ML16321A469

2016-10-DRAFT Outline Comments Rev 2 with PVNGS Response

ML16321A469
Person / Time
Site:	Palo Verde
Issue date:	11/03/2016
From:	Vincent Gaddy Operations Branch IV
To:	Arizona Public Service Co
Gaddy V
References
50-528/16-10, 50-529/16-10, 50-530/16-10 50-528/OL-16, 50-529/OL-16, 50-530/OL-16
Download: ML16321A469 (3)

Text

DRAFT OUTLINE COMMENTS Facility: PVNGS First Exam Date: 10-31-16 10-28-16 Written Exam Outline Comment Resolution On ES-401-4, include question number Added question numbers to the Tier/Group 1

for easier reference. column.

2 3

4 5

Administrative JPM Outline Comment Resolution See comment 1 in next section. Added total number of each type of JPM next 1 to the appropriate attribute in red, in parenthesis and bolded.

2 3

4 5

Control Room / In-Plant System JPM Outline Comment Resolution On ES-301-2 include actual values in Added total number of each type of JPM next 1 quantitative criteria chart, e.g. to the appropriate attribute in red, in (A)lternate Path: 4-6 (5) parenthesis and bolded.

S2: Are there any verifiable actions that Yes. The JPM consists of verifying both the applicant would have to take if RAS LPSI Pumps have stopped, ensuring ESF had actuated properly? CHA-HV-531? Pump suction valves have shifted to Meaning, is the applicant going to be containment (one does not which drives able to predict that it is an alternate path alternate path actions), closing the Train A JPM, because if it wasnt then there and Train B RWT to Safety Injection Valves 2 wouldnt be any verifiable actions? If (one per train, these are verifiable actions not, may need to expand the steps the which would have to be performed whether applicant performs to ensure there the JPM was alternate path or not and would be a verifiable action performed closing these two valves are time critical either way, to preclude cueing. actions which must be completed in 5 Also, is this activity performed during the minutes from the start of the JPM), and scenarios at all? verifying both trains HPSI, LPSI and CS OBDI 202 - IOLE Process Rev 2

Recirc Valves closed. If desired, we can fail one or more of the recirc valves to auto reposition to add more verifiable actions to the JPM.

This activity is NOT performed during any of the scenarios.

Simulator Scenario Outline Comments Comment Resolution Since low-power scenario was not Got it. Also, FYI, you had stated that you administered in 2015, we will most likely want everyone to have a functional scenario need to run it this year. so scenarios 1 and 2 both end in the FR. If 1

you decide to run one FR and one optimal EOP, only two applicants (both SRO upgrades) would NOT see a FR scenario.

Scen 3 CT1 - where does the 30 min 30 minutes comes from the CEOG-820, time requirement come from? which states that failure to report a failed safety function within twice the defined time 2 frame is reason to fail the critical task. At PVNGS, SFSCs are expected to be completed every 15 minutes when in an EOP so two passes of SFSCs is 30 minutes.

Scen 2 CT2 - where does the 30 min 30 minutes comes from the CEOG-820, time requirement come from? which states that failure to report a failed safety function within twice the defined time 3 frame is reason to fail the critical task. At PVNGS, SFSCs are expected to be completed every 15 minutes when in an EOP so two passes of SFSCs is 30 minutes.

4 5

Generic:

Do we have 2 units available for in-plants? Should be beneficial to use both in parallel.

There will be a refueling outage in progress on Unit 3, but Units 1 and 2 will be available.

The reason I didnt use both units on Wednesday is because the Purge Exhaust Units are only installed on Unit 1. In the event of an accident, they are moved to the affected unit. As such, JPM P-3 can only be done (without significant simulation) on Unit 1. JPM P-2 could be done on both units but since P-3 can only be done on Unit 1, I scheduled both to be done on Unit 1 for less moving around of examiners and applicants.

Wednesday may be aggressive Wednesday look aggressive on the schedule but it is not as aggressive as it looks. JPMs S-5 and S-7 can be run concurrently and each takes less than 10 minutes. I would not be at all surprised to see the JPMs there take ~ 60-75 minutes per group. S-2 and S-4 are also likely less than 10 minutes each and I would estimate each group will finish their JPMs in Sim B in ~ 90-120 minutes. The JPMs in Unit 1 should also OBDI 202 - IOLE Process Rev 2

take ~ 10 minutes each and since there are two examiners, the JPMs can be done concurrently. I would expect a transit time of ~ 10-15 minutes to and from the unit so each group should be done with their in-plant JPMs in a total of ~ 90 minutes.

Show a lunch break on schedule weds and thurs. There will need to be a swapping period, as I dont want the same examiners in-plant all day. Lunch will arrive around 1030 or 1100 each day. The reason I didnt show a lunch break is because the time people actually eat lunch tends to vary based on how the day is progressing. I can certainly put a lunch break on the schedule, I simply didnt list one since it will probably vary for each group. The way I laid out the schedule, no examiners will be in the plant all day. On Wednesday, there will be four groups which will go to Unit 1. Each group will have two examiners and 5 or 6 applicants. Every examiner will go to the unit but will only be in the unit for ~ 60-90 minutes.

On Thursday, each group will only have 3 or 4 applicants and would only need one examiner per group to go to the unit.

Schedule: Prefer to have the same JPM schedules in both simulators. i.e. on Wednesday, perform S-5, S-7, S-2, and S-4 in both simulators so applicants and examiners arent going back and forth. Will keep both simulators closer to the same pace as well. I can change the schedule to reflect that if you like. I laid it out the way I did to minimize the number of times the simulators have to be set up for different JPMs and to maximize exam efficiency. Since the A and B simulators are right next to each other, it seemed like this would be easier than running all four JPMs in each simulator. I can tinker with it and see what you think.

Schedule: Lets discuss this team idea youve listed, and what the intent is behind it. The team idea is something I came up with during our annual exam last year. It worked well because the same examiners stayed with the same examinees all day and made coordination of the exam easier to track with various evolutions going on each day.

Additionally, since you want separation between half of the examiners and half of the applicants, the team idea seemed like a good fit. We can discuss further.

Examiner assignments: assign R6 to E6, vice E8. Will balance out the applicant load. I can do that. As of now, E6 has two applicants (total of 4 scenarios) and two sessions of Admin JPMs to administer, and E8 has four applicants (total of 6 scenarios) and no sessions of Admin JPMs. I guess it is a bit unbalanced due to having to fill out 4 sets of 303s instead of 2 so I see your point. OBDI 202 - IOLE Process Rev 2