ML20268A084
| ML20268A084 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/06/2020 |
| From: | Bryan Bergeon Entergy Nuclear Operations |
| To: | NRC/RGN-III/DRS/OLB |
| Bergeon B | |
| Shared Package | |
| ML19213A180 | List: |
| References | |
| Download: ML20268A084 (9) | |
Text
2020 Palisades ILE Operating Test Outlines and Audit Operating Test Outlines Determination of acceptability for the Operating Test Outlines is contingent upon the submittal of Audit Operating Test outline material for NRC review and evaluation.
Facility Response: The exam development team at Palisades understands the restrictions/requirements regarding overlap, and the need for the NRC to review the Audit Test for potential overlap and duplication per Form ES-201-2, items 2.b, and 3.a(3); and the instructions of ES-301 D.1.a, page 5 of 33; and Form ES-301-3 item 1.c. However, we could not locate anything in the NUREG that mentions submittal of Audit Operating Test OUTLINE material for NRC review and evaluation. Much of that material (test and any sort of outline) is still under development. Until the License exam is validated and ready for submittal, any Audit outline or test material is not finalized. Thus, any early submittal of audit materials would likely add confusion.
General Comments:
Facility Response: After reviewing these comments from the NRC, it was determined that the facility had used an inaccurate listing of the Operating Test items from the previous two NRC exams at the site, to select test items suitable for re-use in accordance with the allowances of the ES-301-1 and ES-301-2 forms. This resulted in exceeding the allowable limits for items that were P previously used. The facility contacted the Chief Examiner who was able to provide the correct list of items previously used. Going forward, the JPM outlines have been adjusted.
Admin JPMs:
RO Admins:
General Comments:
None Specific Comments:
RO Admin 1A o No initial concerns.
o Facility Response: moved location to classroom.
RO Admin 1B o No initial concerns.
RO Admin 2 o Appears to be direct from 2017 ILE. Type code is Direct (D) instead of Previous 2 exams (P). Being a previous 2 exam JPM, the requirements for overlap would remain met for the RO admin JPMs (<1 randomly selected for RO).
Facility response: As described in the General Comments above, this JPM has been reclassified to include P.
RO Admin 4 o No initial concerns.
o Facility response: We were unable to make this JPM work the way we wanted, and deleted it. We replaced it with a new JPM in the Radiation Protection area. (Admin 3)
SRO Admins:
General Comments:
Concerns with previous 2 exam overlap restrictions (<1 randomly selected for SRO) o Facility Response: Overlap restrictions followed.
Clarification needed on how SRO Admin 3 and 4 are different than those used on the previous 2 exams (see specific comments for details).
o Facility Response: Clarification provided (see specific comments for details).
Specific Comments:
SRO Admin 1A o Is the JPM considered modified due to changes in the errors made that must identified during the SRO review of the completed Supplement 35 (i.e. what is changed such that the JPM is not direct from bank)?
Facility Response: Yes, and there are different critical steps. The only other JPM I can locate from the past in the bank (Audit exam 2010) that has anything to do with calculating boration for a withdrawn inoperable control rod is much different that the current JPM. In the bank JPM, only one rod is stuck, the core burnup is 7000, and the PCS Boron is 860, and the reactor is still at power. In the proposed JPM, the reactor is tripped, there are four stuck rods, the burnup is 13000, and the PCS Boron is 1000ppm. This would seem to MODIFY the JPM enough to provide a test item that has not been rehearsed.
SRO Admin 1B o Type code should include (R) for classroom on ES-301-1 Facility Response: added R to Type Code SRO Admin 2 o Type code should include (R) for classroom on ES-301-1 o For the CR review, do the applicants need to complete any paperwork? Determine the appropriate TS conditions and required actions?
Facility Response: added R to Type Code; Probably no paperwork, but the Tech Spec Conditions and / or Actions will be identified /noted SRO Admin 3 o Is this JPM different from the 2017 ILE SRO Admin 4 (also 2009 audit exam)? If not, it should be marked as (P) from previous 2 exams and overlap concerns may not be met
(<1 randomly selected for SRO) (see SRO Admin 4).
Facility Response: NO. This JPM is identical to the 2017 ILE. (it was thought that this was the only randomly selected JPM from the previous two exams and should have been marked P). As this is the only P on this section of the exam, the overlap concerns are met.
o Is the simulator required for this JPM (i.e. is the applicant expected to determine the alarm or are they provided that information)? Type code should be marked (S) or (R) to reflect the location.
Facility Response: added S to the Type Code.
SRO Admin 4 o Type code should include (R) for classroom on ES-301-1.
