ML14351A426
| ML14351A426 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/11/2014 |
| From: | Orphanos P Exelon Generation Co, Nine Mile Point |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP2L 2568 OP-AA-102-106, Rev. 3 | |
| Download: ML14351A426 (27) | |
Text
This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 5.
A ExeLon Generation,.
NMP2L 2568 10 CFR 50.90 December 11,2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410
Subject:
Supplement Information for the NRC Audit Concerning Nine Mile Point Nuclear Station License Amendment Request for Maximum Extended Load Line Limit Analysis Plus
References:
- 1.
Letter from P. Swift (NMPNS) to Document Control Desk (NRC), License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus, dated November 1,2013 (ML13316B1307)
- 2.
Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC),
License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus-Core Reload and Safety Limit Supplemental Information, dated February 25, 2014 (ML14064A317)
- 3.
Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC),
License Amendment Request Pursuant to 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus-Revision 1, dated June 13, 2014 (ML14169A034)
- 4.
Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC),
Response to Request for Additional Information Nine Mile Point Nuclear Station License Amendment Request for Maximum Extended Load Line Limit Analysis Plus, dated September 15, 2014 (ML14266A185)
- 5.
Letter from C. Costanzo (NMPNS) to Document Control Desk (NRC),
Response to Fourth Request for Additional Information Nine Mile Point Nuclear Station License Amendment Request for Maximum Extended Load Line Limit Analysis Plus, dated October 10, 2014 (ML14288A241)
Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information in support of a previous request for amendment to the Nine Mile Point Unit 2 (NMP2) Renewed This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 5.
ADo(
U. S. Nuclear Regulatory Commission December 11,2014 Page 2 Facility Operating License NPF-69. The initial request, dated November 1, 2013 (Reference 1),
included a proposed expansion of the operating boundary to allow operation in the Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain and the use of the General Electric Hitachi Nuclear Energy (GEH) analysis code TRACG04. The November 1,2013 request (Reference 1) was revised on June 13, 2014 (Reference 3).
This supplemental submittal contains the information requested by the NRC MELLLA+ Audit Team on November 20, 2014, during the NMPNS Simulator Audit. contains the Operator Response Time Validation sheets for the Time Critical Actions. There are two sets of Operator Response Time Validation sheets, one for each of the Time Critical Actions. The validation information in Attachment 1 supplements the responses to RAI # APHB-1 and RAI # APHB-2 provided on October 10, 2014. (Reference 5) is the current Supplemental Reload Licensing Report (SRLR) for Nine Mile Point 2 (NMP2). This document was prepared by Global Nuclear Fuel (GNF) as 000N2528-SRLR, Revision 1, Class I, January 2014, Reload 14 Cycle 15, Extended Power Uprate (3988 MWt)/MELLLA (99-105% Flow). The MELLLA+ SRLR was previously submitted on February 25, 2014 (Reference 2). is the non-proprietary version of the updated traversing incore probe (TIP) comparisons for current operating conditions prepared by GEH and documented in GEH letter GE-PPO-1GYEF-KG1-742. The TIP comparison information provided in Attachments 3 and 5 supplements the response to RAI SRXB(2)-1.0: Power Density> 50 MWT/MLBM/HR, submitted September 15, 2014 (Reference 4). is the Affidavit justifying withholding of the proprietary information in Attachment 5. is the proprietary information provided to NMPNS as Enclosure 1 of GEH letter, GE-PPO-1GYEF-KG1-742, "GEH Response to the NRC Request for an Update of the TIP Comparisons for Current Operating Conditions," dated December 2, 2014. of this letter contains information considered to be proprietary as defined by 10 CFR 2.390. GE Hitachi Nuclear Energy (GEH), as the owner of the proprietary information in, has executed the affidavit provided in Attachment 4 detailing the reasons for withholding the proprietary information. On behalf of GEH, NMPNS hereby requests that proprietary information in Attachment 5 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390.
The revision to the original amendment request (Reference 3) updated the no significant hazards consideration originally submitted in Reference 1. The Request for Additional Information (RAI) responses submitted on September 15, 2014 (Reference 4) and October 10, 2014 (Reference 5) inadvertently omitted references to the revised request (Reference 3) submitted on June 13, 2014. The supplemental information submitted in the RAI responses on September 15, 2014 and October 10, 2014 were reviewed and determined the information provided did not change the initial or revised determination of "no significant hazards
U. S. Nuclear Regulatory Commission December 11,2014 Page 3 consideration" justified in the original amendment request (Reference 1) and in the revised amendment request (Reference 3).
