ML18200A291

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Notification of Inspection (NRC Inspection Report 0500528/2018004; 05000529/2018004, 05000530/201804 and Request for Information
ML18200A291
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 07/24/2018
From: Vincent Gaddy
Operations Branch IV
To: Bement R
Arizona Public Service Co
References
IR 2018004
Download: ML18200A291 (7)


See also: IR 05000528/2018004

Text

July 24, 2018

Mr. Robert S. Bement

Executive Vice President Nuclear/

Chief Nuclear Officer

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 -

NOTIFICATION OF INSPECTION (NRC INSPECTION REPORT

05000528/2018004, 05000529/2018004, 05000530/2018004 AND REQUEST

FOR INFORMATION

Dear Mr. Bement:

From September 24, 2018 to September 28, 2018, inspectors from the Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline biennial requalification

inspection at Palo Verde Station, using NRC Inspection Procedure 71111.11B, Licensed

Operator Requalification Program. Experience has shown that this inspection is a resource

intensive inspection both for the NRC inspectors and your staff. In order to minimize the impact

to your onsite resources and to ensure a productive inspection, we have enclosed a request for

documents needed for this inspection. These documents have been divided into three groups.

The first group (Section A of the enclosure) identifies information to be provided prior to the

inspection to ensure that the inspectors are adequately prepared. The second group (Section B

of the enclosure) identifies the information the inspectors will need upon arrival at the site. The

third group (Section C of this enclosure) identifies the items which are necessary to close out

the inspection and are usually sent a few weeks after the team has left the site. It is important

that all of these documents are up to date and complete in order to minimize the number of

additional documents requested during the preparation and/or the onsite portions of the

inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Mr. John Rodgers of your training

organization. Our inspection dates are subject to change based on your updated schedule of

examination activities. If there are any questions about this inspection or the material

requested, please contact the lead inspector Nicholas Hernandez (832) 689-9928

(nicholas.hernandez@nrc.gov) or Clyde Osterholtz at (817) 200-1269

(clyde.osterholtz@nrc.gov).

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, control number 3150-

R. Bement 2

0018. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRCs "Agency Rules of Practice and Procedures," 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

NRCs document 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

Docket: 50-05000528/529/530

License: NPF-41, NPF-51, NPF-74

Enclosure:

Inservice Inspection Document Request

ML18200A291

X SUNSI Review ADAMS: Non-Publicly Available X Non-Sensitive Keyword:

By: NAH X Yes No X Publicly Available Sensitive

OFFICE OE:OB OE:OB C:OB

NAME NHernandez COsterholtz VGaddy

SIGNATURE /RA by Email/ /RA by /RA/

Email/

DATE 07/19/18 07/23/18 07/24/18

BIENNIAL REQUALIFICATION INSPECTION DOCUMENT REQUEST

From: Nicholas Hernandez

Operations Engineer, NRC RIV

832-689-9928

To: John Rodgers

Supervisor, Palo Verde

623-393-6335

Subj: Information Request to Support September 24-28, 2018, Licensed Operator

Requalification Program Inspection (IP 71111.11B)

A. The following information is requested in order to support inspection preparation

activities. These items are listed by section as they appear in the inspection module

(ie 2.02, 2.04, etc). Requested materials should be sent either electronically or by

CD/DVD in order to arrive at the Region IV office no later than August 16, 2018. Do

not send USB flash drives.

  • Electronically: To: Nicholas.Hernandez@nrc.gov (lead inspector);

Cc: Clyde.Osterholtz@nrc.gov (inspector)

  • Physically: To: US Nuclear Regulatory Commission, Region IV

1600 E. Lamar Blvd

Arlington, TX 76011

ATTN: Clyde Osterholtz

General Requests:

  • List of licensed operators (SRO & RO) by crew (operating & staff)
  • Training and Operations Department organization charts (with qualified LOR

evaluators identified)

  • Procedures that identify process for revising and maintaining LOR continuing training

program

  • List of outstanding LOR program changes
  • List of plant events and industry operating experience incorporated into LOR

program since last BRQ

  • Audits and/or self-assessment reports addressing the LOR training program
  • Last two years of simulator review committee (or equivalent) meeting minutes
  • Last two years of Curriculum Review Committee (or equivalent) meeting minutes

02.03: Biennial Requalification Written Examination Quality

  • The current and approved biennial written examination schedule
  • The current requalification cycle written examination results to date
  • All written examinations that have been approved for administration up to the date of

submittal. Include password protection if e-mailed or double envelope protection if

mailed per NUREG-1021.

  • The current requalification cycle examination methodology (sample plan)

02.04: Annual Requalification Operating Test Quality

  • The schedule for the operating tests to be given the week of September 24, 2018

Enclosure

  • All operating tests (password protected) that have been approved for administration

up to and including the week of the onsite inspection

  • All 2017 NRC-required annual operating tests
  • Current requalification cycle operating test results
  • Current requalification cycle operating test methodology (sample plan)

02.05: Licensee Admin of Requal Exams

  • All procedures used to administer the annual operating test
  • All procedures used to assess operator performance
  • All procedures that describe conduct of simulator training
  • All procedures used to test, operate, and maintain the simulator

02.06: Requalification Examination Security

  • Tracking tools used to prevent excessive overlap on the written examinations and

ensure sampling of required topics on a periodic basis

  • Tracking tools used to prevent excessive overlap on the operating tests and ensure

sampling of all required malfunctions (major events, instrument/component

malfunctions, TS calls, etc.) on a periodic basis.

