ML15351A429

2015-12 Draft Outline Comments

ML15351A429
Person / Time
Site:	Cooper
Issue date:	12/08/2015
From:	Vincent Gaddy Operations Branch IV
To:	Nebraska Public Power District (NPPD)
References
50-298/15-012
Download: ML15351A429 (4)

Text

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Written Exam Outline 9/23/15 Comment Resolution 1 NRC Generated When updated outline submitted with Deleted line outs.

2 draft exam, no need to include lined-out, replaced K/As on the ES-401-1 Form.

When updated outline submitted, identify Updated outline with PRA insights as which questions test plant-specific applicable and attached CNS PSA Summary.

3 priorities (including PRA and IPE insights). Example: System X is number 2 risk-significant system, etc.

When systems are selected twice in a Separated rows 4 group, include them in separate columns (e.g. Q#30/31)

Administrative JPM Outline 9/23/15 Comment Resolution Number the Admin JPMs A1 through A9. Renumbered JPMs as requested. ROs are 1

A1 through A4, SROs are A5 through A9.

For MODIFIED JPMs, when draft JPM Added revision statement to modified and 2 submitted specify the modifications that new JPMs explaining differences.

were made.

All 4 RO Admin JPM topics have Replaced RO JPM Supp Pool Temp appeared on one of the previous 2 calculation with Perform Thermal Limits exams (2014 or 2012). Replace the checks for Daily Ops Log.

Suppression Pool temperature The RO RadCon JPM is appropriately calculation JPM with a different topic, catagorized as P, repeat JPM.

and justify how the RadCon and E-Plan The RO E-Plan JPM to calculate total curies 3 JPMs will be sufficiently modified from released from a leaking tank was modified to previous to allow re-use. 1 direct bank involve a different tank, which has a different from previous 2 exams allowed. volumetric conversion factor, and a different total level that was drained. Validation proved this modification was discriminatory, because the wrong conversion factor was used by at least one validator.

SRO Equipment Control JPM, Perform The SRO Jet Pump Surveillance JPM was CRS Review of Jet Pump/Recirc daily replaced with SRO Review of Pre-start 4 operability checks appeared on 2012 Checklist for Recirc Pump, which contains exam. Choose a different topic or Justify errors.

how sufficiently modified to allow re-use. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Control Room / In-Plant System JPM Outline 9/23/15 Comment Resolution Rename JPMs S1, S2, S8, and P1, Renamed JPMs as requested.

1 P2, P3.

Type Code E is for emergency or Removed E from simulator JPMs on ES-2 abnormal in-plant, and should not be 301-2 used to code simulator JPMs.

In-Plant JPMs: Safety Function 6 (JPM Replaced Safety Function 6 in-plant JPM with j) has been sampled on the last 3 Safety Function 4 new JPM, Local Isolation of exams (2015 included); replace with a RCIC Turbine.

3 Safety Function that has not been sampled in that time (SF 3, 4, or 5) to reduce predictability.

In the quantitative attributes table, On ES-301-1 and ES-301-2 forms, added the 4 include the actual values in parentheses. actual attribute count in parenthesis beside each category in the attribute tables.

Simulator Scenario Outline Comments 9/23/15 Comment Resolution The CRS should get credit for all events The ES-301-5 form reflects the SRO is 1

(I, C, N, R). getting credit for all events.

Scenario 1 Event 6: An event can be Removed individual credits for component counted as an Instrument/component failures for all events credited as major 2 malfunction or a Major but not both events. ES-301-5 has been revised (applies to all scenarios - See ES-301 accordingly.

D.5.d).