This supplemental information does not change the determination of "no significant hazards consideration" justified in the original amendment request, Reference 1, and as revised in Reference 3. Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental information to the appropriate state representative.
This letter contains no new regulatory commitments.
Should you have any questions regarding the information contained in this submittal, please contact Mr. Terry Syrell, Acting Regulatory Assurance Manager, at (315) 349-5245.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1 1th day of December, 2014.
Respectfully, P etIe rP.
, phan,sV Plant Manager - Nine Mile Point Exelon Generation Company, LLC PMO/KJK Attachments:
- 1. Operator Response Time Validation
- 2. Supplemental Reload Licensing Report for Nine Mile Point 2, Reload 14 Cycle 15, Extended Power Uprate (3988 MWt) / MELLLA (99-105% Flow)
- 3. Updated TIP Comparisons for Current Operating Conditions, GE-PPO-1GYEF-KG1-742, Enclosure 2 (Non-Proprietary)
- 4. General Electric - Hitachi Affidavit Justifying Withholding Proprietary Information in GE-PPO-1GYEF-KG1-742, Enclosure 1
- 5. Updated TIP Comparisons for Current Operating Conditions, GE-PPO-1GYEF-KG1-742, Enclosure 1 (Proprietary) cc:
Regional Administrator, Region I, USNRC Project Manager, USNRC Resident Inspector, USNRC A. L. Peterson, NYSERDA
ATTACHMENT 1 OPERATOR RESPONSE TIME VALIDATION Nine Mile Point Nuclear Station, LLC December 11, 2014
OP-AA-1 02-106 Revision 3 Page 1 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 1 of 6
- 1. Validation Team Members:
Name Title Daniel A. Cifonelli Shift Manager Mike Smith Qualified Simulator Trainer/Operator Dwayne Lemay Qualified Simulator Trainer/Operator George Inch MELLLA+ Senior Engineer Vinod Patel MELLLA+ Senior Engineer James Kinsley MELLLA+ Lead Installation Representative NMP2 "A","C", "D" and "E" NMP2 "A","C", "D" and "E" Shifts Shifts (See Attached)
(See Attached)
Note: This is Revision 1 to this Operator Critical Action Validation. This revision did not change any conclusions, but resolved several editorial issues.
- 2. Validation Preparation:
Determine and List the following current information for the Operator Response Time Item to be validated:
Unique Identifier Action Source Implementing Time Required (TR) by Action Type Description (basis Doc. or PRA)
Procedure, Revision, In Minutes (e.g. TCA1 or TSA1) for the Action and Step(s) or Action(s)
Source Revision TCA10 Place Mode Switch Project Task Report
- 1. N2-SOP-101C, 0.333 in Shutdown in an Task T0902: ATWS Reactor Scram. Rev ATWS Event (000-0135-5571-Ri, 00800, Flowchart DFR 0000-0069-Immediate Action 6535 Class III
- 2. N2-EOP-RPV, August 2013)
RPV Control, Rev 01400, Flowchart Step #1 Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 2 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 2 of 6 Unique Identifier by Action Type (e.g. TCA1 or TSA1):
TCA10
[
Verify the current TCA/TSA source document(s)/program(s) requirement is unchanged since the last validation. Otherwise, verify the Implementing Procedure Step(s) or Action AND site specific Operating Response Time procedure are updated, as appropriate.
[
Review the TCAiTSA Implementing Procedure revisions since the last validation to identify potential impact on the Expected Performance Time (ET). If a potential impact exists, then ensure the validation accounts for the change.
[
Review Crew human performance methodology changes to identify potential impact on the Expected Performance Time (ET). If potential impacts exist, then ensure the validation accounts for the change.
[
Review known Plant Modifications to identify potential impact on the Expected Performance Time (ET). If potential impacts exist, then ensure the validation accounts for the change.
- 3. Validation Planning:
Note: A combination of validation methods may be utilized.
Validation Method(s):
NSimulator Scenario (e.g. Training, Out of the Box Evaluations (OBEs), other)
[] Plant Walkthrough (e.g. JPM, Training, other)
D1 Estimated Times (When simulator and plant walkthrough are not practical or to account for other time to improve the accuracy of the Expected Performance Time (ET).)
