ML21020A098

2020-11 Draft Operating Test Comments

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

Text

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

Generic Scenario Changes Added There are no personnel to Containment for all scenarios Added operator positions for all events Scenario 1:

Driver Setup - Added note to place Protected Equipment placard over AFB-P01 and AFN-P01 Crew Turnover - Added that AFB-P01 and AFN-P01 are protected Event 1 - No changes Event 2 - Specify CS Header valve number o Added valve number Event 2 - Include Appendix C checklist o Included checklist Event 2 - Added LCO 3.7.11 if Essential Filtration fans are stopped Event 3 - Not a separate component failure o Removed event as a separate component failure. Adjusted 301-5 and 301-6 Event 3 - Specify DNBR limit for TS 3.2.4 entry o Added the POL indication that the examinee will be looking at Event 5 - Specify MSIS and CSAS actuation setpoints o Added setpoints Event 5 - Add critical task for securing RCPs o Added critical task Event 5 - Terminate after entering ESD procedure o Updated termination criteria Scenario 2:

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

Added note to place Protected Equipment placard over AFB-P01 and AFN-P01 Crew Turnover - Added that AFB-P01 and AFN-P01 are protected. Added the status of MFPs Event 1 - Specify affected SG o Specified affected SG Event 1 - Proceed to next event once DFWCS alarms reset o Adjusted the point to move to the next event Event 2 - Added the specific battery charger breaker to the Driver Cue Event 3 - Actions to take load off the turbine/borate o Added an Examiner Note that says that if the crew is slow to stop the boration that they will need to take load off the Main Turbine to raise pressure Event 3 - Added breaker noun names to Driver Note Event 4 - No changes

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

Event 5 - Removed boration steps since a boration will not be needed Event 6 - Added driver note for the Attachment 58A performance Scenario 3:

Driver Setup - Added note to place Protected Equipment placard over AFB-P01 and AFN-P01 Crew Turnover - Added that AFB-P01 and AFN-P01 are protected Event 1 - No changes Event 2 - Specify unaffected channel o Specified 100Y Event 3 - Add applicable RM alarms o Added all applicable RM alarms Event 3 - Specify steps to isolate letdown o Included valves that will isolate letdown Event 4 - Removed move changing blowdown constants from move on point Event 5 - Specify procedural source for guidance provided o Added procedural source for guidance Event 6 - Add RM alarms expected o Added expected RM alarm Event 6 - Containment sump, humidity info, sump, temp info o Added Containment parameters to expected indications Event 6 - Determine leak rate steps and add o Added appendix for leak rate determination Event 6 - TS expand 3.4.14 A o Expanded TS information Event 7 - Add note that operator will have to manually start HPSI A o Added Examiner note Event 7 - Add SIAS setpoint and time 30 minute clock starts o Added setpoint and when time starts Event 7 - Add when LOCA starts for 30 minute clock on H2 Analyzers o Added start time Event 7 - Add additional leak rate from Event 6 o Added leak rate Scenario 4:

Driver setup - Added SG feed rate and RCS temperature Crew turnover - Added detail to the turnover Event 1 - Added wait time for Driver Cue Event 2 - Add RCP AOP steps o Added steps

Event 3 - Add AFW valve numbers and note that they will close the valves o Added valve numbers and that the valves will be closed Event 3 - LCO 3.3.6 need I&C cue fuses blown o Added cue Event 3 - Add table C2 from Appendix C o Added appendix Event 3 - TS 3.6.3 applies o Verified with Operations 3.6.3 does not apply and removed from the scenario Event 4 - Add note to what unaffected channel is expected to be switched to (Tave 2) and volts (4.3v) o Added the expected channel and voltage Event 4 - Add note to specify CEDMCS desired mode of operation (manual sequential) o Added note Event 4 - Auto trigger Event 5 when report made o Changed Event 5 initiation to when report to CRS is made Event 7 - Specify to feed using AFA-P01 Added JPM S1:

Where does 11 minute time limit come from?

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

JPM S-2:

Where does 5 minute time limit come from?

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

JPM S-3:

Changed validation time to 5 minutes JPM S-4:

Possible to somehow time compress Step 4?

o Discussed and determined not to time compress

JPM S-5:

In task standard, FVIW should be FWIV.

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

JPM has wrong title (remotely start)?

This is not the title of the JPM, this is the task used from our Master Task List Where does 5 minute time limit come from?

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

JPM S-7:

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

JPM P-2:

JPM P-3:

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

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

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

o Changed cue to per Palo Verde administrative procedural requirements.

JPM A-2:

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

Changed cue to per plant procedural requirements Change validation time from 5 minutes to 10 minutes?

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

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

Changed cue to per Technical Specifications Corrected task standard to only include critical steps Added handout with Pressurizer Vent drawing JPM AS-4:

Removed unisolable from cue.

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

Run this first on administration day so all operators have same start time o Scheduled Corrected task standard to only include critical steps Add time critical requirement in critical step.