IR 05000528/2015301

Er 05000528/2015301; 05000529/2015301; 05000530/2015301; 04/13/2015 - 05/13/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Initial Operator Licensing Examination Report

ML15161A096
Person / Time
Site:	Palo Verde
Issue date:	06/10/2015
From:	Vincent Gaddy Operations Branch IV
To:	Edington R K Arizona Public Service Co
References
50-528/15-301, 50-529/15-301, 50-530/15-301
Download: ML15161A096 (13)

Text

June 10, 2015

Mr. Randall Executive Vice President Nuclear/CNO

Arizona Public Service Company P.O. Box 52034, MS 7602 Phoenix, AZ 85072-2034

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC EXAMINATION REPORT 05000528/2015301; 05000529/2015301; 05000530/2015301

Dear Mr. Edington:

On May 13, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on April 17, 2015, with Mr. G. Andrews, Director, Nuclear Regulatory

Affairs, and other members of your staff. A telephonic exit meeting was conducted on May 13, 2015, with Mr. R. Lange, Director, Nuclear Training, who was provided the NRC licensing decisions.

The examination included the evaluation of 11 applicants for reactor operator licenses, 9 applicants for instant senior reactor operator licenses, and 4 applicants for upgrade senior reactor operator licenses. The license examiners determined that all applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were two post examination comments submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post examination comment resolution.

A licensee-identified violation was identified during this examination. It is described in more detail in Section 4OA7 of this examination report.

In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter and its enclosure will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Managem ent System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Vincent G. Gaddy, Chief Operations Branch Division of Reactor Safety Dockets Nos. 50-528, 50-529, and 50-530 Licenses Nos. NPF-41, NPF-51, and NPF-74

Enclosure:

1. NRC Examination Report 05000528/2015301; 05000529/2015301; 05000530/2015301 2. NRC Review of Written Post-Examination Comments cc: Electronic Distribution

ML15161A096 SUNSI Review By: VGG ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive Keyword: NRC-002 OFFICE OE:OB OE:OB SOE:OB OE:OB OE:OB OE: OB OE:OB NAME CSteely SHedger COsterholtz TBuchanan MHayes MBloodgood MKennard SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 6/9/15 6/9/15 6/8/15 6/8/15 6/8/15 6/7/15 6/8/15 OFFICE SRTI:PWR (TTC) C: PBD C:OB NAME GCallaway GMiller VGaddy SIGNATURE /RA/ /RA/ /RA/ DATE 6/9/15 6/9/15 6/10/15 Letter to Randall from Vincent G. Gaddy, dated June 10, 2015

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC EXAMINATION REPORT 05000528/2015301; 05000529/2015301;

05000530/2015301

Electronic distribution by RIV

Regional Administrator (Marc.Dapas@nrc.gov) Deputy Regional Administrator (Kriss.Kennedy@nrc.gov) DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov) Senior Resident Inspector (Charles.Peabody@nrc.gov) Resident Inspector (Dustin.Reinert@nrc.gov)

Resident Inspector (David.You@nrc.gov)

Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov) Project Engineer, DRP/D Brian.Parks@nrc.gov) Project Engineer, DRP/D (Jan.Tice@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Team Leader, DRS/TSS (Don.Allen@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov) RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov) RIV/ETA: OEDO (Michael.Waters@nrc.gov) Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 50-528; 50-529; 50-530 License: NPF-41, NPF-51, NPF-74 Report: 05000528/2015301; 05000529/2015301; 05000530/2015301 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location:

5951 S. Wintersburg Road Tonopah, Arizona Dates: April 13 - May 13, 2015 Inspectors: C. Steely, Chief Examiner, Operations Engineer C. Osterholtz, Senior Operations Engineer S. Hedger, Operations Engineer M. Kennard, Operations Engineer M. Bloodgood, Operations Engineer M. Hayes, Operations Engineer T. Buchanan, Operations Engineer

G. Callaway, Senior Reactor Technology Instructor (TTC) Approved By: Vincent G. Gaddy Chief, Operations Branch

Division of Reactor Safety Enclosure 1

SUMMARY

ER 05000528/2015301; 05000529/2015301; 05000530/2015301; 04/13/2015 - 05/13/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Initial Operator Licensing Examination

Report.

NRC examiners evaluated the competency of 11 applicants for reactor operator licenses, 9 applicants for instant senior reactor operator licenses, and 4 applicants for upgrade senior reactor operator licenses at Palo Verde Nuclear Generating Station, Units 1, 2, and 3.

The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on April 21, 2015. NRC examiners administered the operating tests the week of April 13, 2015.

The examiners determined that all 24 of the applicants satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued.