Simulator Scenario and revision (if used) Course Code: 2100-MELLLAS01 Supplemental Equipment Req'd (if used) N/A Determine and List the number of Operator(s) and basis: See Attachment 3 for list of Operator's names and qualifications who participated in the validations. (Normal and Minimum Shift Complement)
Determine and List the Starting Location(s) for the Operator(s) and basis:
Operators started in the Nine Mile Point Unit 2 Simulator (Normal location).
Use SRRS 2A.1 12 for this record
OP-AA-1 02-106 Revision 3 Page 3 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 3 of 6 Unique Identifier by Action Type (e.g. TCA1 or TSA1):
TCA10 Note: If a plant condition is the basis for the start of the Required Time (TR), then the establishment of the plant condition should also be the start of the Expected Performance Time (ET). Simulator, Plant Walkthrough, or Estimated Times or a combination of these methods should be used to account for the expected time for Operator recognition of the plant condition, procedure entry, direction provided for Operator response, and Operator response.
Action/indication to start time clock:
Initiating Events were taken as the start time in each scenario. The following scenarios were run on each crew. (1. Dual Recirc Pump Trip, 2. MSIV Closure, 3. Pressure Regulator Failure, 4. Turbine Trip Without Bypass, 5. Loss of All Offsite Power). In all cases, Control Rods fail to insert automatically or by Operator manual actions (ATWS).
Action/indication to stop time clock:
Mode Switch placed in Shutdown per N2-SOP-1 01 C. Reactor Scram and/or Emergency Operating Procedure (N2-EOP-RPV)
Validation Performance Plan Approved By: Daniel A Cifonelli 9/3/14 Team Leader Date Use SRRS 2A. 112 for this record
OP-AA-102-106 Revision 3 Page 4 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 4 of 6
- 4. Post Validation Review:
Expected Performance Time (ET) (Total Time to perform the action): Average 8.49 seconds (0.142 minutes)
Note: A Sat. Time validation Expected Performance Time (ET) is <= Time Required (TR).
/
Usat- (circle one)
PITnsat, list IR # (otherwise N/A) N/A Comments:
The Licensed Reactor Operator's (RO) ability to place a manual Scram within 20 seconds is relatively simple and It Is generally recognized that ROs are proficient at this action. It is a common action that is required in many contingency scenarios and Operators are well trained in this action. It was accomplished with no challenges. This action was completed well within the required time. The actual time was dependent on the Operator's recognition of the plant status as he took in multiple simultaneous indications and if it is performed with or without SRO direction. In most cases, RO's performed a manual scram attempt without SRO direction required. Control Room crew members appeared cognizant of and in agreement with need to scram the plant. The RO Scramming the Plant generally gave a verbal update to communicate his intention to the crew. The times ranged from 5 to 16 seconds based on all observations.
(See Attachment 4.)
At the conclusion of each validation, the Validation Team should conduct a debrief and review the results of the validation by completing the check boxes as follows:
[ Assemble all forms and documentation related to time validation.
[ Determine if the recorded timing of specified events is valid. If validity of any timed event is questionable, then an adjustment with an Estimated Time with supporting information may be documented OR an IR initiated to correct the condition and the scenario should be scheduled to be performed again.
0 Valid El Invalid List IR #
Comments:
Use SRRS 2A. 112 for this record
OP-AA-1 02-106 Revision 3 Page 5 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 5 of 6 0 If additional staffing above the minimum required participated in the validation, then review if they significantly affected the task performance, and if so, then the scenario should be performed again or adjusted with an Estimated Time with supporting information documented.
El Validation identified as Invalid and IR generated per previous step El N/A Validation performed at min. staffing 0 Above min. staffing and additional staffing did not significantly affect the task performance El Above min. staffing and Estimated Time used with supporting information documented Comments:
The task was performed at normal crew complement and at reduced crew complement.
Minimum staffing was used to test the sensitivity of the required times to reduced staff.
The reduction in staff had no measurable impact on the ability of the operators to affect a manual scram. This is due to the priority of scramming the reactor and the fact that it is performed by only a single operator.
[:lIf applicable, evaluate the impact of planned procedural changes.
