ML031710814
| ML031710814 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/14/2003 |
| From: | Gumbert R AmerGen Energy Co |
| To: | Conte R NRC/RGN-I/DRS/OSB |
| Conte R | |
| References | |
| 50-289/03-301 50-289/03-301 | |
| Download: ML031710814 (39) | |
Text
TMI Licensing Exam 511 212003 Scenario #2 Rev 1 SRO Normal Evolution Instrumentation Failure SRO INSTANT Scenario Day I Switch Operating Condensate Pumps.
RCS T-Hot Instrument Failure.
Instrumentation Failure RO Reactivity Change Component Failure Major Ma If u nct ion Generator Hydrogen Gas Leak.
Manual Load Reduction to 850 MW.
Auxiliary Transformer Fault.
Steam Line Rupture Inside Containment Building.
I Component Failure I Stuck Open High Pressure Injection Valve.
Page 1 of 19
TMI Licensing Exam 5/12/2003 Scenario #2 Rev 1 SRO INSTANT Simulator Day I Quantitative Attributes Total Malfunctions RCS T-Hot Instrument Failure.
Main Generator Hydrogen Gas Leak.
ICs Controller Failures.
I A Auxiliary Transformer Fault.
Steam Line Rupture Inside RB.
HPI Valve Failure.
Malfunctions After EOP Entrv HPI Valve Failure.
Abnormal Events RCS T-Hot Instrument Failure.
I ICs Controller Failures.
Main Generator Hydrogen Leak.
I 1A Auxiliary Transformer Fault.
Major Transients Steam Line Rupture Inside RB.
EOPs Entered With Substantive Actions EOP-003, Excessive Primary-to-Secondary Heat Transfer.
EOP Contingencies Requiring Substantive Actions EOP-010, Abnormal Transients, Rules, Guides and Graphs.
Critical Tasks SRO Direct operator actions following OTSG isolation to prevent RCS heat-up and re-pressurization.
RO Termination of high pressure injection flow.
Target 5-8 1-2 2 4 1-2 1 -2 0-2 2-3 Actual 6
1 4
1 I
TMI Licensing Exam 5/12/2003 Scenario #2 Rev 1 Reactivity Manual Load reduction to 800 MW.
I - RCS T-Hot instrument C -Main Generator Hydrogen InstrumentKomponent Failures C -1 A Auxiliary C - HPI Pump ES Auto failure.
Transformer fault.
I Simulator Scenario Dav 1 1
2 II Reqd SRO INSTANT Gas Leak.
I - ICs controller failures.
I A S RO Start Failure.
C -HPI valve failure.
Major Main Steam Line Rupture In Containment.
1 Normal Evolution 1
Actual 1
1 Switch Condensate Pumps I - RCS T-Hot instrument C -Main Generator Hydrogen 2
InstrumentlComponent Failure C - 1 A Auxiliary C - HPI Pump ES Auto failure.
Transformer fault.
1 = 2 c = 4 1=2 c = 4 1
Gas Leak.
I - ICs controller failures.
As SRO Start Failure.
C -HPI valve failure.
Major Main Steam Line Rupture Inside Containment.
I I
Page 3 of 19
TMI Licensing Exam 511 212003 Scenario #2 Rev 1 REVISION DATE REFERENCE TITLE DESCRIPTION (Include AI # if appropriate) 0 I 4/12/03 I N/A 1
I New scenario 511 2/03 per NRC validation Page 4 of 19
TMI Licensing Exam 5/12/2003 Scenario #2 Rev 1 GENERAL DESCRIPTION OF SCENARIO This scenario provides the opportunity for the team and individuals to demonstrate ability to utilize normal, emergency, and accident mitigation procedures, and compliance with Technical Specifications requirements.
It exposes the examinees to operational situations that enable examiners to evaluate the ability of the crew to:
Perform normal operations (switch operating Condensate pumps).
Implement annunciator response and normal operating procedures to stabilize the plant parameters and switch to a valid instrument following failure of a control system input signal.
Determine electrical load limitations due to low gas pressure in the Main Generator due to a Hydrogen leak, and execute a forced load reduction in order to prevent overheating the Main Generator.
Reduce power with the Integrated Control System (ICs) in manual control mode.
Use plant procedures to respond to loss of an Auxiliary Transformer during power operations, and verify compliance with plant electrical technical specifications.
Implement emergency operating procedures to respond to a major steam line rupture inside the Containment Building.
Navigate symptom-based accident mitigation procedures and prioritize rule based operator actions to mitigate effects of excessive RCS heat removal through the ruptured steam line following reactor trip.
Isolate sources of water to the affected OTSG in order to limit and terminate the overcooling event.
Inject sufficient water into the Reactor Coolant System to prevent loss of subcooled margin and potential fuel damage.
Prevent RCS reheat and re-pressurization following isolation of the affected OTSG.
Stabilize RCS system pressure and temperature to limit mechanical stresses in the dry OTSG in order to prevent potential tube failures (LOCA into the RB).
Estimated scenario time 60 minutes.
Critical Tasks I
SRO Critical Task.
2 RO Critical Tasks.
Page 5 of 19
TMI Licensing Exam 5/12/2003 Scenario #2 Rev 1 REFERENCES A. 10 CFR 55.45 Operating Tests, (a) Content (3), (4), (5), (6), (71, (81, (91, (121, (13)
B. PROCEDURE
S:
AP 1203-15 EP 1202-38 AP 1203-20 AP 1203-19 OP 1 102-4 OP 1105-4 OP 1 105-6 OP 1106-1 OP 1106-2 OP 11 06-8 OP 11 07-2A OP 1107-11 OP-TM-EOP-001 OP-TM-EOP-003 OP-TM-EOP-010 OP-TM-861-902 Loss of MU/RCP Seal Injection NS River Water Failure NSCC Failure River Water System Failure DRlSR Power Operation.
Integrated Control System.
Non-Nuclear Instrumentation and Controls.
Turbine Generator.
Condensate System.
Hydrogen Seal Oil and Gas System.
Emergency Electrical - 4KV and 480 Volt.
TMI Grid Operations.
Excessive Primary-to-Secondary Heat Transfer.
Abnormal Transients Rules, Guides and Graphs.