  • All Procedures that describe examination security, including procedures used to

develop the examinations that include guidelines on overlap between examinations

in current exam cycle tests and prior year examinations

  • List of all Condition Reports since the last biennial requalification inspection related

to examination security and overlap

02.07: Licensee Remedial Training Program

  • List of remedial training conducted or planned since last biennial requalification

inspection (includes remedial training for exam failures and training to correct generic

or individual weaknesses observed during previous requal exam cycle)

  • Remediation plans (lesson plans, reference materials, and final documentation)

02.08: Conformance with Operator License Conditions

  • All Procedures and Program documentation for maintaining active operator licenses,

tracking training attendance, and ensuring medical fitness of licensed operators

  • All Procedures and associated documentation that supports reactivation of any

SRO/RO license (operating or staff crew) since the last biennial inspection

02.09: Simulator Performance

  • An index of the most recent operability test packages required by ANSI 3.5 2009

Appendix B, including performance and approval dates, and results.

performance tests required by ANSI 3.5 2009 Appendix B.3.2.1.

  • An index of most recent malfunction tests for the malfunctions listed in ANSI 3.5

2009 3.1.4, as required by section 4.1.4. If these are satisfied exclusively by SBT

packages, then include an index of relevant SBT packages.

  • An index of core physics testing performed in the simulator since September 24,

2016, the plant physics data book reference used for comparison, and results

  • An index of Post-Event Simulator Tests conducted since September 24, 2016
  • An index of simulator modification packages that are not yet complete

2

  • An index of simulator modification packages completed since September 5, 2016
  • Current Simulator Differences List / Lesson plan used in training
  • All Simulator Management and Configuration Procedures if not already provided for

section 02.05 above.

  • Simulator Discrepancy Report summary list for all open DRs, and summary list for

those Discrepancy Reports closed since September 24, 2016.

02.10: Problem Identification and Resolution

  • A summary report of all condition reports related to licensed operator actions/errors

in the control room since September 24, 2016

  • Any revised requalification training that was based on licensed operator performance

issues since September 24, 2016

B. The following information is requested in order to support the onsite inspection

activities. Requested materials should be available to the inspection team, either

electronically or hardcopy, upon site arrival on August 27, 2018.

02.02: Exam Results / 02.03 and 02.04: Written Exam and Op Test Quality

  • All approved operating tests to be administered subsequent to the onsite inspection
  • All results up to the day the team leaves the site.

02.08: Conformance with Operator License Conditions

  • Access to licensed operators records
  • Access to licensed operators training attendance records
  • Access to licensed operators medical records

02.09: Simulator Performance

  • Simulator discrepancies reports (DRs) since September 24, 2016. This should

include all open and closed DRs, with documentation / justification for closure

  • Acceptance test documentation, including hardware and software model revisions at

the time of acceptance (as available)

  • Documentation that validates current models, including the thermal-hydraulic and

neutronics models, to the actual plant.

  • All current model deficiencies, including USAR vs Design differences in the simulator
  • Summary list of modifications since September 24, 2016.
  • Plant modifications (both hardware and software) incorporated onto the simulator

since September 24, 2016.

  • The complete book of all simulator annual performance test packages (either

hardcopy or electronic), complete with all transient tests, steady state tests, and

malfunction tests. This should also include the test procedures for each test, the

acceptance criteria, and results. For each transient test, the reference chart should

be included or an equivalent subject matter expert review versus the simulator

results with an analysis for any differences beyond the ANSI standard requirements

  • Simulator reactor core performance test packages used to verify core physics

parameters (ANSI/ANS 3.5 sections 3.4.3.3 / 4.4.3.3), including applicable reference

graphs from the plant physics data book, test procedures, acceptance criteria, and

results

  • All simulator test, configuration management, and related documents available in the

room for inspectors to review. This includes training needs analysis packages,

simulator review committee meeting minutes, etc.

3

  • Current copy of ANSI 3.5 standard you are committed to for simulator testing

02.10: Problem Identification and Resolution

  • All condition reports related to licensed operator actions/errors in the control room.

C. Palo Verde Nuclear Generating Station is required to send the final results and any

remaining written exams and operating tests to the lead inspector for final review and

comparison against the Significance Determination Tools in order to communicate

the exit results for the inspection. Report results in the format below:

1. Total number of licensed operators.

2. Number of licensed operators administered a requalification examination

required by 10 CFR 55.59(a).

3. Number of individual licensed operators who failed any portion of a

requalification examination (written, JPM, or individual simulator scenario

failures).

3.a. Number of individual licensed operators who failed written exam

3.b. Number of individual licensed operators who failed JPM exam

3.c. Number of individual licensed operators who failed simulator

scenario exam individually

4. Divide line 3 by line 2 to obtain the individual requalification examination  %

failure rate.

5. Number of crews administered simulator scenarios as part of a

requalification examination required by 10 CFR 55.59(a)

6. Number of crews who performed unsatisfactorily on the simulator

scenarios.

7. Divide line 6 by line 5 to obtain the crew simulator scenario failure rate.  %

8. Describe the reason for each licensed operator who was not

administered an NRC-required requalification exam, or who did not pass an

administered requalification exam, and the stations plan to satisfy the

requalification exam requirement for each.

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