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:
References
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 lowest power initial condition is 40%.
1. (Facility) The low power scenario is 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 have included 4 scenarios (3 plus a spare); the exam submittal contained 3 scenarios.
2. (Facility) Scenario #4 (the spare) was not submitted to ensure that it is not entered into ADAMS unless it is used.

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

3. Times are listed in the time column of the D-2 forms. Do these entries represent the expected run time of the scenario? If not, what is their purpose?

Additionally, if these are not the run times, then what are the expected scenario runtimes?

3. (Facility) Times are based on observed times during facility validation.

(NRC) Times were removed per request.

4. Applicants RO-1, RO-3, and RO-5 (scheduled to participate in Scenarios 1 and 3) only have a minimum number of malfunction credit events; during the 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.
4. (NRC) Following validation it was agreed that the associated crews will participate in Scenarios 1 and 2 to ensure adequate coverage of events.
5. Remove items from applicant action/behavior column that are not applicable to the event (all scenarios including the spare).
5. Comment addressed

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 provide a cue about risk evaluation being complete if the crew is hesitant about starting HPCS ESW. It is requested that this clarification be added to the crew turnover so as to minimize evaluator/crew interaction during the scenario.
1. (NRC) Will not be an NRC evaluator.

Will be a facility staff person either the driver or person acting in the role of SM.

(Facility) Clarification added to the crew turnover.

Event 2

1. Include summary of actions to be taken for ONI-SPI-G4 (BOP), ONI-C51 step 15 (ATC)
1. Actions summaries have been added.

Event 3

1. During Event 3, APRM A failing upscale is listed as being a SRO TS call event. The scenario guide lists TS 3.3.1.1 Condition H, and lists Condition G as being a Potential LCO. This event occurs while the plant is in Mode
1. TS Table 3.3.1.1-1 appears to show that item 2.b (Flow Biased Simulated Thermal Power - High) as being applicable in Mode one, and requiring three channels per trip system with a required action of G. It is requested that the facility explain the basis for the wording in the scenario guide or clarify it accordingly.
1. (Facility) Perry uses the term, ACTIVE LCO, for a situation in which the requirements of the LCO statement are not met for the present plant mode or condition. The Action statement is entered. Perry uses the term, POTENTIAL LCO (PLCO), for a situation in which the requirements of the LCO statement are not met; however, the plant is not in the mode or condition applicable to that LCO statement. The Action statement is not entered. A PLCO could become an ACTIVE LCO after a mode change 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 3.7.1 & 3.8.1. The D-2 for this event indicates that the SRO may enter TS 3.8.1 or 3.5.1. The facility needs to clarify what the expected technical specification entries are for this event and ensure that the D-1 and D-2 forms are consistent.
1. (Facility) TS 3.7.1 was a typo on D1 form. Changed D1 to show TS 3.5.1 and/or TS 3.8.1. This TS call will depend on whether the Candidate enters TS 3.8.1 first or TS 3.5.1 first. If TS 3.8.1 is entered first, then entry into TS 3.5.1 is not required.
2. Move last evaluator note to just below 2nd evaluator note.
2. Requested change was made.

Event 5

1. Contrary to evaluator note on 2nd page of the event, RFPT trip will not cause FCV runback, as the FCVs were locked up in Event 3
1. Note revised to reflect correct response.

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 RCIC to auto start as being a BOP malfunction event, however the D-2 (page 14 of 22) lists that this may be performed by either the ATC or the BOP. In Event 7, the D-1 lists the failure of ADS SRV B21-F041E to open on ED as being a BOP malfunction credit event, however the D-2 (page 15 of 22) lists that the BOP or ATC may be the one opening the ADS valves. The lack of consistency on who is expected to complete these actions is problematic for two reasons. First, the scenario guides as written do not support the 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.
1. (Facility) Will change D2 to agree with D1 form. Adding the ATC to start RCIC was a comment from validation, but number of required tasks was overlooked. During the scram, the BOP should be stationed by RCIC and HPCS, so this should not be a problem.