A. NRC-Identified and Self-Revealing Findings

None.

B. Licensee-Identified Violations

A severity level IV violation that was identified by the licensee has been reviewed by the examiners. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. The violation and corrective action tracking number are listed in Section 4OA7 of this report.

1

REPORT DETAILS

4OA5 Other Activities (Initial Operator License Examination)

.1 License Applications

a. Scope

NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. Examiners also audited five of the license applications in detail to confirm that they accurately reflected the subject applicant's qualifications. This audit focused on the applicant's experience and on-the-job training, including control manipulations that provided significant reactivity changes.

b. Findings

No findings were identified.

.2 Examination Development

a. Scope

NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.

b. Findings

No findings were identified.

NRC examiners provided outline, draft examination, and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.

NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.

During examination validation and administration, the NRC and licensee examination teams identified two procedure enhancement opportunities that were captured by Condition Reports PVAR 4645289 and PVAR 4647784.

.3 Operator Knowledge and Performance

a. Scope

On April 21, 2015, the licensee proctored the administration of the written examinations to all 24 applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post examination comments to the NRC on April 29, 2015. These items were reviewed on May 7, 2015 The NRC examination team administered the various portions of the operating tests to all applicants the week of April 13, 2015.

b. Findings

No findings were identified.

All 24 of the applicants passed the written examination and all parts of the operating test. The final written examinations and post examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in the attachment, which includes two post examination comments. There were two post examination comments that requested a change to the answer key, Questions 29 and 84, to which the NRC regional office accepted the recommended changes and the answer key was changed accordingly. (See Enclosure 2 for a brief synopsis of the questions, the comments, and the NRC resolution of these comments. The complete submittal can be found in the ADAMs system using accession number ML 15146A008.) The licensee generated Condition Report PVAR 4647769 to address this issue.

The examination team noted the following generic weaknesses:

There were three questions missed by 50 percent or more of the applicants, with each question analyzed by the licensee as required by NUREG-1021. One question was determined to be a failure of attention to detail and the other two were regarded as knowledge weaknesses. The licensee wrote Condition Report PVAR 4656619 to address the written examination weaknesses.

Several applicants, during the performance of placing the Boron Dilution Alarm System in service, failed to place the Source Range Yokogawa recorders from "Control Channel" to "Start-Up Channel." This resulted in an incorrect Source Range output reading and consequently a failure in the acceptable calculation and job performance measure (JPM). The licensee wrote Condition Report PVAR 4646824 to assess both the procedure and the knowledge deficiency.

Several failures were noted in the JPM performance of resetting a main steam isolation signal (MSIS). The procedure requires the resetting of MSIS Actuation Logic in BOTH the 'A' and 'B' train of NSSS/ESFAS Actuation Logic Cabinets. Several applicants stopped after only resetting the 'A' train. The licensee wrote Condition Report PVAR 4647773 to address this weakness.

During the performance of the loss-of-coolant accident (LOCA) scenarios, it was noted that several crews, during the standard post trip actions (SPTAs) continued to discuss pressurizer level and pressure as if they were going to control them in the normal control band; although, this was clearly not going to be the case. This is a general Palo Verde practice throughout licensed operator initial training. Condition

Report PVAR 4647782 was generated to request a management review of this practice and to determine if any changes/corrections need to be made.

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performanc e with regard to plant fidelity during examination validation and administration.

b. Findings

No findings were identified.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

A licensee identified violation of 10 CFR 55.49, "Integrity of Examinations and Tests,"

occurred and is discussed in Section

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. G. Andrews, Director, Nuclear Regulatory Affairs, and other members of the staff on April 17, 2015. A telephonic exit was conducted on May 13, 2015, between Mr. C. Steely, Chief Examiner, and Mr. R. Lange, Director, Nuclear Training.

The licensee did not identify any information or materials used during the examination as proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) and Severity Level IV was identified by the licensee and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy, for bei ng dispositioned as a Non-Cited Violation.

Title 10 CFR 55.49, "Integrity of Examinations and Tests," requires, in part, that facility licensees shall not engage in any activity that compromises the integrity of any application, test, or examination required by th is part. Contrary to the above, on April 14, 2015, the licensee engaged in an activity that compromised the integrity of the examination. Specifically after administrative JPMs had been administered to the applicants by the examination team, the licensee, upon performing their examination security walk-down, neglected to secure a three-ring binder that contained two reactor operator and two senior reactor operator administrative JPMs that were to be performed the next day. All four JPMs were left unattended and unsecured until 5:00 a.m. on April 15, 2015, when they were discovered as part of the licensee examination security preparation procedure. The four compromised JPMs were replaced by new

administrative JPMs as required by NUREG-1021. The failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process because it impacted the ability of the NRC to perform its regulatory oversight function. This resulted in assignment of a Severity Level IV violation because it involved a non-willful compromise of examination integrity and is consistent with Section 6.4.d of the NRC Enforcement

Policy.