Diesel Generator EG-Y-1 B Emergency Operations C. ALARM RESPONSES:
AA-1-8 H-3-2 SASS MISMATCH.
L-I -6 L-2-3 GEN CORE MONITOR TROUBLE.
AUX XFMR 1 B TRIP.
H-2-5 RX OUTLET T-HOT HI.
GEN H2 SEAL OIL TROUBLE.
D. PRINTS 302-301 Generator Gas & Vents Page 6 of 19
TMI Licensing Exam 5/12/2003 Scenario #2 Rev 1 SIMULATOR INITIALIZATION Action Commentsllnstructions 100% HFP, ICs in full automatic.
Description Initialization Control Console Main Generator reactive load.
IC-16.
Xenon equilibrium.
Middle of Cycle (MOC).
Adjust Main Generator automatic voltage regulator for +200 MVAR
&20.
Value: IN.
When: Immediately.
Value: CLOSE.
When: Immediately.
Scenario support - TSO orders.
Remote Function FWR(37)
Places the 6'h Powdex Vessel into service in preparation for shifting CO-P-IAIB.
Remote Function EGR14.
Closes valve G-07 to isolate Main Generator Hydrogen supply.
Malfunction Nl31 B.
Severity: 100%.
Ramp: 300 seconds.
Event: 2.
RC4A-TE4 RC Hot Leg Temperature Transmitter Failure. (ensure selected)
Blocks ability to lower ICs Unit Load Demand from ULD Toggle Switch.
Diqital I/O Override ZDllCSl MCS(4) 02A4A37-Value: OFF Event: 4.
Diqital I/O Override ZDllCSl3MCS(4)
Diaital I/O Override ZDIICS20MCS(4) 02A4A1 I 02A4A12-Value: OFF.
Event: 4.
Fails Rx Steam Generator Master Low6 Toggle Switch.
Value: OFF.
Event: 4.
Fails Reactor Master Lower Toggle Switch.
1 A Auxiliary Transformer Fault.
Malfunction ED02A.
Event: 5.
Malfunction MS02A.
Severity: 10%.
Ramp: 2 seconds.
Event: 6.
Main Steam Leak in RB.
Malfunction MU08C.
Event: 7 HPI Valve Fails As Is (MU-V-16C).
Event Triqaer 7
Define as MUVMUVl6C>0.99.
Activates Malfunction MU08C to stick MU-V-16C when the valve is wide open.
Main Generator Gas Pressure.
Monitor EGPH2PRESS Monitor EGKH2LOSS Assign to Monitor.
Assign to Monitor.
Fractional rate for Main Generator gas leakage.
Monitor MSK2609A.
Assign to Monitor.
Value: 214.7 psia.
When: immediatelv.
Matches Auxiliary Steam header pressure to nominal value for normal operations.
Page 7 of 19
1 This sheet is to be provided to the examinees for review. I SHIFT BRIEFING Reactor power is 100% with ICs in full automatic.
Due to current grid conditions, Dispatcher has ordered the station to maintain Main Generator reactive load at +200 MVAR k20.
Preparations are complete for removing CO-P-1A from service for maintenance (excessive shaft vibration).
CO-P-1 B will be started before stopping CO-P-1A.
All OP 1106-2 Limits and Precautions are satisfied.
CO-P-16 has been fully primed and vented.
Seal water is lined up from the seal water head tank.
Six Powdex Vessels are in service.
Orders for the shift:
I.
Switch Condensate Pumps IAW OP 1106-2, Condensate System, Section 3.3.2 (provide signed off procedure section, pages 30 & 31).
- 2. Return Powdex Vessel A to standby after shifting Condensate pumps.
- 3. Maintain 100% power.
- 4. Maintain +200 MVAR +20.
Page 8 of 19
TMI Licensing Exam 511 212003 Day 1 Scenario Rev 1 Scenario Outline Simulation Facility:
Three Mile Island Scenario No.:
Day #I Op Test No.:
Event Malf.
No.
No.
1 Nl31 B 2
3 4
EDO2A 5
MS02A 6
MU08C 7
Examiners Description Initial Conditions Turnover Event Event Type*
Description URO Switch operating Condensate Pumps.
N ARO N
US I
URO ARO T-Ave indicatiom(RC4A-TE4)
I us C
URO Main Generator hydrogen gas leak.
C ARO c
us R
URO ARO us Selected RCS Loop A T-hot transmitter failure (high), affecting ICs Manual load reduction to 800 MW due to ICs controller failures.
C URO 1 A Auxiliary Transformer fault (Technical Specifications).
C ARO c
us M
URO M
ARO M
US C
URO Stuck open high pressure injection valve.
ARO c
us Main Steam Line A Rupture Inside the RB with ESAS actuation.
Unit 1 Operators us URO ARO This scenario provides operational situation to evaluate the ability of crew members to implement plant procedures to perform normal operations (switch Condensate Pumps) and to respond abnormal and emergency conditions. While operating at full power, a control system instrumentation failure upsets the balance of plant control. After re-establishing plant stability, a hydrogen gas leak lowers Main Generator gas pressure, requiring a forced load reduction to protect the generator. Because of an Integrated Control System malfunction the load reduction must be performed manually. Following the load reduction, protective relay operation transfers loads off the 1A Auxiliary Transformer to 1 B Auxiliary Transformer and Emergency Generator EG-Y-I B. A major steam line rupture inside the Containment Building causes the reactor to be tripped. Excessive OTSG heat transfer results in a core overcooling event, and ESAS actuation.
Following isolation of feedwater sources to the affected OTSG, crew members are required take actions to prevent RCS reheat and re-pressurization. RCS pressure and temperature are required to be stabilized to protect OTSG and RCS components from excessive stresses that could lead to material failure and fission product release. Control and termination of HPI flow is complicated by a stuck open injection valve.
Plant is at 100% power, with ICs if full automatic. Dispatcher ordered +200 MVAR +20. Ready to switch Condensate Pumps.
See Attached Shift Briefing Sheet.
Page 9 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Event No. 1 Switch Operating Condensate Pumps.
Examiner Notes and Actions SRO Normal Evolution Booth Operator uses FWR37 to return A Vessel to Standby.
