IR 05000528/2013301

Er 05000528/2013301; 05000529/2013301; 05000530/2013301; October 1 - November 20, 2013; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Initial Operator Licensing Examination Report

ML13351A508
Person / Time
Site:	Palo Verde
Issue date:	12/17/2013
From:	Vincent Gaddy Operations Branch IV
To:	Edington R K Arizona Public Service Co
Gaddy V G
References
50-528/13-301, 50-529/13-301, 50-530/13-301
Download: ML13351A508 (13)

Text

December 17, 2013

Randall K. Edington, Executive Vice President, Nuclear/CNO

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

SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC EXAMINATION REPORT 05000528/2013301; 05000529/2013301;

05000530/2013301

Dear Mr. Edington:

On November 9, 2013, 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 November 9, 2013, with Mr. B. Bement, Senior Vice President for Nuclear Operations, and other members of your staff. A telephonic exit meeting was conducted on November 20, 2013, with Mr. W. Potter, Simulator Support Section Leader,

who was provided the NRC licensing decisions.

The examination included the evaluation of eleven applicants for reactor operator licenses, eight applicants for instant senior reactor operator licenses, and six applicants for upgrade senior reactor operator licenses. The license examiners determined that all twenty five of the applicants satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued. There was one post examination comment submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post examination comment resolution. No findings were identified during this examination.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," 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 NRC's 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 Dockets: 50-528; 50-529; 50-530 Licenses: NPF-41; NPF-51; NPF-74

Enclosures:

1. NRC Examination Report 05000528;05000529; 05000530/2013301, w/Attachment 2. NRC Review of PVNGS Written Post-Examination Comments

Electronic Distribution for Palo Verde Nuclear Generating Station Electronic distribution by RIV

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Steven.Reynolds@nrc.gov) DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Tom.Blount@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Tony.Brown@nrc.gov)

Resident Inspector (John.Reynoso@nrc.gov)

Resident Inspector (Mica.Baquera@nrc.gov) Resident Inspector (Dustin.Reinert@nrc.gov)

Administrative Assistant (Revonna.Stuart@nrc.gov)

Branch Chief, DRP/A (Ryan.Lantz@nrc.gov)

Senior Project Engineer, DRP/A (Bob.Hagar@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Ray.Kellar@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/ETA: OEDO (Brett.Rini@nrc.gov)

R:\_REACTORS\_PV\2013\PV 2013301 RP kdc.docx ML ML13351A508 SUNSI Review Completed: __KDC__ ADAMS: Yes No Initials: __KDC__

Publicly Available Non-Publicly Available Sensitive Non-Sensitive OE:OB OE:OB SOE:OB OE:OB OE:OB SPE: PB SHedger CSteely BLarson DStrickland CCowdrey MBloodgood /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ 12/16/13 12/16/13 12/13/13 12/16/13 12/16/13 12/16/13 OE:OB (R3) SOE:OB C: PBA C:OB CMoore KClayton WWalker TFarnholts for VGaddy TBlount for

/RA/telecom

/RA/ /RA/ /RA/ 12/13/13 12/13/13 12/17/13 12/17/13 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets: 50-528; 50-529; 50-530 Licenses: NPF-41; NPF-51; NPF-74 Report: 05000528/2013301; 05000529/2013301; 05000530/2013301 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location: 5951 S. Wintersburg Road Tonopah, Arizona Dates: October 1 - November 20, 2013 Inspectors: K. Clayton, Senior Operations Engineer B. Larson, Senior Operations Engineer C. Steely, Operations Engineer

S. Hedger, Operations Engineer D. Strickland, Operations Engineer C. Cowdrey, Operations Engineer M. Bloodgood, Senior Project Engineer (DRP)

C Moore, Operations Engineer (RIII) Approved by: Vincent Gaddy, Chief Operations Branch

Division of Reactor Safety

SUMMARY OF FINDINGS

ER 05000528/2013301; 05000529/2013301; 05000530/2013301; October 1 - November 20, 2013; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; Initial Operator Licensing Examination Report.

NRC examiners evaluated the competency of el even applicants for reactor operator licenses, eight applicants for instant senior reactor operator licenses, and six 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 November 1, 2013. NRC examiners administered the operating tests the week of November 4, 2013.

The examiners determined that all 25 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

None.

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. The examiners also audited four 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. For the reactivity credits, the licensee had several credits (which were not used on the final applications) that did not meet the intent of the regulation for positive control of the reactor as evidenced with parameter changes and accurate logs for one and only one individual. There were several credits where numerous applicants were logged into the control room at the same time, which clearly does not meet the spirit of having one person signed in to the logs as an under-instruction watch-stander and that person performing the manipulation credit. The chief examiner asked the licensee to remove these credits from the final applications and use other control manipulation credits from the qualification cards that met the spirit of the regulation for this activity. The licensee completed these changes prior to final application submittal and wrote Condition Report PVAR 4477615 to capture this issue.

