ML19239A260
| ML19239A260 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/23/2019 |
| From: | Joseph Demarshall FirstEnergy Nuclear Operating Co |
| To: | NRC/RGN-III/DRS/OLB |
| Demarshall J | |
| Shared Package | |
| ML17215A919 | List: |
| References | |
| Download: ML19239A260 (8) | |
Text
Perry 2019 Initial License Exam Outline Review Comments 1
Simulator Scenario Outline Comments General Comments o
NRC: There is no start-up/low power scenario (defined as criticality to 5% power).
A low power scenario should be included in the scenario set, which includes the Spare, but is not mandatory per ES-301, Section D.5.c, Page 15.
(Note: The Spare scenario was not provided with the outline submittal).
Facility: For previous exams, we have been allowed to hold back the spare scenario, so it can be used on a future exam if not needed for the current exam. By not including it with the outline and exam submittals, it is held out of ADAMS.
Previously, the spare scenario was evaluated during the Walk-through week.
Will send outline (D1) of Scenario 4. Understand this will not be put into ADAMS.
During onsite validation the week of January 7, 2019, the decision was made to designate Scenario 3 as the Spare instead of Scenario 4. Accordingly, Scenario 4 (and associated outline) will be placed in ADAMS with a 2-year delay period, and Scenario 3 will be withheld from ADAMS entirely. The outlines for Scenarios 1, 2, and 3 were initially submitted to the NRC at the 150-day point (Outline Submittal Letter dated 9/12/2018). The Scenario 4 outline (which was not included with the 150-day outline submittal) was provided to the NRC for review two weeks later on 9/28/2019. Therefore, the D-1 Scenario 4 outline will be included, along with the D-1 outlines for Scenarios 1 and 2, in the ADAMS Outline Submission Folder.
o NRC: In Scenario 1, Event 4, when the BOP operator manually aligns the RCIC suction to the suppression pool following a CST level instrument failure, RCIC will be available to start at Level 2 or manually. If the operators use RCIC and close the MSIVs to defeat the stuck open bypass valve, it appears that the critical task to start HPCS may not be valid. Provide the basis for why the manual start of HPCS to recover RPV level has been identified as a critical task. Is HPCS initiation required to restore RPV level above TAF? What will be the lowest level with RCIC feeding the RPV, given the absence of a LOCA in this scenario?
Facility: For the RCIC event, following the suction shift, if the operator attempts to either initiate RCIC or return RCIC to Standby readiness, the Trip Throttle valve will lose power while attempting to open and will not open. This renders RCIC unusable.
o NRC: Critical tasks require boundary conditions for accomplishment (e.g., time or prior to a parameter reaching a certain value). CT bases information will need to be provided for the pre-identified critical tasks in each scenario to confirm their validity.
Facility: The CT bases info is included in each scenario (D-2). Will ensure CTs are bound satisfactorily during Walk-Through week.
NRC comment sufficiently addressed.
CTs bounded during onsite validation. NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 2
o NRC: This exam only exercises Facility: Will modify Scenario 3 to o
NRC: Scenario 2, Event 5, credits both the ATC and the BOP for their response to a leak in the A RWCU Pump Room. What verifiable actions are taken by the ATC and BOP positions for this event?
Facility: The ATC should trip the RWCU pumps from H13-P680 and the BOP should isolate RWCU from the back-panels (H13-P881 & -P882).
o NRC: Scenario 2, Event 7, credits the ATC with a Reactivity Manipulation (i.e.,
lowering power with Recirc flow) necessitated by failure of the SJAE following an Earthquake of less than OBE magnitude (Event 6). If, based on plant conditions, a Manual Reactor Scram is inserted prior to performing the power reduction, the opportunity to observe the Reactivity Manipulation will be lost. At what rate will condenser vacuum be lowering after loss of the SJAE?
Facility: Condenser vacuum does not degrade rapidly on a loss of SJAEs. No other plant parameters would necessitate a manual scram for this event. Scramming prior to lowering power with Recirc flow would not be in compliance with off-normal procedures ONI-D17 and ONI-D51.
o NRC:
Facility:
o NRC:
NRC comment sufficiently addressed.
NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 3
Facility:
o NRC:
Facility:
o NRC:
Facility:
o NRC: Audit Exam Scenario 2, Event 3, Facility: Will change Audit exam to different TS call.
Will send new S2 Audit exam outline.
Verified that the TS call in Audit Exam Scenario 2 was changed. NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 4
o NRC: The Spare scenario outline was not provided with the submittal. Need this outline to confirm no overlap with the previous two NRC Exams and the Perry 2019 Audit Exam.
Facility: See first comment.
o NRC: Form ES-301-6, Competencies Checklist, specifies Scenario 2, Event 4, as a BOP competency item for the Comply With and Use Procedures category.
Scenario 2, Event 4, credits the ATC for actions associated with the downscale failure of APRM D. Additional clarification required.
Facility: The BOP has no verifiable actions to perform for this event. However, he must check back-panel indications as directed by SOI-C51(APRM). The ATC does have verifiable actions for this event.
Will remove credit for BOP on ES-301-6. Will send revised ES-301-6.
Technical Specification Event Concerns:
o NRC: The initial conditions (IC) for Scenario 2 include the failure of Containment Pressure Transmitter 1E12-N062D. No corresponding LCO information has been provided in the IC. If applicable, would this information be relevant to the Event 2 Tech Spec (TS) call associated with failure of the Containment Spray Cont. Press Transmitter?