(12 minutes)
Pos Applicant ActionslBehaviors I
US 1.O Direct ROs to start CO-P-1 B, and then stop CO-P-1A IAW OP 11 06-2, Condensate System, Section 3.3.2.
System, as directed by the US.
Direct ROs to transfer Powdex Vessel A to standby IAW OP 1106-2, Condensate System, Section 3.3.2.
Direct A 0 to transfer Powdex Vessel A to standby IAW OP 1106-2, Condensate System, Section 3.3.2.
ARO I.
1 Shift Condensate Pumps IAW OP 1106-2, Condensate US 2.0 ARO 2.1 ULD may transfer to manual I
Page 10 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Examiner Notes and Actions Activate Event 2 to Fail T-Hot Instrument.
RO/SRO lnstrurnent Failure Event No. 2 - RCS T-Hot Instrument Failure.
poS ADDlicant ActionslBehaviors URO 1.O Announces unexpected alarm H-3-2 SASS Mismatch.
URO us URO RC4A-TE4 RC Hot Leg temp Transmitter failure 3.0 May recognize and announce elevated RCS T-Hot and Tave indications.
May transfer ICs stations to manual to terminate automatic control system response to failed T-Hot detector. 1 105-4, ICs, Section 3.3.
4.0 RC4A-TE3 is the good inst.
URO us URO us URO us US ARO Procedural guidance for this is found in OP 1105-4, ICs, Section 3.6 (Level I) and H-3-2 ARP.
5.0 Verify validity of the alternate narrow range Loop A T-Hot instrument using Plant Process Computer.
Manually select valid narrow range Loop A T-Hot signal for indicationkontrol.
If applicable, transfers ICs back to automatic mode of control. 11 05-4, ICs, Section 3.3, Placing and Operation of the ICs in Manual and Return to Auto.
Place an EDT sticker on the selector pushbutton for the failed instrument.
6.0 7.0 7.1 If requested, Booth Operator US ARO I
URO I 2.0 Recoanizes and announces automatic control rod in-motion.
8.0 Dispatch personnel to the Relay Room to operate local controls to:
0 Clear H-3-2 annunciator.
0 Defeat the failed instrument input to MAP H-3-2 (optional).
I URO I 4.1 Balance plant parameters to establish stable plant control.
us I I
will use Remote Function ICR15 to clear alarm MAP H-3-2.
Page 11 of 19
TMI Licensing Exam 511 212003 Day 1 Scenario Rev 1 Events No. 3 and 4 Respond to Main Generator Hydrogen Leak.
Forced Load Reduction (In Manual)
~
Examiner Notes and Actions Booth Operator -
Monitor EGPHZPRESS.
Set EGKHZLOSS TO 0.03 When Hydrogen pressure reduces to 40 psig, return EGKHZLOSS to 5.79E-05.
Then, immediately report over the radio:
o You responded to noise at the Main Generator Hydrogen Control Panel, and isolated a hydrogen gas leak by:
o Closing valve HG-V-GO2 o Turning valve HG-V-GO1 to C02 position (CCW).
H2 gas leakage has been term inated.
Activate Event # 4 to fail ICs to respond in auto.
Pos us ARO us RO us URO URO us URO URO (15 minutes)
ARRlicant ActionslBehaviors 1.0 Direct ROs to refer to ARP to respond to MAP L-1-6 GEN H2 SEAL OIL TROUBLE.
1.1 1.2 2.0 Refer to ARP for MAP L-1-6.
Dispatch an A 0 to determine cause for local alarm.
Using OP 1106-1 Figure B-2B, Generator Reactive Capability Curve, determine maximum permissible generator load for 40 psig at +200 MVAR.
Direct ROs to reduce generator load to approximately 850 MW at
%/minute, while maintaining +200 MVAR +20.
3.0 3.1 Attempt to reduce ICs Unit Load Demand to 850 MW.
3.2 Recognize and announce ICs controller failure.
3.3 Direct ROs to reduce load with ICs in manual.
3.3.1 Transfer Steam Generator - Reactor Master to manual.
3.4 Recognize and announce Stm Gen-Rx Master controller Page 12 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Examiner Notes and Actions RO Reactivity Evolution poS ARRliCant ActionslBehaviors p
p failure.
Transfer DTC, Loop A and Loop B RN Masters, Reactor Master to manual.
URO 3.4.1 URO 3.5 Recognize and announce Reactor Master controller failure.
URO 3.5.1 Transfer Diamond Control Panel to manual.
URO 3.5.2 ARO the US.
ARO 3.5.3 Adjust Automatic Voltage Regulator Setpoint as required to Manually reduce plant load to 850 MW at rate specified by maintain +200 MVAR k20.
Page 13 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Event No. 5 - 1A Auxiliary Transformer Fault.
Examiner Notes and Actions 4ctivate Event 5.
T.S.
Entry point, 3.1.6.8 for RM-A-2 Pos us RO us RO US RO us RO us RO us RO us ROs us (12 minutes)
Applicant ActionslBehaviors 1.O Recognize and announce loss of Auxiliary Transformer IA, and loss of #8 230 KV Bus.
Perform and verify Immediate Manual Actions for the following Emergency Procedures:
1203-15, Loss of MakeupIRCP Seal Injection.
0 0
Isolate Makeup and SI.
0 Close MU-V-17 0
Close MU-V-32 2.0 2.1 Determine cause for loss of MU/SI.
2.1.I Significant Follow-Up Actions:
0 Start MU-P-1A.
0 Start DC-P-1A.
0 Start DR-P-1A Re-establish RCP Seal Injection.
0 Re-establish RCS Makeup.
1202-38, NS River Water Failure.
0 Verify/Start Standby Pump 0
May close NR-V-1A.
0 May match flags.
2.2 2.3 1203-20, NSCC Failure.
0 VerifyIStart Standby Pump 0
May match flags.
1203-19, RW Systems Failure DR/SR.
0 VerifyIStart Standby Pump 0
May match flags.
May direct efforts to respond to loss of 1A Auxiliary Transformer IAW MAP AA-1-7.
2.4 2.5 2.5.1 Verify automatic actions:
0 230 KV Breakers open to de-energize 1A Auxiliary Transformer.