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 that the written ex aminations initially submitted by the licensee were within the range of acceptability expected for a proposed examination.

The draft scenarios submitted required numerous changes due to overlap issues with the previous two NRC examinations. The licensee wrote Condition Report PVAR 4476184 to address this issue. Several critical tasks were not tied to physical parameters (not just procedure transitions) as required to meet the NUREG-1021 guidance. The licensee wrote Condition Report PVAR 4476152 to address this issue. There were several other examination development/administration issues that required condition reports and were rolled up in the previous two conditions reports listed above.

During examination validation, the NRC and licensee examination teams identified six procedure enhancement opportunities that were captured by Condition

Report PVAR 4480931.

.3 Operator Knowledge and Performance

a. Scope

On November 1, 2013, the licensee proctored the administration of the written examination for all 25 applicants, analyzed the results, and presented their analysis and post-examination comments to the NRC with a letter postmarked on November 14, 2013. These items were reviewed on November 18, 2013.

The NRC examination team administered the various portions of the operating tests to

all 25 applicants the week of November 4, 2013.

b. Findings

No findings were identified.

All 25 of the applicants passed the written examination and all 25 passed all parts of the operating test. The final written examinations, final operating test, and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment, which includes one post-examination comment. There was one post-examination comment that requested a change to the answer key, Question 80, to which the NRC regional office accepted the recommended change and the answer key was changed accordingly. (See Enclosure 2 for a brief synopsis of the question, the comments, and the NRC resolution of these comments. The complete submittal can be found in the ADAMS system using accession number ML13343A136.)

The examination team noted the following generic weaknesses:

There were two questions missed by 50 percent or more of the applicants, with each question analyzed by the licensee as required by NUREG-1021. Both question weaknesses were determined to be knowledge weaknesses. The licensee wrote Condition Report PVAR 4479704 to address these weaknesses and the operating test

weaknesses.

Additionally, the licensee wrote Condition Report PVAR 4481035 to address the problem of general content issues with the examination. Specifically, the applicants

appeared to study old examination materials (such as events on previous scenarios and JPMs from the bank) and then tried to predict the direction or outcome of the task being administered. The licensee was informed that this methodology is not in accordance with the NRC standards or a systems approach to training and should be avoided.

Additionally, NUREG-1021 specifically limits the use of bank materials on the NRC examination because of the predictability of this practice. On page 1 of APPENDIX A, "OVERVIEW OF GENERIC EXAMINATION CONCEPTS," it states that:

"The internal attributes of the examination, such as its level of knowledge, level of difficulty, and use of item banks, also impact the operational and discriminatory validity of the examination, which, in turn, can affect its consistency and reliability. If the internal and external attributes of examinations are allowed to vary significantly, the uniform conditions that are required by Section 107 of the Atomic Energy Act of 1954, as amended, and the basis upon which the NRC's licensing decisions rest are challenged.

The NRC must reasonably control and structure the examination processes to ensure the integrity of the licenses it issues."

Furthermore, it states on page 10 of this same appendix in section C.3.e for "Use of

Item Banks" that:

"Test item banks are a valuable resource for learning and represent one fundamental basis for training and testing. However, it would be inappropriate to copy all or a significant portion of the items for an examination directly from the bank if the same items were previously used for testing or training. Test item banks must be used properly to maintain the validity, reliability, and consistency of the examinations.

Previously administered test items reduce examination integrity because examination discrimination is reduced." It also states below that paragraph that:

"Furthermore, when the bank of items from which the examination is drawn is known to the examinees prior to the examination, the examination is said to be highly predictable. Predictable examinations tend not to discriminate because what is being tested is simple recognition of the answer. Although studying past examinations can have a positive learning value, total predictability of examination coverage through over-reliance upon examination banks reduces examination integrity. When the examinees know the precise and limited pool from which test items will be drawn, they will tend only to study from that pool (i.e., studying to the test) and may likely exclude from study the larger domain of job knowledge. When this occurs, it decreases the confidence in the validity inferences that are made from performance on the test to that of the larger realm of knowledge or skill to be mastered."

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performanc e with regard to plant fidelity during examination validation and administration. There were several minor simulator fidelity observations that did not impact scenario administration and are documented below as required by NUREG-1021. These observations do not constitute audit or inspection findings and, without further verification and review in accordance with IP 71111.11, are not indicative of non-compliance with 10 CFR 55.46. The licensee wrote condition reports, listed with PVAR numbers, in the table below:

Item Description Condition Report #

Condensate pump "C" upper thrust bearing temp This temp exceeded the alarm setpoint of 194 degrees F during some scenarios. This was unplanned but did not impact the scenario administration PVAR 4476190 Containment temp and NCW outlet temp Simulator temperatures for Containment and NCW outlet for the running and idle CEDM ACUs need to be adjusted for better fidelity to Unit 1. This did not impact the scenario

administration. PVAR 4476190 SG Blowdown constants Blowdown constants on the simulator are different than Unit 1. This does not align

with Operator Information Aid for Appendix F of 40DP-9OP14. This did not impact the scenario administration.

