ML17164A137

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2017 Perry Nuclear Power Plant Initial Licensed Operator Examination Scenario Review Comments
ML17164A137
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 02/03/2017
From: David Reeser
NRC/RGN-III/DRS/OLB
To:
FirstEnergy Nuclear Operating Co
Shared Package
ML16242A243 List:
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Download: ML17164A137 (9)
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2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION GENERIC 1. There is no low power scenario. The 1. (Facility) The low power scenario is lowest power initial condition is 40%. Scenario #4, which is the spare. The Candidates will have a low power scenario for their Audit Exam.

2. The original outline submittal appears to 2. (Facility) Scenario #4 (the spare) was have included 4 scenarios (3 plus a not submitted to ensure that it is not spare); the exam submittal contained 3 entered into ADAMS unless it is used.

scenarios. (NRC) Scenario #4 was validated during the on-site validation week.

3. Times are listed in the time column of 3. (Facility) Times are based on the D-2 forms. Do these entries observed times during facility represent the expected run time of the validation.

scenario? If not, what is their purpose? (NRC) Times were removed per Additionally, if these are not the run request.

times, then what are the expected scenario runtimes?

4. Applicants RO-1, RO-3, and RO-5 4. (NRC) Following validation it was (scheduled to participate in Scenarios 1 agreed that the associated crews will and 3) only have a minimum number of participate in Scenarios 1 and 2 to malfunction credit events; during the ensure adequate coverage of events.

validation of this scenario, it will be necessary to ensure that the ATC/BOP will be likely to carry out the response actions for these events.

5. Remove items from applicant 5. Comment addressed action/behavior column that are not applicable to the event (all scenarios including the spare).

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION SCENARIO 1 Event 1 1. Scenario contains an evaluator note to 1. (NRC) Will not be an NRC evaluator.

provide a cue about risk evaluation Will be a facility staff person either the being complete if the crew is hesitant driver or person acting in the role of about starting HPCS ESW. It is SM.

requested that this clarification be (Facility) Clarification added to the added to the crew turnover so as to crew turnover.

minimize evaluator/crew interaction during the scenario.

Event 2 1. Include summary of actions to be taken 1. Actions summaries have been added.

for ONI-SPI-G4 (BOP), ONI-C51 step 15 (ATC)

Event 3 1. During Event 3, APRM A failing 1. (Facility) Perry uses the term, ACTIVE upscale is listed as being a SRO TS call LCO, for a situation in which the event. The scenario guide lists TS requirements of the LCO statement 3.3.1.1 Condition H, and lists Condition are not met for the present plant G as being a Potential LCO. This mode or condition. The Action event occurs while the plant is in Mode statement is entered. Perry uses the

1. TS Table 3.3.1.1-1 appears to show term, POTENTIAL LCO (PLCO), for a that item 2.b (Flow Biased Simulated situation in which the requirements of Thermal Power - High) as being the LCO statement are not met; applicable in Mode one, and requiring however, the plant is not in the mode three channels per trip system with a or condition applicable to that LCO required action of G. It is requested statement. The Action statement is that the facility explain the basis for the not entered. A PLCO could become wording in the scenario guide or clarify an ACTIVE LCO after a mode change it accordingly. or condition change. For example, loss of a second ARPM on the same trip system. Since there are 4 APRM's per trip system, loss of one APRM would only be a PLCO.

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION Event 4 1. For event #4, the D-1 form lists TS 1. (Facility) TS 3.7.1 was a typo on D1 3.7.1 & 3.8.1. The D-2 for this event form. Changed D1 to show TS 3.5.1 indicates that the SRO may enter TS and/or TS 3.8.1. This TS call will 3.8.1 or 3.5.1. The facility needs to depend on whether the Candidate clarify what the expected technical enters TS 3.8.1 first or TS 3.5.1 first. If specification entries are for this event TS 3.8.1 is entered first, then entry and ensure that the D-1 and D-2 forms into TS 3.5.1 is not required.

are consistent.

2. Move last evaluator note to just below 2. Requested change was made.

2nd evaluator note.

Event 5 1. Contrary to evaluator note on 2nd page 1. Note revised to reflect correct of the event, RFPT trip will not cause response.

FCV runback, as the FCVs were locked up in Event 3

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION Event 6 1. In Event 6, the D-1 lists the failure of 1. (Facility) Will change D2 to agree with RCIC to auto start as being a BOP D1 form. Adding the ATC to start malfunction event, however the D-2 RCIC was a comment from validation, (page 14 of 22) lists that this may be but number of required tasks was performed by either the ATC or the overlooked. During the scram, the BOP. In Event 7, the D-1 lists the BOP should be stationed by RCIC failure of ADS SRV B21-F041E to open and HPCS, so this should not be a on ED as being a BOP malfunction problem.

credit event, however the D-2 (page 15 Regarding Event 7, during one of 22) lists that the BOP or ATC may be validation, the SRO sent the BOP to the one opening the ADS valves. The check something on a back panel and lack of consistency on who is expected the ATC opened the SRVs. If the to complete these actions is problematic BOP starts RCIC but misses opening for two reasons. First, the scenario SRVs he will still have enough guides as written do not support the malfunctions.

totals indicated on the 301-5 is either operator can perform these actions (as the D-2s indicate). Secondly, if the ATC operator were to perform the actions for both of these malfunctions it would result in applicants RO-2 and RO-4 not having an adequate number of malfunction events.

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION CRITICAL TASKS 1. Critical task #2 (page 20 of 22) lists that 1. (Facility) We typically add the Critical it is measured by at least two SRVs Task # designation to all actions being opened. In event #7 (page 15 of associated with a critical task.