Facility: PLCO (Potential LCO - used at Perry to identify TS equipment that is out of service but does not require entry in the Required Actions) is identified in the Initial Conditions. During the exam the PLCO is identified on the Shift Turnover Sheet and a PLCO sheet will be provided for this scenario.
This PLCO is relevant to the TS call as the Event 2 failure would put us below the minimum number of required channels.
o NRC:
Facility:
ES-301-6 appropriately revised. NRC comment sufficiently addressed.
NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 5
JPM Outline Comments General Comments o
NRC: RO Admin JPM COOP1, Determine the method for placing the instrument in trip should be listed as Previous 2 exams on the RO 301-1. JPM previously appeared on the 2015 ILE.
Facility: Will identify as such. Will send revised 301-1.
o NRC: SRO Admin JPM COOP1 and COOP2 should both be listed as Previous 2 exams on the SRO 301-1. JPMs both appeared on the 2015 ILE. This means there are now 3 SRO ADMIN JPM from the previous two exams. Two of the following three JPMs will need to be replaced:
COOP1 - Evaluate work schedules to reactivate SRO license
COOP2 - Perform SVI-R10-T5227 for offsite power availability
RC - Determine if an operator can perform an emergency evolution Facility: Will replace both Conduct of Ops JPMs. The replacement for COOP1 will be a different aspect of SRO qualifications. Originally submitted 301-1(SRO) incorrectly indicated JPM # OT-3701-ADM_028SRO. This JPM # was used in 2015 exam and tested maintaining an Active License. A modified JPM will be used for the 2019 exam and will test the aspect of reactivating an SRO License.
COOP2 will be replaced with a new JPM to review a Containment Isolation Valve Surveillance. Will send revised 301-1.
o NRC: The SRO-U Form 301-2 does not include an In-Plant JPM which evaluates an applicants ability to implement actions required during an emergency or abnormal condition, which is contrary to the guidance provided in ES-301, Section D.4.b, first paragraph, Page 14.
Facility: JPM k should have been designated Type Code E. Will send revised 301-2 o
NRC: There are an excessive number of system JPMs which should be listed as Previous 2 exams on the 301-2 forms. Two of the following JPMs should be replaced with ones not previously tested in 2015 and 2017 on the RO 301-2 and one of the following other than JPM f should be replaced on the SRO-I 301-2:
JPM a - Perform RPS manual scram functional (2017 exam)
JPM b - Initiate RCIC (2015 make-up)
JPM e - Perform manual NS4 BOP inboard isolation (2015 exam)
JPM f - Transfer station 13 KV buses (2015 exam)
JPM j - Initiate main transformer deluge (2017 retake)
RO ES-301-1 appropriately revised. NRC comment sufficiently addressed.
SRO ES-301-1 appropriately revised. NRC comment sufficiently addressed.
ES-301-2 appropriately revised. NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 6
Facility: Will retain JPMs a, b, & e and will be replacing JPMs f & j.
SRO-I will now get JPM f and not JPM a.
JPM j will become an alternate path JPM.
Will send revised 301-2 o
NRC: SRO Admin JPM COOP2, Perform SVI-R10-T5227 for offsite power availability, does not appear to meet NUREG-1021 criteria requiring SRO Administrative JPMs to be written at the SRO knowledge level (ES-301, Section D.3.c, Page 10).
Facility: This JPM is being replaced. See comment above.
ES-301-2 appropriately revised. NRC comment sufficiently addressed.
NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 7
Overall Operating Exam Comments o
NRC: Due to the limited nature of the 2017 Retake Exam (SRO-U JPMs only) and the 2015 make-up exam being an extension of the 2015 ILE exam, the NRC considers the previous two NRC exams to encompass all JPMs and scenarios given as examination material to Perry applicants in 2015 and 2017.
Facility: Will replace JPMs as necessary to meet requirements as discussed above.
o NRC: Potential overlap between Audit Exam RO Simulator JPM h, Shift AEGT Trains, and NRC Exam Scenario 2, Event 3, AEGT A Controller Failure. Note:
Audit Simulator JPM h for the SRO-I applicants is a different JPM, unrelated to the AEGT system.
Facility: Will replace audit JPM for AEGT shift and will need to update SRI-I 301-2 for Audit Exam.
Will provide new Audit Exam 301-2.
JPMs appropriately replaced. NRC comment sufficiently addressed.
RO Audit JPM for the AGET shift replaced on the Audit Exam. NRC comment sufficiently addressed.
Perry 2019 Initial License Exam Outline Review Comments 8
Written Exam Outline/Audit Exam Outline o
NRC: Potential overlap on Audit Exam SRO Admin JPM 5 (Emergency Coordinator) and NRC Written Exam Outline Question 99 (SRO-06) (See first item of Form ES-401-4 provided with the submittal).
Facility: Reviewed both Audit Exam SRO Admin JPM 5 and Written Exam Question 99 (SRO-06). Verified no overlap.
SRO-06 concerns the Shift Managers responsibilities for terminating from an E-plan event.
The Audit JPM asks what actions are required following Initial Notification with the Exclusion Area Paging system out of service and which EC duties cannot be delegated.
NRC comment sufficiently addressed.