Regarding Event 7, during one validation, the SRO sent the BOP to check something on a back panel and the ATC opened the SRVs. If the BOP starts RCIC but misses opening SRVs he will still have enough malfunctions.

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 it is measured by at least two SRVs being opened. In event #7 (page 15 of 22), the applicant attempts to open eight ADS valves and recognizes that only seven are open. The expected applicant action to then open an additional SRV to reach the required total of eight is listed as being a critical task. If only two SRVs need to be opened as indicated on page 20 however, why is opening the eighth valve listed as critical on page 15?
1. (Facility) We typically add the Critical Task # designation to all actions associated with a critical task.

However, failure of the 8th SRV is a malfunction and not necessarily part of the Critical Task. If desired, the Critical Task designation can be removed from the SRO direction to open an additional SRV and the ROs action to open the additional SRV.

(NRC) Critical Task designation removed from actions associated with 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 substantive actions (1-2) 2
5. EOP contingencies requiring substantive actions (0-2) 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 for motor replacement
1. Condition added.

Event 2

1. Typographical error; the expected SRO actions on page 3 of 20 (second line of text) says with and flow.
1. (Facility) Corrected typo. Deleted and.

Event 5 (RFBP degrading pressure)

1. Event is the only ATC malfunction credit 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.
1. Noted.

Event 7

1. The BOP is shown as receiving credit for two separate component failures on the 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.
1. (Facility) Split these two malfunction into two Events.
2. In Event 7, one of the malfunctions listed on ES-D-1 is "E12-F042A will not 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.
2. (Facility) This was a typo on the D1 form and has been corrected.

CRITICAL TASKS

1. Scenario 2 contains four critical tasks 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.
1. Noted

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

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

Maintain or restore and maintain 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 substantive actions (1-2) 1
5. EOP contingencies requiring substantive actions (0-2) 1
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 given to the crew by someone roleplaying the Shift Manager that can be used in the event that the crew delays downshifting Recirc Pumps (i.e. expedite downshifting Recirc Pumps, etc.)
1. (Facility) Added prompt, at end of Event 5, to proceed with Recirc Pump downshift if delay occurs.
2. Completing the Recirc pump downshift in Event #6 triggers the major transient automatically following a one minute time delay. Events #2 - #5 are malfunctions that precede the Recirc pump downshift, although the downshift is directed by the crew's turnover instructions. This may be undesirable in the event that the crew downshifts the pumps earlier than planned in the scenario. Downshifting the Recirc pumps early would result in automatic initiation of the major transient and 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.
2. The intention of this scenario was to initiate Event #2 through #5 prior to Downshifting of Recirc Pumps Event.

During validation this was not a concern based on the preparation needed to down shift Recirc pumps. If desired, we can remove the automatic timing of Event 7. The concern is, if we wait too long to insert Event 7, the crew may continue with unnecessary plant shutdown activities.

(NRC) Automatic trigger replaced with manual trigger.

Event 7

1. Add clarification that ONI-C51 may be entered but that crew may not have time to implement before SCRAM occurs.
1. Requested change was made.

2017 PERRY NUCLEAR PLANT INITIAL LICENSE EXAMINATION SCENARIO REVIEW COMMENTS SCENARIO/EVENT COMMENT RESPONSE/RESOLUTION Event 8

1. Revise post scram actions to reflect implementation of EOP-1A
1. Changes were made.
2. Revise position assignments for ATWS actions (except initial response to SCRAM failure) to include either ATC/BOP
2. Requested change was made.

CRITICAL TASKS

1. Shouldnt CT 2 include and/or injecting BORON with SLC)
1. Requested change was made.

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 substantive actions (1-2) 2
5. EOP contingencies requiring substantive actions (0-2) 1
6. EOP based Critical tasks (2-3) 2
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