22), the applicant attempts to open However, failure of the 8th SRV is a eight ADS valves and recognizes that malfunction and not necessarily part only seven are open. The expected of the Critical Task. If desired, the applicant action to then open an Critical Task designation can be additional SRV to reach the required removed from the SRO direction to total of eight is listed as being a critical open an additional SRV and the ROs task. If only two SRVs need to be action to open the additional SRV.

opened as indicated on page 20 (NRC) Critical Task designation however, why is opening the eighth removed from actions associated with valve listed as critical on page 15?

opening the additional SRV.

Quantitative Attributes

1. Malfunctions after EOP entry (1-2) 2
2. Abnormal events (2-4) 3
3. Major transients (1-2) 2
4. EOPs entered/requiring 2 substantive actions (1-2)
5. EOP contingencies requiring 2 substantive actions (0-2)
6. EOP based Critical tasks (2-3) 3

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION SCENARIO 2 Initial Conditions 1. Add that HPCS Pump is tagged OOS 1. Condition added.

for motor replacement Event 2 1. Typographical error; the expected SRO 1. (Facility) Corrected typo. Deleted actions on page 3 of 20 (second line of and.

text) says with and flow.

Event 5 (RFBP degrading pressure) 1. Event is the only ATC malfunction credit 1. Noted.

item for SRO-I-3; it will be necessary to ensure during validation that the ATC will be likely to carry out the response actions for this event.

Event 7 1. The BOP is shown as receiving credit for 1. (Facility) Split these two malfunction two separate component failures on the into two Events.

same event. NUREG-1021 ES-301 Section D.5.d states With the exception of the SRO TS evaluations, each event should only be counted once per applicant One of these two malfunctions is a manual start of an ESW pump that has failed to start, which appears to be a relatively simple action.

2. In Event 7, one of the malfunctions listed 2. (Facility) This was a typo on the D1 on ES-D-1 is "E12-F042A will not form and has been corrected.

override shut, trip RHR A pump." On the D-2 however (page 13 of 20), it appears that the BOP is observing the operation of 1E12-F042B and stopping RHR pump B however.

CRITICAL TASKS 1. Scenario 2 contains four critical tasks 1. Noted which is a deviation from the ES-301-4 attribute target valve of two to three critical tasks. The overall scenario appears to have an appropriate level of difficulty in accordance with ES-301 section D.5.d.

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION

2. Critical task #4 states that an ED must 2. (Facility) Added required actions and be performed if the required conditions additional critical tasks for ED. Also cannot be maintained. The scenario added additional Termination Criteria guide does not include the contingency for RPV Level if ED performed actions for the SRO/ATC/BOP should (NRC) During on-site validation this action become necessary. These discussions CT 4 was revised to be:

contingency actions should be included Maintain or restore and maintain in the scenario guide. RPV pressure/Suppression Pool temperature below HCL. Three contingent CTs were added:

Termination and Prevention of injection; Emergency Depressurization; and Level Restoration.

Quantitative Attributes

1. Malfunctions after EOP entry (1-2) 2
2. Abnormal events (2-4) 3
3. Major transients (1-2) 1
4. EOPs entered/requiring 1 substantive actions (1-2)
5. EOP contingencies requiring 1 substantive actions (0-2)
6. EOP based Critical tasks (2-3) 4

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION SCENARIO 3 EVENT 6 1. For Event #6, add a prompt that may be 1. (Facility) Added prompt, at end of given to the crew by someone roleplaying Event 5, to proceed with Recirc Pump the Shift Manager that can be used in the downshift if delay occurs.

event that the crew delays downshifting Recirc Pumps (i.e. expedite downshifting Recirc Pumps, etc.)

2. Completing the Recirc pump downshift 2. The intention of this scenario was to in Event #6 triggers the major transient initiate Event #2 through #5 prior to automatically following a one minute Downshifting of Recirc Pumps Event.

time delay. Events #2 - #5 are During validation this was not a malfunctions that precede the Recirc concern based on the preparation pump downshift, although the downshift needed to down shift Recirc pumps. If is directed by the crew's turnover desired, we can remove the automatic instructions. This may be undesirable timing of Event 7. The concern is, if in the event that the crew downshifts we wait too long to insert Event 7, the the pumps earlier than planned in the crew may continue with unnecessary scenario. Downshifting the Recirc plant shutdown activities.

pumps early would result in automatic (NRC) Automatic trigger replaced with initiation of the major transient and manual trigger.

potentially losing one or more malfunctions needed for ATC/BOP credit. It appears to be desirable to instead have Event #7 (major transient) be initiated on the direction of the lead evaluator.

Event 7 1. Add clarification that ONI-C51 may be 1. Requested change was made.

entered but that crew may not have time to implement before SCRAM occurs.

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION Event 8 1. Revise post scram actions to reflect 1. Changes were made.

implementation of EOP-1A

2. Revise position assignments for ATWS 2. Requested change was made.

actions (except initial response to SCRAM failure) to include either ATC/BOP CRITICAL TASKS 1. Shouldnt CT 2 include and/or injecting 1. Requested change was made.

BORON with SLC)

Quantitative Attributes

1. Malfunctions after EOP entry (1-2) 1
2. Abnormal events (2-4) 4
3. Major transients (1-2) 2
4. EOPs entered/requiring 2 substantive actions (1-2)
5. EOP contingencies requiring 1 substantive actions (0-2)
6. EOP based Critical tasks (2-3) 2
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