ML15061A154
| ML15061A154 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/27/2015 |
| From: | Wideman S Wolf Creek |
| To: | Lyon F Plant Licensing Branch IV |
| References | |
| TAC MF3112 | |
| Download: ML15061A154 (6) | |
Text
NRR-PMDAPEm Resource From: Wideman Steve G [stwidem@WCNOC.com]
Sent: Friday, February 27, 2015 1:09 PM To: Lyon, Fred Cc: Muilenburg William T; Suter Jeffrey F; Fox Brian R
Subject:
RE: Fire Protection Program - Alt SD Capability Clarification Questions (TAC No. MF3112)
Attachments: image001.jpg; image002.jpg Fred - provide below (in red) are responses to the clarification questions associated with the January 21, 2015 (letter ET 15-0001) response to the December 4, 2014 request for additional information.
Steve Wideman Principal Licensing Engineer Wolf Creek Nuclear Operating Corp 620-364-4037 stwidem@wcnoc.com The information contained in this electronic correspondence is informally submitted to the NRC and is not considered as docketed correspondence by Wolf Creek Nuclear Operating Corporation (WCNOC). Should the NRC wish to assign a docket number to this correspondence, WCNOC requests it be contacted to obtain concurrence.
From: Lyon, Fred [1]
Sent: Friday, February 06, 2015 9:08 AM To: Wideman Steve G Cc: Muilenburg William T
Subject:
Fire Protection Program - Alt SD Capability Clarification Questions (TAC No. MF3112)
The AHPB reviewer asked for clarification of your Jan 21, 2015, RAI response regarding the following:
- 1. In the submittal on page 13 of 14 under the title of Procedures and Training, the licensee does not address training. Has training been provided on the changes to the program, including what to do if pressurizer level goes off-scale during a control room fire?
Response: Training has been conducted on Procedure OFN RP-017, Control Room Evacuation, as part of the licensed operator and non-licensed operator requalification programs. The licensed operator and non-licensed operator requalification programs are governed by procedure AP 30B-001, Licensed Operator Requalification Training Program, and procedure AP 30B-002, Non-Licensed Operator (NLO) Requalification Training Program. Step A.7 of OFN RP-017 specifies steps taken to maintain stable plant conditions and includes maintaining pressurizer level between 25% and 75%. In the Response Not Obtained column of the procedure (i.e., if pressure level is not within the specified band) the operator performing the turbine building actions is directed by the senior reactor operator at the Auxiliary Shutdown Panel to control pressurizer level locally using the boron injection tank outlet valve. As such, it would be expected that action is taken to maintain pressurizer level and this same action would apply if it were to go off-scale during a control room fire.
- 2. On page 3 of 14, the licensee stated that additional operators were timed on action C2, Isolate Pressurizer Pilot Operated Relief Valves (PORVs) and completed the action in 1.95 minutes (63 second margin), 2.62 minutes (23 second margin) and 1.77 minutes (74 second margin). Please describe the whole sample of operators, both the original sample and this new additional set of operators; that is, describe the total 1
number of operators used in the time-testing, their representativeness of the number of crews on site, ages, experience, their representativeness of the population that is expected to do this task. This particular task has very little time margin, that could be easily eaten up by something as simple as a trip and fall accident, so well be looking for a solid validation process that includes a representative sample or a complete sample of the operators who may be called upon to isolate the Pressurizer PORVs.
Response: As discussed in the response to question FP-RAI-01 in Reference 1, WCNOC determined that demonstration of feasibility and reliability of operator manual actions per NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire, is not applicable to Appendix R,Section III.G.3 areas. WCNOC performs periodic operator timing of the time sensitive manual actions per procedure AI 21-017, Timed Fire Protection Actions Validation, to ensure operators continue to meet the required response times documented in drawing E-1F9915 and evaluated in Evaluation SA-08-006. Procedure AI 21-017 was based on the guidance in WCAP-16755-NP, Operator Time Critical Action Program Standard.