Scenario 1 Events 2 and 3: also count Per our discussion, credit is not taken for as Abnormals if significant and abnormal event for simplistic events where verifiable actions are required by an AOP entry is not required or where lack of alarm response procedure. (applies to crew response could not result in significant, 3 all scenarios, pre-Major events only. shorter-term degradation. Credit for See Appendix D) abnormal events will not be taken for scenario 1 events 2 and 3. Credit for an abnormal event is still sometimes taken where expected operator response only involves ARP actions. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Simulator Scenario Outline Comments 9/23/15 Scenario 1 Event 4: (RPS MG Set B These are separate malfunctions that require trip) with (failure of SGT A Exhaust Fan) independent responses. RPS B MG Set loss are these 2 separate malfunctions results de-energization of Group 6 logic, requiring independent responses, or are causing an isolation and SGT initiation. This they necessary to each other and requires response to energize RPS B from its 4

interrelated? alternate source and then recover from the half scram and isolation signals. The SGT A fan trip was added as a separate, recognizable malfunction to provide a TS opportunity for the SRO.

Scenario 1: Quantitative Attributes Deleted Total Malfunctions row from the Table. Total Malfunctions is calculated quantitative attribute tables that had been on an event basis, and includes only added for reference to the ES-D-1 forms.

those for which the crew takes verifiable Also ensured the Instrument/Component actions and get credit for on Form 301-5. Malfunctions count in those tables did not Same goes for Instrument/Component include malfunctions causing Major Events.

5 failures. For example, Failure of RCIC The ES-301-5 submitted were not auto isolation and RCIC isolation valve constructed from the Total Malfunction breaker trip are a single malfunction. count and were correct for the scenarios submitted, except for the Component Malfunctions credited for Major Events, as previously noted.

Scenario 2 Event 5: Loss of Offsite Listed Event 5 in scenario 2 as a separate Power with trip of RHR Pumps A and C major event.

6 should be considered a separate major event.

Scenario 3 Event 5: Major event is a In scenario 1, the ATWS results in power hydraulic block ATWS, same as below 3%. In scenario 3, the ATWS results in Scenario 1. Justify how the response is power ~20%. Scenario 3 requires a much sufficiently different to allow repetition, or different response per EOPs, specifically modify the major on one of the Level/Power control per EOP-7A. Also, scenarios. scenario 1 results in Emergency Depressurization due to secondary containment parameters per EOP-5A.

7 Scenario 2 does not require Emergency Depressurization. The ATWS malfunction in Scenario 1 serves two purposes. First, it maintains reactor pressure during the RCIC steam line break so that Emergency Depressurization will be required. Second, it makes the actions required for Emergency Depressurization different than non-ATWS EDs in scenarios 2 and 4. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Simulator Scenario Outline Comments 9/23/15 Scenario 3 Event 5: Does SLC failure to SLC failure in scenario 3 is to keep reactor initiate have independent crew response, power higher, to provide more challenge to or is it integral to the ATWS? Separate the crew to exercise Level/Power Control. No 8 event? additional component malfunction credit is taken for SLC failure, since there are no additional verifiable actions related to SLC failure.

Scenario 4: Add a normal event to start Added normal event to place the Main this scenario. Even though spare, needs Generator Voltage Regulator in automatic at 9

to stand alone in case it needs to be the beginning of the scenario.

used.

Scenario 4 Event 4: Is the intention that This was originally intended to be an RPS the ARI automatically initiates or that failure event with automatic ARI functional, 10 operators manually initiate? If requiring no additional verifiable operator automatic, is this part of the event action. As discussed, there is no value in necessary? this, so the RPS failure has been removed.

Scenario 4 Event 4: Is the Turbine Trip As discussed, removed the spurious turbine necessary or can the FW line break be trip, since it added no additional verifiable the sole major event initiator? Already operator action and because the goal is for 11 have a Turbine Trip-initiated major in operator diagnosis of the Feedwater line Scenario 3. break. Therefore, the Feedwater line break will be the initiator.

General Comments 9/29/15 Comment Resolution Schedule: We prefer to run scenarios Schedule changed to reflect scenarios will be back-to-back, rather than run 1 scenario, run back-to-back, one per day.

1 then run JPMs, then run a second scenario. More efficient turnaround time.

Schedule: Our intent is to fly out Sunday Schedule changed to reflect Monday morning 2 Nov 29 in order to start exam activities exam start.

