ML20241A242
| ML20241A242 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/04/2020 |
| From: | Greg Werner Operations Branch IV |
| To: | Nebraska Public Power District (NPPD) |
| References | |
| Download: ML20241A242 (7) | |
Text
PROPOSED OUTLINE COMMENTS Facility: CNS First Exam Date: Apr 27, 2020 Written Exam Outline Comment Resolution 1 NRC Generated None.
2 Replacement K/As approved by NRC None.
First replaced K/A 259001 A1.06 with K/A Replace RO Question 31:
256000 A1.10 as noted in this comment, but K/A 259001 (SF2 FWS) Feedwater, could not write a discriminatory question at Ability to predict and/or monitor changes the RO level.
in parameters associated with operating the REACTOR FEEDWATER SYSTEM Later, replaced K/A 256000 A1.10 with K/A controls including: 256000 A1.07, System lineup, provided by A1.06 Feedwater heater level NRC.
with the following:
K/A 256000 (SF2 CDS) Condensate, Ability to (a) predict the impacts of the following on the REACTOR CONDENSATE SYSTEM; and (b) 3 based on those predictions, use procedures to correct, control, or mitigate the consequences of those abnormal conditions or operations:
A2.02 Valve closures.
Ability to predict and/or monitor changes in parameters associated with operating the REACTOR CONDENSATE SYSTEM controls including:
A1.10 Condenser vacuum Reason is that same system cannot be sampled on both RO and SRO exams until all systems in a tier/group have been sampled between the two exams.
Administrative JPM Outline Comment Resolution 1 A1 says modified by type code is N Changed type code to M for A1 2 A3 is also type code D Added type code D for A3 3 Rename SA5-9 as A5- A9. Renamed SA5-9 as A5- A9 4 A5 is also type code D Added type code D for A5 OBDI 202 - IOLE Process Rev 3
A8 on its face it appears to be a Discussed with NRC. The first part of this combination of the 2018 and 2017 A8 JPM is to determine the emergency JPM tasks ensure pertinent exposure limit. The task is to manually close conditions are changed so that this isnt a RCIC steam isolation valve. The exposure just a combination of two previously- limit for this task is 10Rem. In contrast, the used JPMs, and that the spirit of non- task associated with 2018 JPM SA8 was to repetition is met. locally start RCIC and had an exposure limit of 25 Rem. The second portion of this task is to determine whether authorization of KI is required for the task. For the 2020 JPM, KI should NOT be authorized for the operator 5 performing the task based on plant conditions. In contrast, 2017 JPM A8 required determining KI should be authorized for EMTs involved in the related task.
2020 JPM A8 is designated as new because it was created from the ground up without reference to any bank JPM and involves a new combination of task requirements related to completely different task conditions and expected results than used in 2017 JPM A8 or 2018 JPM SA8.
Control Room / In-Plant System JPM Outline Comment Resolution 1 Add S type code to all sim JPMs Added S type code to all sim JPMs Combine ES-301-2s into one form (NRC Combined the three ES-301-2 forms into 2 will provide) one, specifying which are performed by RO, SRO-I, and SRO-U For alt path JPMs, add a brief 1 Added brief statement describing the 3 sentence description of what the faulted alternate path for each alternate path JPM condition is.
4 Credit S2 as D as well, on 301-2 Added type code D for S2 Simulator Scenario Outline Comments Comment Resolution SCEN1 - Is event 5 considered an Discussed with NRC. Event 5 is not an ATWS? Should the reactor have tripped ATWS. The stability solution used at CNS automatically but failed to? does not include an automatic scram based If not an ATWS, Id like to credit this as on P/F Stability Exclusion Region Entry nor 1
a Component malfunction instead of a flux oscillation signature. As requested in Major, esp since it is immediately comment #3, the automatic scram based on followed by another Major. APRM flux high is defeated so that operator action is required to scram. OBDI 202 - IOLE Process Rev 3
This was changed from a Major event to a malfunction per CE request.
SCEN1 - Event 5, does RRP B seize on The shaft binding malfunction causes a shaft binding and then trip? Not clear. binding of RR Pump B rotor. Motor current, pump vibration, and motor vibration increase, Also: resulting in annunciation on Panel 9-4. RR This appears to be similar or identical to Pump B will trip ~20 seconds after Trigger 5 is 2018 Scenario 4 event 6 Major event. activated.
