IR 05000528/2019301
| ML20028D876 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/28/2020 |
| From: | Greg Werner Operations Branch IV |
| To: | Lacal M Arizona Public Service Co |
| Werner G | |
| References | |
| 50-528/19-301, 50-529/19-301, 50-530/19-301, EPID L-2019-OLL-0008 50-528/OL-19, 50-529/OL-19, 50-530/OL-19 | |
| Download: ML20028D876 (16) | |
Text
ary 28, 2020
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - NRC INITIAL EXAMINATION REPORT 05000528/2019301, 05000529/2019301, AND 05000530/2019301
Dear Mrs. Lacal:
On October 11, 2019, 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 October 11, 2019, with Mr. Paul Bury, Training Director, and other members of your staff. A telephonic exit meeting was conducted on December 19, 2019, with Ms. Maria Lacal, Senior Vice President Regulatory and Oversight, and other members of your staff.
The examination included the evaluation of 18 applicants for reactor operator licenses, 2 applicants for instant senior reactor operator licenses, and 7 applicants for upgrade senior reactor operator licenses. The license examiners determined that all applicants satisfied the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 55, and the appropriate licenses have been issued. There were three post-examination comments submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post-examination comment resolution.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, one Severity Level IV violation is documented in this report. We are treating these violations as non-cited violations (NCVs)
consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Palo Verde Nuclear Generating Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Gregory E. Werner, Chief Operations Branch Division of Reactor Safety Docket Nos. 05000528, 05000529, and 05000530 License Nos. NPF-41, NPF-51, and NPF-74
Enclosures:
1. Examination Report 05000528/2019301, 05000529/2019301, and 5000530/2019301 w/attachment: Supplemental Information 2. NRC Post-Examination Comment Resolution
Inspection Report
Docket Numbers: 05000528, 05000529, and 05000530 License Numbers: NPF-41, NPF-51, and NPF-74 Report Numbers: 05000528/2019301, 05000529/2019301, and 05000530/2019301 Enterprise Identifier: L-2019-OLL-0008 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station Location: Tonopah, Arizona Inspection Dates: October 7, 2019, to December 19, 2019 Inspectors: K. Clayton, Chief Examiner C. Osterholtz, Senior Operations Engineer T. Farina, Senior Operations Engineer M. Hayes, Operations Engineer M. Doyle, Operations Engineer N. Hernandez, Operations Engineer M. Kennard, Operations Engineer, Region II S. Hedger, Emergency Preparedness Inspector M. Bloodgood, Emergency Preparedness Inspector Approved By: Gregory E. Werner, Chief Operations Branch Division of Reactor Safety Enclosure 1
SUMMARY
ER 05000528/2019301; 05000529/2019301; 05000530/2019301; 12/19/2019; Palo Verde
Nuclear Generating Station, Units 1, 2, and 3; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of 18 applicants for reactor operator licenses, applicants for instant senior reactor operator licenses, and 7 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 11. The written examination was administered by the licensee on October 4, 2019. The NRC examiners administered the operating tests during the week of October 11, 2019.
The NRC examiners determined that all 27 applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
List of Findings and Violations Failure to Correctly Translate the Emergency Procedure Design Basis for the Containment Temperature Safety Function Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.1] - 4OA5.6.b NCV 05000528/2019301-01; Resources05000529/2019301-01; 0500530/2019301-01 Open/Closed A self-revealed Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III,
Design Control, was identified when the design basis for the containment temperature safety function was incorrectly translated into the emergency procedure technical guidelines/basis document. Specifically, the licensee failed to correctly translate the emergency procedure design basis for the containment temperature safety function into procedure 40DP-9AP12,
Loss of Offsite Power/ Loss of Forced Circulation Technical Guideline, Revision 27. The licensee entered this issue in the corrective action program as Condition Report CR-2019-15222.
Failure to Inform the NRC of an Uncorrected Performance Test Failure on the Simulator for Condenser Vacuum that Existed Prior to or Concurrent with Exam Preparations Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 4OA5.6.b NCV 05000528/2019301-02; 05000529/2019301-02; 0500530/2019301-02 Open/Closed The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.46(d)(3), for failure to inform the NRC of any uncorrected performance test failure results on the simulator that existed at the time of the operating test prior to or concurrent with initial examination preparations during the week of September 9, 2019, for the scheduled operating test to be administered during the week of October 7, 2019. Specifically, the licensee failed to inform the NRC that there was an uncorrected simulator deficiency with condenser vacuum during validation week and this was a licensing parameter for this examination and it impacted examination administration. The licensee entered this issue in the corrective action program as Condition Report CR-2019-1488
Licensee-Identified Violations
None.