Fast Transfer to 1 B Auxiliary Transformer 0
IA7KVBus.
1 E 4KV ES Bus re-energized by emergency diesel generator EG-Y-1 B.
0 2.6 LOSS Of RM-A-2 Page 14 of 19
TMI Licensing Exam 5/12/2003 Day I Scenario Rev 1 Events No. 6 and 7 - Main Steam Line Rupture Inside Containment.
High Pressure Injection Valve Sticks Open.
Examiner Notes and Actions Activate Event 6.
Excessive primary to secondary heat transfer may be diagnosed during performance of the reactor trip EP immediate actions. If so. then Steps A - D here will be performed during (in parallel with) EOP-001 immediate actions.
Pos us RO us us URO us URO URO ARO ARO us ARO URO URO URO (16 minutes)
Applicant ActionslBehaviors 1.O Recognize and announce lowering RCS pressure, Pressurizer level, and rising Reactor Building pressure and activity levels.
Concurs with plant conditions, and requirement to manually trip the reactor in accordance with OP-TM-EOP-001.
Directs URO to manually trip the reactor and perform EOP-001 Immediate Actions.
URO (from memory) performs and verbalizes Immediate Actions of OP-TM-EOP-001, Reactor Trip, and the US performs concurrent verification.
2.0 3.0 4.0 4.1 Depresses the Reactor Trip and DSS pushbuttons.
4.2 Verifies reactor is shutdown (power is less than 7%).
A.
May recognize and declare excessive primary-to-secondary heat transfer, and announce applicability of Rule 3, XHT.
B.
Manually reduce Main FW Flow to the OTSGs (FW Loop Masters are in Hand at time of reactor trip).
C.
Concurs with excessive primary-to-secondary heat transfer, and applicability of Rule 3, XHT.
D.
Initiates Rule 3. XHT.
4.3 Depresses the Main Turbine Trip pushbutton.
4.4 Verifies all 4 Main Turbine stop valves are closed.
4.5 Actuates Global Silence.
4.5 Announces to the Team that EOP-001 Immediate Actions have been completed, and that Global Silence has been initiated.
Page 15 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Events No. 6 and 7 - Main Steam Line Rupture Inside Containment.
High Pressure Injection Valve Sticks Open.
Pos Examiner Notes and Actions Applicant ActionslBehaviors RO will actually need to terminate HPI, since there is no RCS leak.
US US RO RO US US 5.2 Concurs with Symptom Check Report. Announces transition from EOP-001, Reactor Trip, to EOP-003, Excessive Primary-to-Secondary Heat Transfer.
Directs operator actions to perform immediate actions of EOP-003, Excessive Primary-to-Secondary Heat Transfer.
Implement Rule 3, XHT (may already implemented as described earlier).
Initiate Guide 9, RCS Inventory.
0 Direct both ROs to implement Guide 12, Stabilization following OTSG Isolation.
For sequence steps, refer to EOP-010, Guide 12 Direct RO to adjust OTSG 1 B pressure to prevent RCS heatup following isolation of OTSG 1A 6.0 6.1 6.2 For sequence steps, refer to EOP-010, Guide 9 7.0
- 7. I us RO us 7.1.1 Reduce OTSG pressure to prevent RCS reheat and re-pressurization due to coolant expansion, as directed by US.
ARO RO 4.6 Concurs that EOP-001 Immediate Actions have been completed, and acknowledges initiation of Global Silence.
Requests ARO to deliver Symptom Check Report to the Team.
Provides Team with Symptom Check Report, identifying excessive primary-to-secondary heat transfer, and implementation of Rule 3, XHT.
0 Perform phase 1 isolation of A OTSG A side Main Steam 0
A side Main Feedwater Perform phase 2 isolation of A OTSG A side Emergency Feedwater 5.0 5.1 0
7.2.1 Bypass and defeat Train A and B ESAS actuation signals to gain control of ES equipment.
us 7.2 Direct RO to throttleherminate HPI IAW Rule 2, LPVHPI Throttling.
0 For sequence steps, refer to EOP-010, Rule 2.
RO I 7.2.2 Reduce HPI flow to prevent RCS re-pressurization due refill, Page 16 of 19
TMI Licensing Exam 5/12/2003 Day 1 Scenario Rev 1 Events No. 6 and 7 - Main Steam Line Rupture Inside Containment.
High Pressure Injection Valve Sticks Open.
Examiner Notes and Actions d
The only way to terminate flow through MU-V-16C is to stop MU-P-lC, either at this point or at Step 7.2.4 below. (Event #7)
I RO us RO I Should not apply to current conditions.
Should not apply to current conditions - not being fed.
Should not apply to current conditions.
Required if RB Pressure >2 psig.
Required if RB Pressure >2 psig.
P P
I (16 minutes)
Applicant ActionslBehaviors as directed by the US.
7.2.2.1 Recognize and announce that MU-V-16C is stuck open.
(note: loss of power to motor operator) 7.2.3 Open MU-V-36 and MU-V-37 (minimum recirc valves) prior to reducing HPI flow below 115 gpm per operating pump.
7.2.4 Stop MU-P-lC, allowing MU-P-1A to continue to operate to provide RCP seal Injection and RCS makeup flow.
7.2.5 7.3 Dispatch and A 0 to manually close MU-V-16C.
May close MU-V-14A and MU-V-148 to isolate MU-P-1 B suction from the BWST when the Makeup Tank level is >55 inches (IAW Guide 9, RCS Inventory Control).
Review Rule 6, PTS, for applicability.
7.4 7.5 Review Guide 13, Dry OTSG, for applicability.
7.6 Review Guide 14, TSDT Limit Guide, for applicability.
7.7 lmdement and announce successful comdetion of Guide 15: EFW Actuation.
Announce transition to EOP-003 Follow-up Actions.
8.0 9.0 Direct RO actions to complete EOP-003 Follow-up Actions.
9.1 Perform EOP-003 Follow-up Actions as directed by the US.
9.2 May direct RO to initiate OP-TM-534-901, Reactor Building Emergency Cooling Operations if RB pressure >2 psig.
Initiate OP-TM-534-901, Reactor Building Emergency Cooling Operations if RB pressure, as directed by the US.