Simulator discrepancy DRC 2013-3612 has been created. ERFDADS RCS leak rate The simulator ERFDADS RCS leak rate for a SGTL event appeared to change between morning and afternoon runs of the same scenario (8 gpm in the AM;

5-6 gpm in the PM). This did not impact the scenario

administration.

PVAR 4476190 Multiple TCW alarms There were multiple B06 and B07 alarms that came fairly quickly after inserting the TCW sheared shaft malfunction. Need to verify that the timing of the alarms is appropriate for the condition. Need to verify amperage indication was appropriate on affected

pump motor.

PVAR 4477166 The NIS Control Channel gain adjustment

potentiometer The NIS Control Channel gain adjustment

potentiometer in Unit 1 is different than the simulators (One PVAR for simulator fidelity; one for Palo Verde's PVAR 4476283 PVAR 4476289 like-for-like component replacement process).

2B SIT Tank Hi-Hi and Lo-Lo Pressure Alarm setpoints not correct This issue was found and fixed after validation week but prior to examination

administration week.

Simulator discrepancy DRC 2013-3591 was created

and fixed prior to examination administration

week.

b. Findings

No findings were identified.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security 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

No findings were identified.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. B. Bement, Site Vice President of Nuclear Operations, and other members of the staff on November 9, 2013. A telephonic exit was conducted on November 20, 2013, between Messrs. Kelly Clayton, Chief Examiner, and W. Potter, Simulator Support Section Leader.

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

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Bement, Vice President of Nuclear Operations

D. Mims, Vice President of Nuclear Regulatory Assurance

W. Potter, Simulator Support Section Leader

L. Burton, Operations Training / Written Examination Author

A. Rasmussen, Operating Test Author

NRC Personnel

T. Brown, Senior Resident Inspector

ADAMS DOCUMENTS REFERENCED

Accession No. ML13343A132 - FINAL WRITTEN EXAMINATION (delayed release until Dec. 15, 2015)

Accession No. ML13343A135 - FINAL OPERATING TEST

Accession No. ML13343A136 - POST EXAMINATION ANALYSIS AND COMMENTS

Enclosure 2 NRC Review 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 ML13343A136.

Question 80

With regards to the (EW) Essential Cooling Water system in mode 1, which of the following is the correct application of Tech Specs?

(1) When cross connected to the Nuclear Cooling Water (NCW) system, EW is

INOPERABLE...

(2) When cross connected to the Fuel Pool Cooling, EW is INOPERABLE...

A. (1) and remains inoperable while cross connected. (2) and remains inoperable while cross connected.

B. (1) and remains inoperable while cross connected. (2) but operability can be restored if a flow balance is performed because the

EW system is sized to supply the SDC heat exchanger, Essential Chiller and the SFP heat exchanger.

C. (1) but operability can be restored if a flow balance is performed because the EW system is sized to supply the NCW priority loads and the SDC heat

exchanger.

(2) and remains inoperable while cross connected.

D. (1) but operability can be restored if a flow balance is performed because the EW system is sized to supply the NCW priority loads and the SDC heat

exchanger.

(2) but operability can be restored if a flow balance is performed because the EW system is sized to supply the SDC heat exchanger, Essential Chiller and the SFP heat exchanger.

Proposed Answers: A & B

Licensee Comments for Question 80:

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

"Originally B was identified as the only correct answer but after review it has been determined that A is also correct.

Given only conditions stated in the stem, 'A' and 'B' are correct answers.

EW is

INOPERABLE when cross connected to either the NC or SFP cooling systems. EW may be restored to OPERABLE when connected to SFP cooling if a flow balance is performed. The

stem makes no reference to a flow balance being performed. 'A' would have been wrong if the statement read (1) and remains inoperable when cross connected regardless of performing a flow balance.

'B' is still correct (1) is correct and (2) is correct in stating that operability is restored if a flow balance is performed. 'C & D' are both still wrong because (1) is a wrong statement for both.

Operability is not restored for EW when cross tied to NC even if a flow balance is completed. EW is not sized to supply both NC priority loads and the SDC heat exchanger. EW is sized to carry the SFP heat exchanger, Essential chiller and the SDC heat exchanger. Operability is restored if a flow balance is completed after the cross-tie to Fuel Pool Cooling.

Distracters D are plausible because one part of the answer is correct.

Distracter C is plausible because the answers are true for the opposite condition."

NRC Resolution of Question 80:

The NRC reviewed the licensee's submittal and concluded that the licensee was correct, that both "A" and "B" are correct.

Any time two safety systems are cross-connected they are typically INOPERABLE as defined in the Technical Specifications.

The new question and subsequent validation by several licensed operators was flawed and a Condition Report

PVAR 4476152 was written to address this issue.

The NRC changed the key and re-graded the written examinations with the correct answer as "A" or "B" for question 80 as recommended.