Facility Response: NO, I think we need the Simulator. The Type code has been marked S.
o Will this EAL call be different that that of the 2014 ILE SRO Admin 5? If not, it should be marked as (P) from previous 2 exams and overlap concerns may not be met (<1 randomly selected for SRO) (see SRO Admin 3).
Facility Response: In 2014 it was from Mode 6 (Alert CA4.1). The proposed 2020 JPM is from Mode 5 and is an ALERT CA3.1. The initial conditions are different in many respects, but there are some similarities. The 2020 JPM conditions also meet other, lesser thresholds that the applicant must navigate past. The 2020 JPM is different enough from the 2014 JPM that the 2020 JPM is considered NEW. Thus, the overlap concerns are met.
Walkthrough JPMs:
General comments:
Concerns with previous 2 exam overlap restrictions (<3 randomly selected for RO and SRO-I).
o JPMs F, I, and K are labeled as (P) previous 2 exams, however, JPM B and J appear to be the same as used in the last 2 exams as well - see those specific JPM comments for details.
Facility Response: Further evaluation of the proposed JPMs and the replacement of one JPM, has left the outline submittal within the allowances for overlap with the previous 2 exams. See the specific responses below.
Specific Comments:
Sim JPM A o No initial concerns.
Sim JPM B o Per the JPM summary, this JPM appears to be the same as the 2017 ILE Sim H. This is marked as a (N) new JPM. As a previous 2 exams JPM, this, combined with Sim F and In-Plant I and K (and potentially In-Plant J) would exceed the previous 2 exams overlap requirements (<3 randomly selected for RO and SRO-I).
Facility Response: Upon further review, it is very similar to the 2017 ILE Sim H JPM and has been marked with the Type Code P, and the N code removed (Please refer to General Comments above). In-plant JPMs I and J have also been marked as P, and the F JPM has been replaced, making a new total of 3 from the previous two exams, which is within the limit.
Sim JPM C
o Is this JPM being performed as a surveillance to cycle the PORV isolation valves? This is marked as a (L) low-power/shutdown JPM - which Mode is this (surveillance/test) being performed in?
Facility Response: No, it is NOT a Surveillance to check an alarm that alerts an operator to a closure of an LTOP relief path (Palisades does not have that). The JPM setup is MODE 3 at 525°F and NOP. The plant is shutdown, but not yet cooled down. The PZR PORV Block valves are NORMALLY CLOSED at power but energized. The re-establishing of pressure on the PZR PORVS has been known to cause inadvertent lifting of the PORVS. The intent is to get the block valves open to enable LTOP during an upcoming cooldown without causing an SIAS.
Sim JPM D o No initial concerns.
Sim JPM E o No initial concerns.
Sim JPM F o Used on 2017 ILE Sim D. No initial concerns.
Facility Response: Due to having too many P JPMs selected, this JPM was replaced with a bank JPM to Start and Load a DG from the control room which was not part of the previous 2 NRC Exams. The ES-301-2 forms have been updated, this is not a P JPM.
Sim JPM G o No initial concerns.
Sim JPM H o As the JPM requires the applicant to direct local operations, is simulator booth involvement required during the JPM?
Facility Response: Yes, there are two operations at the beginning that the sim operator will be directed by the candidate to perform as a local operator. The remaining actions (10 or so) are performed by the candidate in the simulator.
In-Plant JPM I o Used on 2014 ILE In-Plant J. No initial concerns.
Facility Response: The Type Code is P.
In-Plant JPM J o Per the JPM summary, this JPM appears to be the same as the 2014 ILE In-Plant K. This is marked as a (D) direct from bank JPM. As a previous 2 exams JPM, this, combined with Sim F and In-Plant I and K (and potentially Sim B) would exceed the previous 2 exams overlap requirements (<3 randomly selected for RO and SRO-I).
Facility Response: The updated ES-301-2 is marked P, as it is the same JPM as the one on 2014. However, due to a replacement, and as explained in the other responses, the new total number of P JPMs is 3.
In-Plant JPM K o Used on 2017 ILE In-Plant K. No initial concerns.
Facility Response: This shouldve been labelled as MODIFIED. The task was on the 2017 ILE as In-Plant K, but the current version has been modified such that the initial conditions now have a loss of DC, and the Isolation of the SG from the
control room procedure has been commenced but not completed. This provides the loss of control room position indication of a valve, that then requires local closure of two other valves from out in the plant. This modification to the verifiable actions qualifies this as a modified JPM, NOT a P.
The ES-301-2 form has been updated.
Scenarios Facility Response: Due to the volume of changes, the D-1s, Scenario Summaries, and ES-301-5 forms have been revised.