NUREG 1021 Rev 11 APP D states: if any major event is repeated from either This is considered to be a different event of the previous two NRC initial licensing from that used in 2018 Scenario 4 event 6, operating tests, the examination author because in that case RR Pump A should change the major event, the ICs, experienced shaft binding, and in this or subsequent malfunctions (or a scenario RR Pump B will experience shaft combination) to alter the course of binding. Completely different annunciators action (within the emergency and pump indications specific to RR Pump B procedures) for the given scenario(s). are involved. Additionally, the course of The NRC expect that all major events action within the EOPs for this scenario is would be broadly sampled over the different from that in 2018 Scenario 4. In course of several operating tests and 2018 Scenario 4, normal scram response that no major event will routinely be ensued, complicated by need to manually omitted without justification. If a facility control RFPs due to a 480V Buss loss, until, 2
licensee encounters difficulty meeting after a 14 minute delay, a RCIC steam leak these requirements (e.g., because of into secondary containment was inserted, large class sizes requiring the and EOP-5A became the driver. No ECCS generation of more scenarios than initiation signal was received in that scenario.
normal), it should coordinate with the NRC chief examiner to meet the intent In this 2020 scenario, a drywell steam leak of this section to the extent possible. occurs 3 minutes after the scram, resulting in an ECCS initiation and multiple Group Justify how this major event is different isolations and the need to verify enough from 2018 THI event to satisfy initiations/isolations and override ECCS above guidance, or replace. systems not required for injection IAW EOP-1A. The effect of the steam leak on DW pressure results in EOP-3A being the driver for the scenario.
In addition, this was changed to a component malfunction per CE request in comment #1. Discussed with NRC, and now there is no concern related to a repeat major event from 2018 Scenario 4 event 6.
SCEN 1 CT#1 - I like the 25% peak-to- Discussed with NRC. The automatic scram peak bounding criteria, but I dont want based on APRM flux high is defeated so that the plant to be able to be put in a safe operator action is required to scram. The condition by an automatic scram on overrides used to defeat the automatic scram 3 APRM hi power block the APRM high are not counted as an additional malfunction.
flux SCRAM such that the crew HAS to manually trip the reactor to put plant in safe condition. Dont count the blocked APRM scram as a separate event OBDI 202 - IOLE Process Rev 3
because were not expecting a competent crew to get to the point where APRM auto scram is challenged, its more of an initial condition for the THI event.
SCEN 1 - Combine events 9 and 10, Discussed with NRC. Combined events 9 RHR pumps B and D trip, into one and 10 and eliminated RHR Pump D failure 4
event, since they are both just used as to auto start.
drivers for Emx Depressurization.
SCEN1 Event 7 - what action is Discussed with NRC. The Containment required by the crew in response to this Spray cooling valve permissive switch will fail malfunction, that they would not have to for the first RHR loop attempted to be placed take if this malfunction did not occur? in Torus spray. The summary was written 5
Trying to determine if it should be assuming RHR A will be attempted first. This creditable as a separate I/C bean, or if override will require the crew to transition to its more of a setup condition for the the opposite RHR loop to establish E.D. Containment Spray.
SCEN 1 - good job putting together and Will try to use this effort for OE as model for 6
documenting OE for this scenario. future exams.
SCEN 1 - Target Quantitative Attribute No action required.
for Malfunctions After EOP Entry is 1-2.
Scenario 1 has 3. ES-301 states, The quantitative attribute target ranges that are specified on the form are not absolute limitations; some scenarios may be an excellent evaluation tool but may not fit within the ranges. A scenario that does not fit into these ranges shall be evaluated to ensure that the level of difficulty is appropriate. On evaluation, this scenario has an appropriately 7
normal level of difficulty, the 1st two post-EOP malfunctions are straightforward, and the 3rd post-EOP malfunction is necessary to facilitate transition to an EOP contingency procedure, at least one of which is required per scenario set. In the opinion of the Chief Examiner, the deviation from target quantitative attributes is justified and the scenario is of an appropriate level of difficulty.
SCEN 2 - Event 8 - what is the Discussed with NRC. The Rx Mode Switch significance of Mode Switch failing in failing in RUN uses an override to simulate RUN position? Writeup sounds like the switch being in RUN, with respect to scram in event 6 was successful, except electrical contacts, regardless of physical 8
for SDV vent/drain valves failure to switch position. This scenario uses a low close. Is this an ATWS? decay heat IC. When the reactor is scrammed, RPV pressure will decay below the Group 1 isolation setpoint on RPV OBDI 202 - IOLE Process Rev 3
Is this supposed to be the Mode Switch Pressure Low within < 1 minute. With the Rx physically failing in RUN, or the RUN Mode Switch failed in RUN, a Group 1 electrical contact remaining energized? (MSIV) isolation will occur. This is necessary to prevent reactor pressure from depleting through paths to the condenser in order to maintain enough driving head for the HPCI steam leak to exceed Max Safe temperatures in more than one area in secondary containment. This will force the crew to ultimately transition to other injection systems than RFPs and prevents resetting the scram. The crew will have to control CRD flow to control reactor level below SCEN 2 - Target Quantitative Attribute No action required.
for Malfunctions After EOP Entry is 1-2.