REPORT DETAILS
(4OA5)
OTHER ACTIVITIES
- INITIAL LICENSE EXAM
.1 License Applications
a. Scope
The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited four of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants 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
The NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b. Findings
The NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
The 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.
.3 Operator Knowledge and Performance
a. Scope
On October 4, 2019, the licensee proctored the administration of the written examinations to all 27 applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post-examination comments to the NRC on October 21, 2019.
The NRC examination team administered the various portions of the operating tests to all applicants from October 7-11, 2019.
b. Findings
All applicants passed the written examination and all parts of the operating test. The final examinations and post-examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in the attachment.
The examination team noted no generic weaknesses associated with applicant performance on the operating tests. The licensee identified nine generic weaknesses associated with applicant performance on the written examinations:
1. Charging pump malfunctions - 18/27 missed Question 16 2. Reactor trip on low steam generator levels (basis) - 20/27 missed Question 23 3. Loss of instrument air - 18/27 missed Question 28 4. Operation of fire detection panels in the control room - 19/27 missed Question 65 5. Safety function evaluation during a Loss of Coolant Accident - 6/9 missed Question 77 6. Technical Specifications for containment isolation valves - 6/9 missed Question 84 7. Reactor protection system bypasses - 7/9 missed Question 87 8. Post-accident monitoring instrument requirements - 5/9 missed Question 92 9. Radiation Monitors and purge release requirements - 7/9 missed Question 97 Copies of all individual examination reports were sent to the facility Training Manager for evaluation and determination of appropriate remedial training.
.4 Simulation Facility Performance
a. Scope
The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.
b. Findings
See inspection results for a simulator performance related finding.
.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 minor violation of 10 CFR 55.49, Integrity of Examinations and Tests, occurred during the scenario administration when a booth operator used an instant messenger program to communicate to plant staff that were not on the exam security agreement that there was a problem with the simulator vacuum model. Due to quick recognition and action by the lead examiner for the station, all the individuals who received the communication were signed onto the examination security agreement within a few minutes. During this entire time the applicants were all sequestered.
.6 Inspection Results
a. Scope
The NRC examiners reviewed examination security, procedure content, plant physical conditions, plant operations, simulator performance, application processes, medical program challenges, emergency preparedness, and training performance during the 6 months of exam development, administration, and grading processes for regulatory issues.
b. Findings
Failure to Correctly Translate the Emergency Procedure Design Basis for the Containment Temperature Safety Function Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.1] - 4OA5.6.b NCV 05000528/2019301-01; Resources05000529/2019301-01; 0500530/2019301-01 Open/Closed A self-revealed Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified when the design basis for the containment temperature safety function was incorrectly translated into the emergency procedure basis document.
Specifically, the licensee failed to correctly translate the emergency procedure design basis for the containment temperature safety function into procedure 40DP-9AP12, Loss of Offsite Power/ Loss of Forced Circulation Technical Guideline, Revision 27. The licensee entered this issue in the corrective action program as Condition Report CR-2019-15227.
Description:
On October 14, 2019, during the post exam reviews, the training staff and the applicants were reviewing the written examinations and the applicants commented that the distracter choice A for Question 99 on the written examination was correct based on the procedure 40DP-9AP12, Revision 27, page 41. The licensee agreed and determined that a change had been made to the emergency procedures, but the corresponding change was not made to the basis document. The emergency procedure for a loss of offsite power and its technical guideline/basis document had different values for the maximum containment temperature safety function (125oF versus 117oF, respectively).
During review of licensee provided post-examination comments and the associated materials, the NRC noted the disparity between the two descriptions for this value between the two documents. Specifically, the emergency operating procedure 40EP-9EO07, Loss of Offsite Power / Loss of Forced Circulation, Revision 31, stated on Page 47 that the maximum temperature for the containment safety function during this major event is 125oF. However, procedure 40DP-9AP12 was not updated to reflect this change. Revision 27 of the technical guideline stated that the maximum containment temperature should not exceed the technical specification temperature limit (which is 117oF). When procedure 40EP-9EO07, Revision 31 was changed with the value for maximum containment temperature to meet the safety function at 125oF, the corresponding technical guideline procedure was not revised for this new temperature of 125oF and was therefore incorrect.