Announce transition from EOP-003 Follow-up Actions to EOP-001 VSSV (IAW Step 3.15).
Direct RO actions to complete EOP-001 VSSV actions.
9.2.1 9.3 9.4 Page 17 of 19
Examiner Notes and Actions poS Applicant ActionslBehaviors RO Page 18 of 19 9.5 Perform EOP-001 VSSV actions as directed by the US.
Scenario can be terminated.
L US 9.6 Announce transition EOP-001 Follow-up Actions.
US 9.7 Direct RO actions to complete EOP-001 Follow-up actions.
RO 9.8 Perform EOP-001 Follow-up Actions as directed by the US.
TMI Licensing Exam 5/12/2003 Day I Scenario Rev 1 TERMINATION CRITERIA When all of the following conditions exist:
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
- 6.
'7.
Reactor is shutdown.
OTSG 1A is isolated and depressurized.
HPI is terminated.
Flow through MU-V-16C has been terminated.
RCS pressure and temperature are stabilized.
EOP-003 actions are complete.
EOP-001 VSSV actions have been completed.
EOP-001 Follow-up Actions are in progress.
EMERGENCY PLAN CLASSIFICATION ALERT HA4 Non-Bomb Explosion inside the Vital Area.
I Exelon Standard E-Plan EALs. I TECHNICAL SPECIFICATIONS 3.7 Electrical 3.1.6.8 RM-A-2 Page 19 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Instrumentation Failure SRO Normal Evolution Instrumentation Failure SRO INSTANT Scenario Day 2 Pressurizer Level Instrument Failure.
Swap Makeup Pumps.
M U-V-32 Fa i I u re.
Component Failure Instrumentation Failure OTSG Tube Leak (Small).
CRD Fails to Respond in Automatic.
RO Reactivity Change I Manual Power Reduction.
Instrumentation Failure Major Malfunction ES Train Failure.
I OTSG Tube Rupture.
Page 1 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Quantitative Attributes Total Malfunctions Rev 3 Target 5-8 SRO INSTANT Simulator Scenario Dav 2 Pressurizer Level Instrument Failure.
MU-V-32 Failure.
OTSG Tube Leak (Small).
CRD Fails to Respond in Auto.
OTSG Tube Rupture.
ES Train Failure.
I Pressurizer Level Instrument Failure.
MU-V-32 Failure.
I CRD System Fails to Respond in Automatic.
CRD Fails to Respond in Auto.
ES Train Failure.
I ES Train Failure.
Major Transients OTSG Tube Rupture.
1-2 2-4 EOP Contingencies Requiring Substantive 0-2 EOPs Entered With Substantive Actions OP-TM-EOP-005, OTSG Tube Leakage.
1-2 I Critical Tasks SRO Direct entry into OP-TM-EOP-005, OTSG Tube Leakage.
RO Implement EOP-010 Guide 2 in response to HPI Train B Failure RO/SRO Maintain <IO00 psig OTSG pressure to limit MSSV operation RO/SRO Minimize RCS Subcooled Margin to reduce tube leak rate.
2-3 Actual 6
2 4
1 1
1 4
Page 2 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Reqd SRO INSTANT Actual As RO I
Manual Power Reduction.
InstrumentKomponent Failures I - Pzr Level Instrument Fails. I I - CRD Auto Control I
I I Reactivitv 1 1 1 1 2
1=3 c = 2 C -MU-V-32 Failure.
Failure.
I -ES Train Failure.
C -0TSG Tube Leak (Small).
OTSG Tube Rupture.
I Major As SRO 1
Normal Evolution Swap Makeup Pumps.
Instrument/ComDonent Failure I
1 2
C -MU-V-32 Failure.
C -0TSG Tube Leak (Small).
I - Pzr Level Instrument Fails. I I - CRD Auto Control I
Failure.
I -.ES Train Failure.
Major OTSG Tube RuDture.
1 1
1=3 c = 2 I
Page 3 of 19
DATE 5/27/0 1 71710 1 4/12/2003 5/12/2003 REFERENCE TITLE N/A NIA NA per NRC validation TMI Licensing Exam 511 212003 Day 2 Scenario Rev 3 DESCRIPTION--(lnclude AI # if appropriate)
New Scenario
- 1. Added Pressurizer level instrument failure.
- 2. Added Tech. Spec. information for discussion at end of scenario.
Updated for current procedure revisions.
Format and editorial changes. Changed MU-V-32 malfunction to fail the valve open in automatic mode of control. Reduced initial power level at request of NRC.
added more detailed EP responses, TS reference.
Page 4 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 GENERAL DESCRIPTION OF SCENARIO The scenario will be initiated at 30% power. Makeup Pump 1 B (MU-P-1 B) was removed from service for an oil change, and is now ready to be returned to service. Crew direction is to return MU-P-1 B to service and maintain 30% Power steady state operation.
The selected Pressurizer level instrument slowly fails low. The crew will swap to the alternate Pressurizer level and temperature instruments.
The crew will swap from MU-P-1A to MU-P-1 B IAW 11 04-2, Makeup and Purification System.
Once MU-P-1 B is in operation, MU-V-32, Seal Water Injection Flow Control valve will fail open, requiring the team to establish manual RCP seal injection flow control.
A small tube leak will occur. Alarm C-1-1, High Radiation, will actuate to cue the crew to the tube leak. The crew will respond IAW Alarm response procedure for MAP C-1-1, and implement OP-TM-EOP-005, OTSG Tube Leakage procedure.
The crew will commence a normal plant shutdown IAW OP-TM-EOP-005, MAP C-I -1, and Technical Specification requirements.
During the power reduction, the rod control diamond station will fail to respond in Auto. The crew will be required to continue the shutdown with Manual control of the Diamond CRD station and Feedwater ICs stations.
A large OTSG tube rupture develops. The crew will have to evaluate plant conditions, and should trip the reactor and initiate High Pressure Injection.
The 'B' train of Engineered Safeguards Actuation System will not actuate using the Manual Actuation pushbuttons, requiring manual HPllLPl initiation at the component level.
Estimated scenario time - 60 minutes.