Scenario 2 has 4. ES-301 states, The quantitative attribute target ranges that are specified on the form are not absolute limitations; some scenarios may be an excellent evaluation tool but may not fit within the ranges. A scenario that does not fit into these ranges shall be evaluated to ensure that the level of 9 difficulty is appropriate. On evaluation, this scenario has an appropriately normal level of difficulty, the post-EOP malfunctions are straightforward and related, necessary to facilitate transition to an EOP contingency procedure. In the opinion of the Chief Examiner, the deviation from target quantitative attributes is justified and the scenario is of an appropriate level of difficulty.
Scenario 3 event 5 hydraulic block The 2018 ATWS was the low power ATWS: Explain how this is different scenario. Power was <3% following RR from Hydraulic ATWS used on 2018 Pump trip, so reactor water level was not scenario 1 and 2017 scenario 1, to required to be lowered. SLC Pump A failed satisfy guidance: NUREG 1021 Rev 11 to start, but was of less consequence since APP D: if any major event is repeated power was low. For 2020, SLC B relief valve from either of the previous two NRC will fail open, which will be of significantly initial licensing operating tests, the greater consequence, since power is much examination author should change the higher than in 2018.
11 major event, the ICs, or subsequent malfunctions (or a combination) to alter The 2017 ATWS was ~40% hydraulic block the course of action (within the malfunction severity, resulting in ~ 35%
emergency procedures) for the given power after RR Pumps were tripped. In that scenario(s). The NRC expect that all scenario, Bypass valves failed closed; major events would be broadly sampled however SLC was not impaired and some over the course of several operating steam continued to go to the main condenser tests and that no major event will via BOP steam loads. RFPs remained routinely be omitted without justification. available to control reactor water level. SLC OBDI 202 - IOLE Process Rev 3
If a facility licensee encounters difficulty reduced power to <3%within ~3 minutes.
meeting these requirements (e.g., RR Pumps automatically tripped on ATWS-because of large class sizes requiring RPT in 2017, but in 2020, RR Pump B will the generation of more scenarios than fail to trip automatically and must be tripped normal), it should coordinate with the manually.
NRC chief examiner to meet the intent of this section to the extent possible. In this 2020 scenario, ATWS severity and initial resulting power level is comparable to How is the response to the hydraulic that of the 2017 scenario. But in contrast, ATWS itself different from previous 2 the 2020 scenario will involve a complete exams? loss of condenser vacuum, resulting in loss of RFPs and MSIV closure. The condenser will be lost as a heat sink, and all steam will divert to the Suppression Pool. HPCI and RCIC will be required for level control due to loss of RFPs. SLC will be impaired, so power will remain higher significantly longer.
Manual control rod insertion and lowering reactor water level, which was not required to be executed in 2018, will necessitate higher priorities than in 2017 in order to limit the amount of energy the Suppression Pool must absorb. Execution of the legs of the EOPs will require a different prioritization than was required, necessarily, in 2017. The CRS will prioritize BOP actions differently than was necessary in 2017 due to loss of RFPs and MSIV closure.
Discussed with NRC, difference is acceptable.
SCEN 3 - Target Quantitative Attribute No action required.
for Malfunctions After EOP Entry is 1-2.
Scenario 3 has 3. On evaluation, this scenario has an appropriately normal level of difficulty, the post-EOP malfunctions are straightforward and 12 related, necessary to facilitate transition to an EOP contingency procedure. In the opinion of the Chief Examiner, the deviation from target quantitative attributes is justified and the scenario is of an appropriate level of difficulty.
Scenario 2 - Event 4 (control rod double Added control rod double notch to notch) is not listed on quantitative table Instrument/Component Malfunctions and of Instrument/Component Malfunctions, Total Malfunctions on qualitative attribute or Total Malfunctions table. OBDI 202 - IOLE Process Rev 3
General Comments Comment Resolution ALL SCENARIOS: Make sure that none Each justification for major events was of the Major Events are exact repeats discussed with NRC, and major events used from last two exams. This is to satisfy in each scenario were determined to be guidance of NUREG 1021 Rev 11 APP different from those used in previous two D: if any major event is repeated from exams, IAW NUREG 1021 Rev 11 App. D.
either of the previous two NRC initial licensing operating tests, the examination author should change the major event, the ICs, or subsequent malfunctions (or a combination) to alter the course of action (within the emergency procedures) for the given 1 scenario(s). The NRC expect that all major events would be broadly sampled over the course of several operating tests and that no major event will routinely be omitted without justification.
If a facility licensee encounters difficulty meeting these requirements (e.g.,
because of large class sizes requiring the generation of more scenarios than normal), it should coordinate with the NRC chief examiner to meet the intent of this section to the extent possible.
Form ES-201-2 3.a: provide revised Audit exam will not be completely developed form, signed, when audit exam is until after the proposed exam submittal date developed. of 2/10/20. OBDI 202 - IOLE Process Rev 3