Corrective Actions: The licensee planned to restore compliance by changing the design basis document maximum containment temperature to 125oF and improving procedure 40DP-9AP15, Emergency and Abnormal Procedure Writers Guide, that makes changes to station procedures to include reviewing changing emergency procedure technical guideline/basis documents.
Corrective Action Reference: CR-2019-15227
Performance Assessment:
Performance Deficiency: Failure to correctly translate the design basis of the containment temperature safety function into an emergency operating procedure technical basis document was a performance deficiency.
Screening: The inspectors determined that it was more than minor and therefore a finding because it adversely affects the procedure quality attribute of the barrier integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The incorrect guidance in the emergency operating procedure technical guideline/basis document could result in a licensed operator making incorrect decisions during emergency procedure events when evaluating the maximum containment temperature for ensuring that the associated safety function is met.
Challenging the safety function of the containment could increase the risk to public health and safety. Traditional enforcement did not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function and was not the result of any willful violation of NRC requirements.
Significance: The inspectors assessed the significance of the finding in accordance with Inspection Manual Chapter 0609, Attachment 4, Initial Screening and Characterization of Findings, and the associated Appendix A for at-power significance determinations, Exhibit 3, Barrier Integrity Screening Questions. The finding was determined to be of very low safety significance (Green) because the finding:
- (1) did not represent an actual open pathway in the physical integrity of reactor containment;
- (2) did not involve an actual reduction in function of hydrogen igniters in containment;
- (3) did not represent a degradation of the radiological barrier function provided for the control room, auxiliary building, or spent fuel pool; and
- (4) did not represent a degradation of the barrier function of the control room against a smoke or toxic atmosphere.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the licensee failed to ensure that the procedure used to make changes to station procedures contained adequate information for validation of the emergency operating procedure basis document when an emergency operating procedure was changed.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states in part that,
. . . for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. The containment temperature safety function value is a required part of Criterion III. Contrary to the above, on February 6, 2018, the containment temperature safety function value was not correctly translated into procedure 40DP-9AP12, Loss of Offsite Power/ Loss of Forced Circulation Technical Guideline, Revision 27. Specifically, the maximum temperature for the containment safety function during a loss of offsite power changed from 117oF to 125oF, but this change was not incorporated into the procedure.
Enforcement Action: This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Inform the NRC of an Uncorrected Performance Test Failure on the Simulator for Condenser Vacuum that Existed Prior to or Concurrent with Exam Preparations Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 4OA5.6.b NCV 05000528/2019301-02; 05000529/2019301-02; 0500530/2019301-02 Open/Closed The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.46(d)(3), for failure to inform the NRC of any uncorrected performance test failure results on the simulator that existed at the time of the operating test prior to or concurrent with initial examination preparations during the week of September 9, 2019, for the scheduled operating test to be administered during the week of October 7, 2019. Specifically, the licensee failed to inform the NRC that there was an uncorrected simulator deficiency with condenser vacuum during validation week; this was a licensing parameter for this examination; and it impacted examination administration on October 9, 2019, during the administration of Scenario 2. The licensee entered this issue in the corrective action program as Condition Report CR-2019-14882.
Description:
On October 7, 2019, during the administration of Scenario 2, a degraded vacuum malfunction was inserted into the scenario to facilitate a down-power event. After the down-power was completed a report from the field operator (simulator booth) was to confirm that the condenser vacuum degradation was caused by an empty loop seal and was being filled by the local operator. The vacuum degradation issue was not expected to come back at this point, however vacuum continued to degrade and then improved in a sawtooth pattern that was not part of the scenario. The training staff informed the NRC lead evaluators in both simulators that there was something wrong with the vacuum model. The NRC lead evaluators informed the crews to continue with the scenario, that vacuum was improving as stated before, based on their actions and the local actions to fill the seal. One of the booth operators sent out a text message via an instant messaging application to six instructors that vacuum was not performing correctly. This led to the minor exam security violation discussed above.
After the first occurrence of this issue, the NRC knew how to handle the event, but it was not in accordance with the simulator regulations for removing uncorrected performance test failures from the exam prior to administration to prevent complicating the license decisions.