0 N/A, no procedure changes being evaluated El Procedure changes evaluated and comments as follows:
Comments:
None El Any portions of procedure implementation which effect time validation of operator actions that cannot be validated on the simulator should be validated separately using the Plant Walkthrough or Estimated Times methods, or combination, as appropriate.
Comments:
N/A. all validation performed in the simulator.
Use SRRS 2A.1 12 for this record
OP-AA-1 02-106 Revision 3 Page 6 of 9 ATTACHMENT 1 Operator Response Time Validation Sheet Page 6 of 6 El If any performance discrepancies observed during the Validation, then document and initiate an Issue Report (IR) to identify and review for corrective action.
0 N/A, no discrepancies
[E Discrepancies observed, list IR #
Discrepancy Comments:
E] If Time validation Expected Performance Time (ET) / Time Required (TR) is >= 0.80, then initiate an IR to review past validations for a degrading trend and review for margin improvement actions (e.g. training, procedure improvement, accessibility to equipment, etc.)
List Time validation Expected Performance Time (ET) / Time Required (TR):
0.142 minutes / 0.333 minutes = 0.43 0 N/A, ET / TR < 0.80 Dl ET / TR >= 0.80, list IR #
Comments:
None.
NInitiate Action Tracking to update the Master List of Time Critical or Sensitive Actions Expected Performance Time (ET), as applicable, when the Validation Team determines that the existing time, ratios, or other information should be updated and shall be performed when TR/ET < 3 where periodic validation is not exempt.
0l N/A, no updates to Master List necessary and TR/ET >= 3 0 Action Tracking # Action Item 01705490-21 to update Master List Comments:
None.
Validation Review Reviewed By: George Inch
- .F._(:,-ý
/,12o, Engineering %EL5LLA+t.ead Date Validation Review Approved By: Daniel Cifonelli Team Leader Date' I
Use SRRS 2A. 112 for this record
OP-AA-1 02-106 Revision 3 Page 7 of 9 ATTACHMENT 2 Sample Site Procedure Template Page 1 of 2 OPERATOR RESPONSE TIME PROGRAM AT NINE MILE POINT UNIT 2
- 1.
PURPOSE 1.1.
Nine Mile Point Unit 2 has a number of actions that are to be accomplished in a specified time. Completion of these actions assures the plant complies with the assumptions made during the analysis of design basis events, regulatory committed design events, and events with high PRA significance. OP-AA-102-106 Operator Response Time Program establishes the process, controls, and methodologies to validate and document operator Time Critical Actions (TCA) and Time Sensitive Actions (TSA). The purpose of this procedure is to document Station Name (fill in as applicable) site specific actions and required times.
- 2.
DOCUMENTATION 2.1.
The required Operator Response Times are maintained on Attachment 1. Changes to the data on Attachment 1 are approved by the Operations Director or designee.
2.2.
Validation performed lAW OP-AA-1 02-106 shall be maintained as an Operations record filed using SRRS location 2A. 112 for the Operator Response Time Program.
2.3.
Nine Mile Point Unit 2 design basis references.
- 3.
ATTACHMENTS 3.1., Nine Mile Point Unit 2 Master List of Time Critical and Time Sensitive Actions
OP-AA-1 02-106 Revision 3 Page 8 of 9 ATTACHMENT 2 Sample Site Procedure Template Page 2 of 2 Nine Mile Point Unit 2 Master List of Time Critical and Sensitive Actions (Duplicate as many pages as needed)
Unique Action Source Implementing Time Required Expected TR/ET Ratio Validation Comments Identifier Description (basis Doc. or Procedure, (TR)
Performance Method(s) by Action PRA) for the Revision, Step(s)
In Minutes Time (ET)
(Simulator, Plant Type Action and or Action(s)
In Minutes Walkthrough, (e.g. TCA1 or Source Revision Estimated Times)
TSA1)
TCA10 Place Mode MELLLA+
- 1. N2-SOP-0.333 0.142 0.43 Simulator This time Switch in 101C, Reactor was Shutdon in Project Task Scram. Rev based on Shutdown in Report Task
- 00800, an an ATWS T0902: ATWS Flowchart Event (000-0135-Immediate average of 5571-R1, DFR Action several events 0000-0069-
Control, Rev
- 01400, Flowchart Step
- 1
OP-AA-1 02-106 Revision 3 Page 9 of 9 Intentionally Blank Page C Shift Jason Sawyer SM Ben Wood SRO Matt Kostyal SRO Chris Andus RO Mike Sobolewski RO Justin Wilcox RO Doug Roik RO 9/9/2014 RO: Ucensed Reactor Operator SRO: Licensed Senior Reactor Operator SM: Shift Manager (Also, Licensed Senior Reactor Operator)