WCAP-16755-NP was developed by the Pressurized Water Reactor Owners Group to provide standardized guidance for operator time critical action programs. While this guidance was developed for operator time critical actions associated with design basis accidents, WCNOC believe that the guidance was appropriate for fire protection time sensitive actions for a fire that results in evacuation of the control room.
Procedure OFN RP-017, Step C.2 is a reactor operator action that includes isolating the pressurizer pilot operated valves (PORVs). The original validation performed in accordance with procedure AI 21-017 was based on a single performance. As discussed in the response to question SRXB-RAI-1 in Reference 1, procedure AI 21-017 specifies that if the time sensitive action is performed between 80% and 100% of the required time, consideration is given to performing additional validations using other performers. An additional three reactor operators performed additional validations. At WCGS there are six operating crews that includes 15 reactor operators (
Reference:
Special Order 1, Revision 230). The total population of reactor operators is 20. The average age of reactor operator is approximately 46 years old. The average experience of the reactor operator is approximately 9 years. Table 1 below provides data associated with the validations performed for procedure OFN RP-017, Step C.2. The experience row in Table 1 below is the years the individual has held a reactor operator license.
Table 1 Reactor Operator* Reactor Operator Reactor Operator Reactor Operator (Demonstrated) 1 2 3 Age 55 51 36 64 Experience 20 7 1.5 20 Demonstrated 2.83 1.95 2.62 1.77 Time
- Individual is assigned to the Clearance Order Group.
10 CFR 55.21, Medical examination, requires an applicant for a license have a medical examination by a physician every two years. This regulation further requires the physician to determine that the applicant or licensee meets the requirements of 10 CFR 55.33(a)(1). 10 CFR 55.33(a)(1) requires that the applicants medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. Regulatory Guide 1.134, Revision 2, Medical Evaluation of Nuclear Power Plant Personnel Requiring Operator Licenses, describes a method acceptable to the NRC staff for providing the information needed by the staff for its evaluation of the medical qualifications of applicants for initial or renewal operator or senior operator licenses. USAR Appendix 3A, Conformance to NRC Regulatory Guides, indicates that WCNOC conforms to Regulatory Guide 1.134 and Section C endorses ANSI/ANS 3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants.: Section 5.2.1 of the ANSI/ANS standard indicates that the examinee shall demonstrate stability and capacity for all of the following: (3) Physique, stamina, motor power, range of motion, and dexterity to allow ready access to and safe execution of assigned duties. Procedure AI 13G-003, Medical Examinations for 2
Licensed Personnel, specifies that licensed personnel are required to successfully complete a physical examination annually and these examinations must be completed within a period not to exceed two years. As part of the physical examination, an Astrand Cycling Ergometer exam is administered to assess physical stamina.
As such, the medical examination process required by regulation and conservatively administered by WCNOC reinforces the reactor operators ability to perform the assigned time sensitive action.
Based upon the above information, WCNOC has demonstrated that Step C. 1 of procedure OFN RP-017 can feasibly be performed on or before the 3 minute time limit during timed evolutions.
3
Hearing Identifier: NRR_PMDA Email Number: 1909 Mail Envelope Properties (3258E47FA4A47747BFA39985EE2B35413795154F)
Subject:
RE: Fire Protection Program - Alt SD Capability Clarification Questions (TAC No.
MF3112)
Sent Date: 2/27/2015 1:09:01 PM Received Date: 2/27/2015 1:09:31 PM From: Wideman Steve G Created By: stwidem@WCNOC.com Recipients:
"Muilenburg William T" <wimuile@WCNOC.com>
Tracking Status: None "Suter Jeffrey F" <jesuter@WCNOC.com>
Tracking Status: None "Fox Brian R" <brfox1@WCNOC.com>
Tracking Status: None "Lyon, Fred" <Fred.Lyon@nrc.gov>
Tracking Status: None Post Office: WC-E2010.wcnoc.com Files Size Date & Time MESSAGE 8062 2/27/2015 1:09:31 PM image001.jpg 784 image002.jpg 805 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
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