During further review by the licensee staff, they determined that this was a known issue that had been fixed in the simulator code (DR-2019-4423), but the fix had not been rolled into the simulator code to reflect this repair to the condenser vacuum model. The complexity of the vacuum issue was compounded because it did not appear during validation week with the dry run of Scenario 2. The licensee staff also validated this scenario in both simulator machines before the NRCs arrival and it did not appear then either. The licensee signs a quality form, as part of the docketed submittal, Exam QA form ES-301-4, Simulator Scenario Quality Checklist. Item 8 of this form states that, The scenarios have been validated. Pursuant to 10 CFR 55.46(d), any open simulator performance deficiencies or deviations from the referenced plant have been evaluated to ensure that functional fidelity is maintained while running the planned scenarios. The exam author and facility representative both thought the intent of Item 8 was met due to the issue not manifesting during any of the validations. The licensees exam team believed the cause of this issue was a misinterpretation of Item 8 from form ES-301-4, as the wording in Item 8 is somewhat vague. After reviewing the CFR referenced in Item 8 {10 CFR Part 55.46(d)(3)}, the intent was clear. This regulation states, in part, Make results of any uncorrected performance test failures that may exist at the time of the operating test or requalification program inspections available for NRC review, prior to or concurrent with preparations for each operating test or requalification program inspection.
Corrective Actions: The licensee planned to restore compliance by incorporating the fix into the simulator code and updating its submittal checklists to include a copy of the Simulator Discrepancy Report and the Simulator Differences List in the various docketed submittal packages. The licensee also planned to revise procedure 15DP-0OT01, NRC Initial Exam Development, to require the exam team to review the Simulator Deficiency Report and Simulator Differences List prior to commencing scenario and job performance measure development.
Corrective Action Reference: CR-2019-14882
Performance Assessment:
Performance Deficiency: The failure to inform the NRC of any uncorrected performance test failure results on the simulator prior to or during operating test preparations was a performance deficiency.
Screening: The inspectors determined that this issue was within the traditional enforcement process because it impeded the NRC's ability to perform its regulatory function. The violation was more than minor because the failure to notify the NRC impacted the initial exam administration via the incorrect vacuum performance during a scenario. Had the NRC known about this modeling issue with condenser vacuum, any material associated with it would have been removed from the initial examination.
Significance: Consistent with the guidance in Section 2.2.1.c of the NRC Enforcement Policy, the inspectors concluded that the violation was a Severity Level IV because the failure to notify the NRC of this information could have impacted the NRCs decisions during licensing activities. This issue impeded the regulatory process of ensuring simulator issues did not affect the exam administration via uncorrected simulator performance test failures. This disclosure is a regulatory requirement and is also required on docketed submittal quality form ES-301-4, Simulator Scenario Quality Checklist, Item 8, prior to exam validation.
Cross-Cutting Aspect: Not Applicable for traditional enforcement.
Enforcement:
Violation: Title 10 CFR Part 55.46(d)(3) Simulation Facilities, states in part that, Make results of any uncorrected performance test failures that may exist at the time of the operating test or requalification program inspections available for NRC review, prior to or concurrent with preparations for each operating test or requalification program inspection.
Contrary to the above, the licensee did not make the results of an uncorrected performance test failure available for NRC review prior to or concurrent with preparations for the initial operating test. Specifically, during the initial examination preparation week of September 9, 2019, the licensee did not inform the NRC of the known uncorrected simulator performance test failure with condenser vacuum.
Enforcement Action: This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
Exit Meeting Summary
The licensee did not identify any information or materials used during the examination as proprietary.
The chief examiner presented the preliminary examination results with Mr. P. Bury, Training Director, and other members of your staff on October 11, 2019. A telephonic exit meeting was conducted on December 19, 2019, with Ms. M. Lacal, Senior Vice President Regulatory and Oversight, and other members of your staff.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Lacal, Senior Vice President Regulatory and Oversight
- P. Bury, Director, Nuclear Training
- B. Cable, Director, Operations
- M. Kura, Director, Nuclear Regulatory Assurance
- Z. Goldwasser, Department Leader, Operations Training
- D. Lowdermilk, Nuclear Operations Coordinator, Licensing
- J. Rodgers, Operations Training Instructor
- J. Shaver, Section Leader, Operations Training
NRC Personnel
- C. Peabody, Senior Resident Inspector