Operating Crew C Time 9/9/2014 TT w/o Bypass 5
Dual RPT 7
Pres Reg Failed 8
MSIV Closure 7
LOOP 8
AVERAGE 7
Average 8.49 Percent of Require 42.44
- Performed at Minimum Staff Compliment (1 SRO and 2 ROS)
Note: Times expressed in Seconds
OP-AA-102-106 Revision 3 Page 1 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 1 of 7
- 1. Validation Team Members:
Name Title Daniel A. Cifonelli Shift Manager Mike Smith Qualified Simulator Trainer/Operator Dwayne Lemay Qualified Simulator Trainer/Operator George Inch MELLLA+ Senior Engineer Vinod Patel MELLLA+ Senior Engineer James Kinsley MELLLA+ Lead Installation Representative NMP2 "A","C", "D" and "E" NMP2 "A","C", "D" and "E" Shifts Shifts (See Attached)
(See Attached)
Note: This is Revision 1 to this Operator Critical Action Validation. This revision did not change any conclusions, but resolved several editorial issues.
- 2. Validation Preparation:
Determine and List the following current information for the Operator Response Time Item to be validated:
Unique Identifier Action Source Implementing Time Required (TR) by Action Type Description (basis Doc. or PRA)
Procedure, Revision, In Minutes (e.g. TCA1 or TSA1) for the Action and Step(s) or Action(s)
Source Revision TCA1 1 Terminate and Project Task N2-EOP-C5, 4.50 Prevent Injection Report Task Failure to Scram, in a Dual Recirc T0902: ATWS Rev 01301, Step Pump Trip ATWS (000-0135-5571-L-9 Event R1, DFR 0000-0069-6535 Class III August 2013)
Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 2 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 2 of 7 Unique Identifier by Action Type (e.g. TCA1 or TSA1):
TCA1 1
[
Verify the current TCA/TSA source document(s)/program(s) requirement is unchanged since the last validation. Otherwise, verify the Implementing Procedure Step(s) or Action AND site specific Operating Response Time procedure are updated, as appropriate.
- Review the TCAITSA Implementing Procedure revisions since the last validation to identify potential impact on the Expected Performance Time (ET). If a potential impact exists, then ensure the validation accounts for the change.
I Review Crew human performance methodology changes to identify potential impact on the Expected Performance Time (ET). If potential impacts exist, then ensure the validation accounts for the change.
Z Review known Plant Modifications to identify potential impact on the Expected Performance Time (ET). If potential impacts exist, then ensure the validation accounts for the change.
- 3. Validation Planning:
Note: A combination of validation methods may be utilized.
Validation Method(s):
Z Simulator Scenario (e.g. Training, Out of the Box Evaluations (OBEs), other)
I-Plant Walkthrough (e.g. JPM, Training, other)
- Estimated Times (When simulator and plant walkthrough are not practical or to account for other time to improve the accuracy of the Expected Performance Time (ET).)
Simulator Scenario and revision (if used) Course Code: 2100-MELLLAS01 Supplemental Equipment Req'd (if used) N/A Determine and List the number of Operator(s) and basis: See Attachment 3 for list of Operator's names and qualifications who participated in the validations. (Normal and Minimum shift complement)
Determine and List the Starting Location(s) for the Operator(s) and basis:
Operators started in the Nine Mile Point Unit 2 Simulator (Normal location).
Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 3 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 3 of 7 Unique Identifier by Action Type (e.g. TCA1 or TSA1):
TCA1 1 Note: If a plant condition is the basis for the start of the Required Time (TR), then the establishment of the plant condition should also be the start of the Expected Performance Time (ET). Simulator, Plant Walkthrough, or Estimated Times or a combination of these methods should be used to account for the expected time for Operator recognition of the plant condition, procedure entry, direction provided for Operator response, and Operator response.
Action/indication to start time clock:
The Initiating Event (Dual Recirc Pump Trip) was taken as start time in each scenario.
In all cases, Control Rods fail to insert automatically or by Operator manual actions (ATWS).