Monday morning. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Written Exam Outline 9/23/15 Comment Resolution 1 NRC Generated When updated outline submitted with Deleted line outs.

2 draft exam, no need to include lined-out, replaced K/As on the ES-401-1 Form.

When updated outline submitted, identify Updated outline with PRA insights as which questions test plant-specific applicable and attached CNS PSA Summary.

3 priorities (including PRA and IPE insights). Example: System X is number 2 risk-significant system, etc.

When systems are selected twice in a Separated rows 4 group, include them in separate columns (e.g. Q#30/31)

Administrative JPM Outline 9/23/15 Comment Resolution Number the Admin JPMs A1 through A9. Renumbered JPMs as requested. ROs are 1

A1 through A4, SROs are A5 through A9.

For MODIFIED JPMs, when draft JPM Added revision statement to modified and 2 submitted specify the modifications that new JPMs explaining differences.

were made.

All 4 RO Admin JPM topics have Replaced RO JPM Supp Pool Temp appeared on one of the previous 2 calculation with Perform Thermal Limits exams (2014 or 2012). Replace the checks for Daily Ops Log.

Suppression Pool temperature The RO RadCon JPM is appropriately calculation JPM with a different topic, catagorized as P, repeat JPM.

and justify how the RadCon and E-Plan The RO E-Plan JPM to calculate total curies 3 JPMs will be sufficiently modified from released from a leaking tank was modified to previous to allow re-use. 1 direct bank involve a different tank, which has a different from previous 2 exams allowed. volumetric conversion factor, and a different total level that was drained. Validation proved this modification was discriminatory, because the wrong conversion factor was used by at least one validator.

SRO Equipment Control JPM, Perform The SRO Jet Pump Surveillance JPM was CRS Review of Jet Pump/Recirc daily replaced with SRO Review of Pre-start 4 operability checks appeared on 2012 Checklist for Recirc Pump, which contains exam. Choose a different topic or Justify errors.

how sufficiently modified to allow re-use. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Control Room / In-Plant System JPM Outline 9/23/15 Comment Resolution Rename JPMs S1, S2, S8, and P1, Renamed JPMs as requested.

1 P2, P3.

Type Code E is for emergency or Removed E from simulator JPMs on ES-2 abnormal in-plant, and should not be 301-2 used to code simulator JPMs.

In-Plant JPMs: Safety Function 6 (JPM Replaced Safety Function 6 in-plant JPM with j) has been sampled on the last 3 Safety Function 4 new JPM, Local Isolation of exams (2015 included); replace with a RCIC Turbine.

3 Safety Function that has not been sampled in that time (SF 3, 4, or 5) to reduce predictability.

In the quantitative attributes table, On ES-301-1 and ES-301-2 forms, added the 4 include the actual values in parentheses. actual attribute count in parenthesis beside each category in the attribute tables.

Simulator Scenario Outline Comments 9/23/15 Comment Resolution The CRS should get credit for all events The ES-301-5 form reflects the SRO is 1

(I, C, N, R). getting credit for all events.

Scenario 1 Event 6: An event can be Removed individual credits for component counted as an Instrument/component failures for all events credited as major 2 malfunction or a Major but not both events. ES-301-5 has been revised (applies to all scenarios - See ES-301 accordingly.

D.5.d).

Scenario 1 Events 2 and 3: also count Per our discussion, credit is not taken for as Abnormals if significant and abnormal event for simplistic events where verifiable actions are required by an AOP entry is not required or where lack of alarm response procedure. (applies to crew response could not result in significant, 3 all scenarios, pre-Major events only. shorter-term degradation. Credit for See Appendix D) abnormal events will not be taken for scenario 1 events 2 and 3. Credit for an abnormal event is still sometimes taken where expected operator response only involves ARP actions. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Simulator Scenario Outline Comments 9/23/15 Scenario 1 Event 4: (RPS MG Set B These are separate malfunctions that require trip) with (failure of SGT A Exhaust Fan) independent responses. RPS B MG Set loss are these 2 separate malfunctions results de-energization of Group 6 logic, requiring independent responses, or are causing an isolation and SGT initiation. This they necessary to each other and requires response to energize RPS B from its 4

interrelated? alternate source and then recover from the half scram and isolation signals. The SGT A fan trip was added as a separate, recognizable malfunction to provide a TS opportunity for the SRO.