The associated performance deficiency was screened as Green because there was not an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59, "Integrity of Examinations and Tests." The licensee entered this issue into their corrective action program as PVAR 4645293.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Andrews, Director, Nuclear Regulatory Affairs

R. Lange, Director, Nuclear Training

J. Allison, Section Leader, Nuclear Training

L. Burton, Senior Instructor, Nuclear Training

D. Heckman, Senior Consultant, Nuclear Regulatory Affairs

C. Cruise, Section Leader, Nuclear Training

NRC Personnel

C. Peabody, Senior Resident Inspector

ADAMS DOCUMENTS REFERENCED

Accession No. ML15139A117 - FINAL WRITTEN EXAMS (Delayed release until April 21, 2017) Accession No. ML15148A299 - FINAL OPERATING TEST

Accession No. ML15146A008 - POST EXAM ANALYSIS-COMMENTS

NRC Resolution of PVNGS Written Post Examination Comments Note:

A complete text of the licensee's post examination analysis and comments can be found in ADAMS under Accession Number ML15146A008.

Question 29

Given the following conditions:

• Unit 1 is operating at 100% power

(1) What is the predicted effect on the RCS if a Purification ion exchanger that has been isolated for 5 days is placed in service without performing any pre-service flushes?

(2) What actions should be taken to offset the reactivity change?

A. (1) RCS temperature will rise (2) RCS dilution

B. (1) RCS temperature will rise (2) RCS boration

C. (1) RCS temperature will lower (2) RCS dilution D. (1) RCS temperature will lower (2) RCS boration

Proposed Answer: C

Licensee Comments for Question 29:

In the justification section for this question the licensee wrote the following:

"Even though an isolated and cooled down IX placed in service would have an affinity to absorb boron the over-riding effect would be the 10-15 ppm RCS dilution that would had occurred over those 5 days due to fuel depletion. Therefore placing the IX back in service without pre-service flushes would have caused a small boration and subsequent lowering of RCS temperature. To maintain 100% reactor power and RCS T-cold on program the operators would dilute to offset the negative reactivity and raise RCS T-cold to the program value."

"Both 'C' and 'D' were correct in part (1) in that RCS temperature will lower when placing an isolated ion exchanger in service.

However, in response to a lower RCS temperature the crew would (2) "dilute" not borate making 'C' the correct answer.

The validation process failed to identify 'C' as the correct answer.

The correct answer has been verified with both Training and Operations staff."

NRC Resolution of Question 29:

The NRC reviewed the licensee's submittal and concluded that the licensee is correct; in that 'C' is the only correct answer.

In order to offset the initial negative reactivity change of the addition of boron from the ion exchanger and subsequent lowering of RCS temperature, the operators would be required to perform a dilution to add negative reactivity and raise RCS temperature back to the normal control band.

SRO QUESTION # 84

Given the following conditions:

• Unit 1 is in a refueling outage.

• Spent fuel is being moved in the SFP.

• A seismic event alarm occurs, with readings < 0.1g. * The event is NOT felt in the plant. * The SFP LEVEL

HI-LO (EO0204A) on

PCN-E02 alarm actuates.

RU-31, Spent Fuel Pool Area monitor is in HIGH Alarm.

• The LSRO reports an incident with the fuel being moved in the SFP.

RU-145, Fuel Building Ventilation Low Range monitor, and

RU-146, Fuel Building

Ventilation High Range monitor, readings are stable below the ALERT setpoint.

Which of the following is the current classification level and highest applicable EAL and would be reported to state and federal agencies?

EAL tables are provided

A. Notification of Unusual Event,

HU1.1

B. Alert,

HA1.1

C. Alert,

RA2.2

D. Notification of Unusual Event,

RU2.1

Proposed Answer: D

Licensee Comments for Question 84:

In the justification section for this question the licensee wrote the following:

"The original version of this question identified EAL

RA2.2 as the correct answer.

Following the initial validation of the question, it was identified that the question required modification to ensure no overlap issues.

This revision change to the question stem made the previous correct answer incorrect.

The correct answer was not properly updated on the answer key."

NRC RESOLUTION of Question 84:

The NRC agrees with the licensee's recommendation to change the correct answer on the key

from 'C' to 'D'.

The question and answer is unchanged since the NRC examination review.

The answer as reviewed by the NRC has always been 'D' and therefore the answer key was correctly changed to reflect this status.