are trained in the LOIT program at PVNGS, however failure to train on a topic is not a justifiable reason to reject a KA per NUREG 1021. The applicants do get trained on Fuel Handling Equipment, but knowledge of the ST requirements not specifically covered. The TLCO requirement for 1600 overload setpoint on the Refueling Machine is covered in the Refueling Machines lesson plan (which corresponds to the ST), and Spent Fuel Pool moves are covered in the lesson plan, although the limit of 2000 lbs was not located in the lesson plan itself. There are questions in the LOIT bank that ask about the TLCO limit of 2000 lbs for moves over spent fuel. (this TLCO limit corresponds to the ST for the fuel building crane).

Student feedback was that this is a KA that has little to no operational relevance and that even if this was trained additionally in the program, they would have still be guessing on this question.

==

Conclusion:==

Consider adding verbiage about the 2000 lb limit for moves over the spent fuel pool. Question is valid, however may border on LOD 5. Question is technically accurate though.

2023 PVNGS NRC Initial Written Exam Performance Analysis (< 70% Pass Rate Questions)

Question 94 Given the following timeline of events for the Unit 1 CRS:

0515 - 0530: Transit from parking lot to Unit 1 0530 - 0600: Turnover in the Unit 1 Control Room with the off-going CRS 0600 - 1200: CRS in the Unit 1 Control Room 1200 - 1300: Meeting with Operations Director in cafeteria for SM qualification 1300 - 1800: CRS in the Unit 1 Control Room (turnover from 1730-1800) 1800 - 1830: Interview regarding equipment mis-position during the shift 1830 - 1845: Transit from interview to parking lot Per 01DP-9AP17, Managing Personnel Fatigue, what is the MINIMUM amount of time which is REQUIRED to be counted as work hours for the purpose of fatigue management?

20$ A. 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 20% B. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 40% C. 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 20% D. 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> Analysis: The activities which are and are not required to be counted towards fatigue are covered in the Fatigue Management lesson plan.

Student feedback was that they just werent sure if what time they got paid for matched up with what time counted towards fatigue. The ones who missed it acknowledged that they just overthought the question. They felt it was a fair question.

==

Conclusion:==

Question is fine as is.

2023 PVNGS NRC Initial Written Exam Seating Chart Door Kitchen Restrooms Physical Physical Hallway Barrier Barrier Door Door SROs shaded in yellow Podium Proctors Proctors Screen Front of Auditorium

Questions Asked During NRC Written Exam Q# Applicant Question and Answer 4 Q: What does slowly mean for RWT level lowering A: At the rate you would expect based on conditions in the stem 13 Q: Am I supposed to answer based on an automatic action that will cause entry into RPCB AOP or can I consider required operator actions as well?

A: (posted) For each of the listed conditions, consider either automatic plant response or required operator actions 77 Q: Can I assume standard thumbrules apply?

A: Unless conditions in the stem indicate otherwise, assume normal plant response per the NUREG briefing 9 Q: Can I assume a nominal 12 gpm of bleedoff flow since the acceptable range is as low as 4 gpm?

A: Answer based on normal indications you would see in the unit 79 Q: Is the question asking if the NAN Emergency Message Form would have to be filled out or updated to indicate a release in progress?

A: Yes 80 Q: Can I assume that temp just exceeded 650 or it is far beyond 650?

A: You can assume temperature has just exceeded 650 15 Q: Is the question asking if it can be verified from the control room that control power is available or that it is specifically aligned to the alternate source?

A: Can the availability of control power be observed from the control room

93 Q: Are the MSIV accumulators that are inop on the same train or different trains?

A: Answer as written 88 Q: Can I assume that if I dont have enough information to indicate that subcooling has met an EAL threshold that the threshold has not been met?

A: Answer as written 54 Q: Can I assume that Appendix A (EW-NC Cross-Tie) is complete?

A: Yes