Critical Tasks 3 SRO Critical Tasks 3 RO Critical Tasks Page 5 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 REFERENCES A. 10 CFR 55.45 Operating Tests, (a) Content (3), (4), (5), (6), (7), (8), (9), (12), (13)
B. PROCEDURE
S:
OP 11 02-4 OP I 104-2 OP 11 05-4 EP 1202-12 EP 1202-29 OP-TM-EOP-00 1 OP-TM-EOP-005 OP-TM-EOP-01 0 Power Operation.
Makeup and Purification System (marked up copy).
Integrated Control System.
Excessive Radiation Levels.
Pressurizer System Failure.
OTSG Tube Leakage.
Abnormal Transient Rules, Guides and Graphs.
C. ALARM RESPONSES:
C-1-1 HIGH RADIATION.
F-1-5 G-2-5 PZR LEVEL HI/LO.
G-3-5 PZR LEVEL LO-LO.
G-2-2 CRD SEQUENCE FAULT G-2-6 PWR DISTRB LIMITS EXCEEDED RCP SEAL TOT INJECT FLOW HIILO.
D. OTHER Maintenance Risk Document for EF-P-2A.
Page 6 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Initialization IC-I 6.
Control Console Reduce power to 30%.
Adjust Mvars to 0.
Trip FW-P-1 B, open drains.
Start FW-P-1 B AC Lube Pp.
Reduce to 4 Powdex Vessels.
Secure all MO-Ps.
Start MU-P-IA, stop P-I B.
Start IC-P-1 B, stop IC-P-1A.
Tag EF-P-2A out of service.
Stop HD-P-1 A.
SIMULATOR INITIALIZATION Malfunction ESOIB ES02B Remote Function CCRl2 Remote Function FWR12 I4 Action Commentsllnstructions Description 100% HFP, ICs in automatic.
When: Immediately.
Xenon equilibrium, Middle of Cycle (MOC).
Scenario support.
Use FW Remote Functions.
Malfunction RC04A.
Malfunction MU07.
Severity: 100%.
Ramp: 240 seconds.
Event: 1.
Severity: 100%.
Ramp: 30 seconds.
Event: 3.
Severity: 0.08%.
Event: 4.
Event: 6.
Pressurizer Level instrument failure.
MU-V-32, RCP seal injection control valve, fails open in automatic mode.
Malfunction TH17A.
Malfunction RD1 OC OTSG 1A Tube Rupture (Low).
CRD Group 7 Automatic In-Motion Command Block.
Malfunction TH 16A Severity: 5.0%.
Ramp: 1 second.
Event: 7.
When: Immediately.
OTSG tube rupture (middle).
~
~~~
B Train ESAS Fail to Actuate at 1600# and 500# Setpoints.
Value: NS.
When: Immediatelv.
Transfer MU-P-1A to NSCC cooling.
Value: OUT.
When: Immediately.
Value: OFF.
When: Immediately.
Value: OFF.
When: Immediately.
Define as CRQCRNM 0.27.
Rack out EF-P-2A breaker to the disconnected position, remove fuses.
Digital I/O Override Digital I/O Override Event Trimer 6
03A4S02-ZDIPBI RBB 03A4SOl-ZDIPBl RCB Blocks B Train Manual 4# ES actuation.
Blocks B Train Manual 1600# ES actuation.
Trigger is used to block automatic in-commands from Group 7 rods.
Monitor MSK2609A.
Assign to Monitor.(VERIFY)
Value: 215 psia.
When: Immediately.
Matches Auxiliary Steam header pressure to nominal value for normal operations.
Page 7 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 I This sheet is to be provided to the examinees for review. I SHIFT BRIEFING Reactor power is 30% with ICs in automatic.
Xenon is building up due to recent power reduction.
FW-P-IA is in service.
FW-P-IB has been secured.
Emergency Feedwater Pump 2A (EF-P-2A) is tagged out for bearing replacement.
0 Expected to be returned to service in next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Makeup Pump 1A is running to support an oil change on Makeup Pump IB.
0 Makeup Pump 1A is being cooled by Nuclear Services Closed Cooling Water.
0 MU-P-?A and MU-P-IC are currently selected for ES.
0 IC-P-1 B is operating with IC-P-1A in standby.
0 The oil change has been completed and Makeup Pump 16 is ready to be returned to service.
On-Line Risk Management Sheet # I 32 is attached for reference.
Orders for the shift:
- 1. Swap from Makeup Pump 1A to Makeup Pump 1 B.
- 2. Continue 30% power operation.
Page 8 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Scenario Outline Simulation Facility:
Three Mile Island Scenario No.:
Day #2 Op Test No.:
Unit 1 Examiners Operators us URO Event No.
Malf.
No.
RC04A ARO Event Type*
I URO Description This scenario provides operational situations to evaluate the ability of crew members to implement plant procedures to perform normal operations, and to respond to abnormal and emergency conditions. While operating at reduced power, the operators are required to mitigate the effects of a controlling instrument failure by establishing manual control and then selecting alternate (valid) input signals. After re-establishing automatic RCS inventory control, the operators implement normal operating procedures to switch operating Makeup Pumps. An additional control system malfunction requires the operators to establish manual flow control for RCP seal injection. A small OTSG tube leak (greater than Technical Specification limits) forces the operators to implement an emergency operating procedure that includes plant shutdown. The power reduction is performed in manual due to an automatic control problem in the Control Rod Drive System. During the shutdown, a large OTSG Tube rupture develops, requiring the operators to initiate High pressure Injection and trip the reactor. One of the two ES Trains will not actuate automatically or manually at the Train level, requiring the operator is to initiate individual components. Following reactor trip, actions are performed to ensure the reactor is shutdown properly, establish radiological controls and isolate potential secondary release paths, prevent inadvertent operation of the Main Steam Safety Valves, and reduce RCS leakage through the OTSG tubes in order to limit off-site doses.
Plant is at 30% power, with ICs in automatic. FW-P-1A is in operation. EF-P-2A is out of service for bearing replacement. MU-P-1A is operating, cooled by NSCC, to support MU-P-1 B oil change.