Action/indication to stop time clock:
Terminate and Prevent Injection complete per Emergency Operating Procedures (N2-EOP-C5)
Validation Performance Plan Approved By: Daniel A Cifonelli 9/3/14 Team Leader Date Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 4 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 4 of 7
- 4. Post Validation Review:
Expected Performance Time (ET) (Total Time to perform the action): Average 193 seconds (3.217 minutes)
Note: A Sat. Time validation Expected Performance Time (ET) is <= Time Required (TR).
n 'Jat (circle one) 1Tnsat, list IR # (otherwise N/A) N/A Comments:
It was observed that Licensed Reactor Operators are well trained and proficient on the strategy to Terminate and Prevent Inlection into the reactor to lower power. In an ATWS. Operators are required to perform this action as directed by the SRO Implementing the Emergency Response Procedure (N2-EOP-C5. Failure to Scram, Step L-9). The action is directed after a failure to scram when power level is above 4% and reactor level is above 100 inches. The order that the SRO generally gives as discussed in NMP2 Transient Mitigation Guidelines (GAI-OPS-20) is "Terminate and prevent on Panel 603, when level drops below 100 inches, establish a level band of 50 to 80 inches." Control Room Panel 603 is the main Control Room Panel that includes Feedwater level control. The High Pressure Core Spray System (HPCS) generally has already been disabled when this step is reached, since HPCS is not a preferable system for iniection In an ATWS Event. The only iniection allowed during injection Termination and Prevention is Control Rod Drive injection for Rod Insertion, Standby Liquid Control for Boron Iniection and Reactor Core Isolation Cooling (RCIC). RCIC is a preferred ATWS injection system since it is pre-heated as it iniects outside the shroud: it is a low flow -600 gpm system and it assists in pressure control since it is a steam powered system. The specific action necessary to start lowering water level is to place in manual and close the Feedwater Flow Regulation Valves (2FWS-LVI0's). In all cases, the Terminate and Prevent action was timely relative to the Dual Recirc Pump Trip MELLLA+ analysis required operator time of 270 seconds. The completion times recorded ranged from 150 seconds to 232 seconds. (See Attachment 4.) The time from event initiation to termination of iniection is spent on event recognition, scram actions and scram reporting, procedure reading/place keeping, additional manual scram actions from the front panels, HPCS defeating, ARI defeating, the communication of the order to defeat MSIV isolation, communications of relevant plant parameter trends and equipment status, the communication of the terminate and Prevent order and the action to close the feedwater iniection valves.
Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 5 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 5 of 7 At the conclusion of each validation, the Validation Team should conduct a debrief and review the results of the validation by completing the check boxes as follows:
[ Assemble all forms and documentation related to time validation.
0 Determine if the recorded timing of specified events is valid. If validity of any timed event is questionable, then an adjustment with an Estimated Time with supporting information may be documented OR an IR initiated to correct the condition and the scenario should be scheduled to be performed again.
0 Valid El Invalid List IR #
Comments:
Use SRRS 2A.1 12 for this record
OP-AA-102-106 Revision 3 Page 6 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 6 of 7 Z If additional staffing above the minimum required participated in the validation, then review if they significantly affected the task performance, and if so, then the scenario should be performed again or adjusted with an Estimated Time with supporting information documented.
El Validation identified as Invalid and IR generated per previous step El N/A Validation performed at min. staffing Z Above min. staffing and additional staffing did not significantly affect the task performance El Above min. staffing and Estimated Time used with supporting information documented Comments:
The task was performed at normal crew complement and at reduced crew complement.
Minimum staffing was used to test the sensitivity of the required times to reduced staff.
The reduction in staff had no measurable impact on the ability of the operators to lower water level. This is due to the priority of lowering water and the fact that it is performed by only a single operator.
l]If applicable, evaluate the impact of planned procedural changes.
Z N/A, no procedure changes being evaluated F1 Procedure changes evaluated and comments as follows:
Comments:
None El Any portions of procedure implementation which effect time validation of operator actions that cannot be validated on the simulator should be validated separately using the Plant Walkthrough or Estimated Times methods, or combination, as appropriate.
Comments:
N/A. all validation performed In the simulator.
Use SRRS 2A.1 12 for this record
OP-AA-1 02-106 Revision 3 Page 7 of 10 ATTACHMENT 1 Operator Response Time Validation Sheet Page 7 of 7 El If any performance discrepancies observed during the Validation, then document and initiate an Issue Report (IR) to identify and review for corrective action.