Scenario 1: Quantitative Attributes Deleted Total Malfunctions row from the Table. Total Malfunctions is calculated quantitative attribute tables that had been on an event basis, and includes only added for reference to the ES-D-1 forms.

those for which the crew takes verifiable Also ensured the Instrument/Component actions and get credit for on Form 301-5. Malfunctions count in those tables did not Same goes for Instrument/Component include malfunctions causing Major Events.

5 failures. For example, Failure of RCIC The ES-301-5 submitted were not auto isolation and RCIC isolation valve constructed from the Total Malfunction breaker trip are a single malfunction. count and were correct for the scenarios submitted, except for the Component Malfunctions credited for Major Events, as previously noted.

Scenario 2 Event 5: Loss of Offsite Listed Event 5 in scenario 2 as a separate Power with trip of RHR Pumps A and C major event.

6 should be considered a separate major event.

Scenario 3 Event 5: Major event is a In scenario 1, the ATWS results in power hydraulic block ATWS, same as below 3%. In scenario 3, the ATWS results in Scenario 1. Justify how the response is power ~20%. Scenario 3 requires a much sufficiently different to allow repetition, or different response per EOPs, specifically modify the major on one of the Level/Power control per EOP-7A. Also, scenarios. scenario 1 results in Emergency Depressurization due to secondary containment parameters per EOP-5A.

7 Scenario 2 does not require Emergency Depressurization. The ATWS malfunction in Scenario 1 serves two purposes. First, it maintains reactor pressure during the RCIC steam line break so that Emergency Depressurization will be required. Second, it makes the actions required for Emergency Depressurization different than non-ATWS EDs in scenarios 2 and 4. OBDI 202 - IOLE Process Rev 1

DRAFT OUTLINE COMMENTS Facility: CNS First Exam Date: 11/30/15 Simulator Scenario Outline Comments 9/23/15 Scenario 3 Event 5: Does SLC failure to SLC failure in scenario 3 is to keep reactor initiate have independent crew response, power higher, to provide more challenge to or is it integral to the ATWS? Separate the crew to exercise Level/Power Control. No 8 event? additional component malfunction credit is taken for SLC failure, since there are no additional verifiable actions related to SLC failure.

Scenario 4: Add a normal event to start Added normal event to place the Main this scenario. Even though spare, needs Generator Voltage Regulator in automatic at 9

to stand alone in case it needs to be the beginning of the scenario.

used.

Scenario 4 Event 4: Is the intention that This was originally intended to be an RPS the ARI automatically initiates or that failure event with automatic ARI functional, 10 operators manually initiate? If requiring no additional verifiable operator automatic, is this part of the event action. As discussed, there is no value in necessary? this, so the RPS failure has been removed.

Scenario 4 Event 4: Is the Turbine Trip As discussed, removed the spurious turbine necessary or can the FW line break be trip, since it added no additional verifiable the sole major event initiator? Already operator action and because the goal is for 11 have a Turbine Trip-initiated major in operator diagnosis of the Feedwater line Scenario 3. break. Therefore, the Feedwater line break will be the initiator.

General Comments 9/29/15 Comment Resolution Schedule: We prefer to run scenarios Schedule changed to reflect scenarios will be back-to-back, rather than run 1 scenario, run back-to-back, one per day.

1 then run JPMs, then run a second scenario. More efficient turnaround time.

Schedule: Our intent is to fly out Sunday Schedule changed to reflect Monday morning 2 Nov 29 in order to start exam activities exam start.

Monday morning. OBDI 202 - IOLE Process Rev 1