Initial Conditions I
2 3
ARO I
us URO N
ARO N
US MU07 C
URO ARO TH17A c
us C
URO 4
I I
ARO 5
6 7
8 c
us URO ARO us RD1 OC I/R URO ARO I
us TH16A M
URO ARO M
US ESOI B I
URO ES02B ARO Sheet.
Event Description Pressurizer level instrument failure.
Switch operating Makeup Pumps.
MU-V-32, RCP seal injection valve, failure.
Small OTSG 1A tube leak.
Initiation of plant shutdown.
Control Rod Drive System automatic control failure.
OTSG tube rupture.
ES Train failure.
Page 9 of 19
TMI Licensing Exam 511 2/2003 Day 2 Scenario Rev 3 Activate Event #I (N)ormal, (R)eactivity, (I)nstrument, (C)omponent, (M)ajor Event No. 1 Pressurizer Level Instrument Failure.
P Direct Operations I t-Expected Operator Actions 1.O Recognize and announce Pressurizer level instrument failure from MAP alarms G-2-5, PZR LEVEL HVLO, G-3-5, PZR LEVEL LO-LO, MU-V-17 response and redundant indications.
2.0 Announce entry into EP 1202-29, Pressurizer System Failure.
2.1 Take MU-V-17 to Hand and adjust makeup flow to equal letdown flow minus seal injection.
Select alternate pressurizer level transmitter.
2.2 2.3 2.4 3.0 Select alternate pressurizer temperature transmitter.
Transfer MU417 back to automatic control mode (optional).
US may request Equipment Deficiency Tag (EDT) be placed on LT-1 Pressurizer Level Transmitter Selector.
Place EDT on LT-1 Selector Switch, as directed by the US.
3.1 Page 10 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Event No. 2 Swap From Makeup Pump I A to Makeup Pump 1B Pos URO RO RO URO URO URO RO RO US URO Examiner Notes and Actions Direct Operations Expected Operator Actions Direct Makeup Pump swap IAW OP 1104-2, Makeup and Purification System.
Verify MU-P-IB lube oil system is running normally.
Have A 0 ES select MU-P-1 B.
1.0 1.1 I
.2 1.3 Start MU-P-1B.
1.4 I
.5 Stop MU-P-1A when conditions stabilize.
Monitor makeup and seal injection flows and adjust as necessary.
Have A 0 ES select MU-P-1 C.
Change MU-P-1A cooling water supply back to DCCW.
US may direct operator to start IC-P-IA, stop IC-P-1 B (optional).
Shift operating IC-Ps as directed by the US.
1.6 1.7 2.0 2.1 ICO: MUR29 to MU-PI B Control Board Operations ICO: MUR29 to MU-PIC ICO: CCRIS to DC Page 11 of 19
TMI Licensing Exam 511 212003 Day 2 Scenario Rev 3 Pos URO us URO US URO Event No. 3 MU-V-32, RCP Seal Injection Valve Failure.
Expected Operator Actions 1.O Recognize and announce rising seal injection flow from MAP alarm F-1-5, RCP SEAL TOT INJECT FLOW HI/LO, and seal injection flow console indication.
Diagnose MU-V-32 failure (valve open too far).
Direct the operator to transfer MU-V-32 to Manual control, restore normal RCP Seal Injection flow, and maintain Manual flow control.
As directed by the US, transfer MU-V-32 to Hand and restore normal seal injection flow by throttling MU-V-32 in the closed direction.
2.0 2.1 2.2 Examiner Notes and Actions Activate Event #3 Direct Operations Page 12 of 19
TMI Licensing Exam 511 2/2003 Day 2 Scenario Rev 3 Event No. 4 Small Tube Leak Develops in OTSG IA.
Examiner Notes and Actions Activate Event #4 Procedures Direct Operations SRO Critical Task Technical Specifications Pos us RO us us us us URO URO Expected Operator Actions 1.O Diagnose a tube leak in OTSG 1A from MAP alarm C-1-1, HIGH RADIATION, and rising indication/alarms on RM-G-26, RM-A-5 and RM-A-15.
2.0 Direct RO activities to implement ARP for MAP C-1-1, HIGH RADIATION.
3.0 Direct RO Actions to implement Immediate Actions of EP 1202-12, Excessive Radiation Levels:
0 Page announcement.
0 0
Markcharts.
Contact GRCS.
Maintenance, operations or sampling is N/A.
4.0 5.0 Direct STA to start a one-hour leak rate calculation.
Direct ROlSTA to perform a mass balance calculation for leak 6.0 Perform mass balance and validate OTSG leak rate greater than 1 aDm.
7.0 Determine that criteria is met for entry into OP-TM-EOP-005, OTSG Tube Leakage (greater than 1 gpm).
Page 13 of 19
TMI Licensing Exam 511 2/2003 Day 2 Scenario Rev 3 Event No. 5 Commence Plant Shutdown as Directed by OP-TM-EOP-005, OTSG Tube Leakage.
Pos US US US URO Examiner Notes and Actions ExDected ODerator Actions 1.O Direct RO activities to implement OP-TM-EOP-005, OTSG Tube Leakage.
Direct RO to close MU-V-3 as necessary and increase makeup to maintain Pressurizer level.
Direct a plant shutdown to commence at a specified rate, using OP 11 02-4, Power Operation.
Set ULD rate of change to value specified by US, and reduce ULD megawatt demand to commence a plant shutdown.
I.
1 1.2 1.3 Procedures Technical Specifications US ROs US US Direct Operations 1.4 Monitor plant response as power reduction begins.
1.5 Emergency classification will be obtained after the scenario since the examinee does not have the support of a Shift Manager for Emergency Plan implementation.
Direct notification of Chemistry and Rad Con and for sampling and surveys.
1.6 Page 14 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Pos Examiner Notes and Actions KO: When Reactor power is less than 27%, verify Event #6 activates to fail the Diamond CRD panel to respond in Auto.
(group 7 in command failure)
Diagnosis Expected Operator Actions NOTE: Entrance into TS 3.5.2.5 for CRD overlap is possible.
NOTE: Requires the following stations (as a minimum) to be transferred to Hand:
0 ATC 0
0 ICs Reactor Demand.
0 Diamond CRD Panel.
Feedwater Demand A & B.
US ARO Event No. 6 Diamond Fails to Respond in Automatic.