0 N/A, no discrepancies El Discrepancies observed, list IR #
Discrepancy Comments:
El If Time validation Expected Performance Time (ET) / Time Required (TR) is >= 0.80, then initiate an IR to review past validations for a degrading trend and review for margin improvement actions (e.g. training, procedure improvement, accessibility to equipment, etc.)
List Time validation Expected Performance Time (ET) / Time Required (TR):
3.217 minutes /4.50 minutes = 0.715 0 N/A, ET / TR < 0.80 El ET / TR >= 0.80, list IR #
Comments:
None.
0 Initiate Action Tracking to update the Master List of Time Critical or Sensitive Actions Expected Performance Time (ET), as applicable, when the Validation Team determines that the existing time, ratios, or other information should be updated and shall be performed when TR/ET < 3 where periodic validation is not exempt.
El N/A, no updates to Master List necessary and TR/ET >= 3 0 Action Tracking # Action Item 01705490-21 to update Master List Comments:
None.
Validation Review Reviewed By: Georqe Inch
/2-Engineering MELLLA+ Lead Date Validation Review Approved By: Daniel Cifonelli/
Team LeaderD Use SRRS 2A. 112 for this record
OP-AA-102-106 Revision 3 Page 8 of 10 ATTACHMENT 2 Sample Site Procedure Template Page 1 of 2 OPERATOR RESPONSE TIME PROGRAM AT NINE MILE POINT UNIT 2
- 1.
PURPOSE 1.1.
Nine Mile Point Unit 2 has a number of actions that are to be accomplished in a specified time. Completion of these actions assures the plant complies with the assumptions made during the analysis of design basis events, regulatory committed design events, and events with high PRA significance. OP-AA-102-106 Operator Response Time Program establishes the process, controls, and methodologies to validate and document operator Time Critical Actions (TCA) and Time Sensitive Actions (TSA). The purpose of this procedure is to document Station Name (fill in as applicable) site specific actions and required times.
- 2.
DOCUMENTATION 2.1.
The required Operator Response Times are maintained on Attachment 1. Changes to the data on Attachment 1 are approved by the Operations Director or designee.
2.2.
Validation performed lAW OP-AA-1 02-106 shall be maintained as an Operations record filed using SRRS location 2A. 112 for the Operator Response Time Program.
2.3.
Nine Mile Point Unit 2 design basis references.
- 3.
ATTACHMENTS 3.1., Nine Mile Point Unit 2 Master List of Time Critical and Time Sensitive Actions
OP-AA-102-106 Revision 3 Page 9 of 10 A'TACHMENT 2 Sample Site Procedure Template Page 2 of 2 Nine Mile Point Unit 2 Master List of Time Critical and Sensitive Actions (Duplicate as many pages as needed)
Unique Action Source Implementing Time Required Expected TRIET Ratio Validation Comments Identifier Description (basis Doc. or Procedure, (TR)
Performance Method(s) by Action PRA) for the Revision, Step(s)
In Minutes Time (ET)
(Simulator, Plant Type Action and or Action(s)
In Minutes Walkthrough, (e.g. TCA1 or Source Revision Estimated Times)
TSA1)
TCA1 1 Terminate and MELLLA+
N2-EOP-C5, 4.50 3.217 0.715 Simulator This time Prevent Project Task Failure to was Injection in a Report Task Scram, Rev based on Dual Recirc T0902: ATWS 01301, Step an Pump Trip (000-0135-L-9 average of ATWS Event 5571-R1, DFR four 0000-0069-events 6535 Class III observed August 2013)
OP-AA-102-106 Revision 3 Page 10 of 10 Intentionally Blank Page C Shift Jason Sawyer SM Ben Wood SRO Matt Kostyal SRO Chris Andus RO Mike Sobolewski RO Justin Wilcox RO Doug Roik RO 9/9/2014 RO: Licensed Reactor Operator SRO: Licensed Senior Reactor Operator SM: Shift Manager (Also, Licensed Senior Reactor Operator)
Operating Crew C 9/9/2014 Dual RPT Terminate & Prevent Time 150 Average 193 Percent of Required 71
- Performed at Minimum Staff Compliment (1 SRO and 2 ROS)
Note: Times expressed in Seconds