1.O Recognize and announce Diamond CRD panel failure to respond by ICs alarms and cessation of CRD movement.
0 Expected Alarms:
0 G-2-2 CRD SEQUENCE FAULT G-2-6 PWR DISTRB LIMITS EXCEEDED I
us ROs 2.0 Direct ROs to transfer ICs to Manual to continue the power reduction.
0 May direct URO to take hand control of SG/Rx demand station.
0 Group 7 fails to respond 0
US should direct the next step Place ICs in Hand and recommence power reduction as directed by the US.
2.1 Page 15 of 19
TMI Licensing Exam 511 212003 Day 2 Scenario Rev 3 Events No. 7 and 8 Large OTSG Tube Rupture Develops, B Train ESAS Actuation Fails.
Examiner Notes and Actions Activate Event #7 System Response Procedures (Event 8 occurs)
RO Critical Task This task is critical to event mitigation strategy due to the degraded condition of High Pressure Injection.
Pos URO RO ROs URO URO us URO URO URO URO URO us URO Expected Operator Actions 1.O Recognize and announce significant leak rate increase from Pressurizer level reduction, MU-V-17 valve position demand, and rising Makeup flow.
2.0 Close MU-V-3 to conserve RCS inventory.
3.0 4.0 Continue power reduction in Hand.
Recognize Pressurizer level lowering below 150 inches while Reactor power is greater than 25%.
Announce requirement to initiate High Pressure Injection, and to trip the reactor IAW step 3.3.1.A.
4.1 5.0 Concur with requirement to initiate High Pressure Injection, and to trip the reactor IAW step 3.3.1.A, and then to perform EOP-001 Immediate Actions.
5.1 Depress Manual 1600 psig ESAS Actuation Buttons for High Pressure Iniection.
5.2 Recognize and announce the failure of " B Train ESAS manual actuation.
Implements Guide 2, HPI/LPI Initiation.
6.0 6.1 Manually initiates two HPI Pumps and two LPI Pumps in ES alignment at the component level as follows:
0 Open MU-V-14B.
0 Start MU-P-IC.
0 Open MU-V-16C.
0 Open MU-V-16D.
0 Close MU-V-37.
0 Start DC-P-1 B.
0 Start DR-P-1 B.
0 Close MU-V-3.
0 Open DH-V-5B.
0 Start DH-P-1 B.
0 Open DH-V4B.
7.0 URO (from memory) performs and verbalizes Immediate Actions of OP-TM-EOP-001, Reactor Trip, and the US performs concurrent verification.
7.1 Depresses the "Reactor Trip" and "DSS pushbuttons.
Page 16 of 19
TMI Licensing Exam 511 212003 Dav 2 Scenario Examiner Notes and Actions poS Expected Operator Actions URO URO 7.2 7.3 Verifies reactor is shutdown (power is less than 7%).
Depresses the Main Turbine Trip pushbutton.
URO URO 7.4 8.0 Actuates Global Alarm Silence.
Verifies all 4 Main Turbine stop valves are closed.
I I 13.1.1 Notify SM to evaluate EALs.
URO US I
I 13.2 Determine affected OTSG.
I 9.0 Announces to the Team that EOP-001 Immediate Actions have been completed.
Concurs that EOP-001 Immediate Actions have been completed, and acknowledges actuation of Global Alarm Silence.
10.0 13.3 Initiate Attachment 2 to establish radiological controls and isolate secondary release paths.
US 11.O Directs ARO to deliver Symptom Check Report to the Team.
, ARO 11.I Provides Team with Symptom Check Report.
US 12.0 Concurs with Symptom Check Report.
US 13.0 Announces transition out of EOP-001 back to EOP-005 due to the OTSG tube leak.
Direct follow up actions of EOP-005, OTSG Tube Leakage:
US 13.1 13.4 Transfer Gland Steam System to the Auxiliary Steam supply.
SRORO Critical Task I 13.5 Perform a Symptom Check.
I 13.7 Dispatch A 0 to verify all Main Steam Safety Valves (MSSVs) are closed.
13.7.1 Direct performance of an alarm review.
Direct Operators to reduce and maintain OTSG pressure to less than 1000 psig to prevent lifting Main Steam Safety Valves.
US 13.8 RO 13.6 Announce reactor trip over plant page and radio system.
I US I 13.9 Direct ROs to implement Guide 8, RCS Pressure Control to Page 17 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 Events No. 7 and 8 Large OTSG Tube Rupture Develops, B Train ESAS Actuation Fails.
t SRORO Critical Task This task is critical in order to reduce the primary to secondary leak rate to reduce the dose to the public.
Expected Operator Actions minimize Subcooled Margin (SCM).
13.9.1 Implement Guide 8, RCS Pressure Control to minimize Subcooled Margin (SCM), as directed by the US.
13.9.2 Reduce RCS pressure until SCM is between 70" and 30°F.
0 Turn off Pressurizer heaters.
0 Open Pressurizer Spray Valve RC-V-I.
Close RC-V-I when SCM has been minimized (between 70" and 30°F).
NOTE: When cool-down is initiated, terminate scenario.
Page 18 of 19
TMI Licensing Exam 5/12/2003 Day 2 Scenario Rev 3 TERMINATION CRITERIA When all of the following conditions exist:
1, The examinees have had the opportunity to perform all critical tasks.
- 2. OTSG pressures are both less than 1000 psig.
- 3. Sub-cooled Margin has been reduced to between 30 and 70°F.
- 4. Plant cool-down is in progress.
EMERGENCY PLAN CLASSIFICATION (Based on Exelon Standard Emergency Plan)
FA1 ALERT Potential Loss of RCS Barrier (> 160 gpm Primary to Secondary leak)
TECHNICAL SPECIFICATIONS 3.4 Decay Heat Removal Capability 3.4.1.I
- a. (2) gives 72-hour time clock for one Emergency Feedwater Pump out of service, or be in Cold Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3.1.6 Leakage 3.1.6.3 is LCO for exceeding 1 gpm primary to secondary leakage, however, the Operating License only allows 0.1 gprn above baseline leakage rate.
3.5.2.5 May be entered for CRD overlap.
Page 19 of 19