General Comments No lower power scenario (defined as criticality to 5% power). The lowest initial condition is a power ascension commencing at 60%. A low power scenario is desirable, but not mandatory per ES-301. However, neither of the last two exams contained a low power scenario.
o Facility Response: Per phone calls on 11/19/19 with the Chief Examiner, a Criticality to 5% power scenario is not required. However, the exam should have a variety of initial power levels. A range of 25 to 100% was agreed upon.
Numerous events have credit (instrument, component, normal, reactivity) given to applicants who are not performing a verifiable action for the given event. Additionally, multiple events are a cause-effect relationship that one event causes a transient (with no verifiable actions) where action is taken on a following event (where a verifiable action is taken) and both are listed as separate events. See scenario specifics for details.
o Facility Response: Some of the events /malfunctions were listed because they provided an opportunity to be graded on the Interpretation/Diagnosis and communications and parts of the direct shift operations competencies. The NUREG states to provide multiple opportunities for each applicant to be graded on each competency and asks for the event numbers on the ES-301-6 Form (Competencies Checklist). The summaries have been enhanced to describe more of the verifiable actions by the not so obvious players.
Scenario turnover information needs enhancing and clarification.
o Facility Response: See specific scenarios comments for enhancements and clarifications.
Critical Tasks all require bounding conditions, as required by App D.
o Facility Response: See specific scenarios for bounding conditions for each Critical Task.
Scenario Specific comments Scenario 1 o Will need to determine bounding conditions for each CT.
Facility Response: Each remaining CT has stated bounds.
o With the lifting relief valve, will the PCS leak at power result in an automatic SIAS if the crew does not take action to isolate the leak (i.e. does it exceed the normal charging capacity)? If not, the CT is not considered critical.
Facility Response: No. If the leak remains unisolated, an automatic SI will NOT occur. The CT has been removed.
o After the T2/L2 strategy is implemented, what conditions are expected to be exceeded such that the remaining 2 PCPs must be secured to satisfy CT 3?
Facility Response: The T2/L2 strategy is employed while the LOCA is small. After 2 PCPs are tripped, the severity of the LOCA rises, resulting in a CSAS and produces the point where conditions no longer support operation of any PCPs.
o Event 3 - how is the BOP receiving credit for a normal for this event?
Facility Response: The ATC responds by selecting alternate control channels for PLCS. The BOP performs the Bypassing of the TM/LP channel affected by the RTD failure per the AOP, which is a response to the instrument failure. The BOP should be credited with an (I) vice an (N).
o Event 6 - RO will receive reactivity credit, while BOP and SRO receive normal (currently has ALL applicants receiving normal credit and the RO receiving an additional reactivity credit).
Facility Response: Events 5 and 6 have been reconfigured such that there is only one event. The rapid reduction in power (Event 5) per the AOP should be credited as an (N) for the BOP and SRO, and an (R) for the ATC. Event 6 is a LOCA with degraded equipment responses requiring actions to Start a HPSI Pump, use the T2/L2 Strategy, then later Trip the remaining PCPs, and Start Containment Spray.
Scenario 2 o The crew will need to know what the SIRWT boron concentration is and additional information to complete the task; also need to provide procedure direction.
Facility Response: The turnover will include the necessary information for the crew to perform the boration of the SIRWT.
o Turnover information needs enhancing.
Facility Response: See previous comment o Will need to determine bounding conditions for each CT.
Facility Response: CTs adjusted to include bounding statements.
o It appears that CT 1 and CT 3 are required in order to satisfy CT 2 (i.e. in order to prevent SG overfill conditions, PCS/SG pressures must be equalized to minimize PCS leakage to the ruptured SG and the faulted/ruptured SG be isolated)? Both CT 1 and CT 3 are part of the mitigative strategy performed to prevent SG overfill. It seems as though CT 2 is more of the bounding condition for CT 1 and CT 3.
Facility Response: Rewrote the CTs to incorporate the bounding statements.
o Should manually actuating SIAS be considered a CT (not doing so will lead to loss of PZR level and potential core uncovery, void growth, fuel damage, etc.)?
Facility Response: Yes, actuating SI on at least one train is a CT.
o Should throttling HPSI flow to stabilize PZR level/pressure and SG level be a CT?
Facility Response: The rate of Pressurizer level Recovery does make this a valid CT.
o Event 3 - What verifiable action is the BOP taking to receive component credit to the tripped cooling tower pump? The BOP is only directing local actions in AOP-6 and has no verifiable actions. The BOPs verifiable action to initiate the runback, in which the
BOP would receive normal credit under Event 4. Appears that Event 3 & 4 are a singular Event (cause and effect).
Facility Response: The event has been changed to a lube oil problem on the Cooling Tower pump that is cued by a main control room alarm. Reports from the field confirm the pump is in distress. The BOP will manually trip the pump, to receive component credit.
o Event 4 - SRO receives normal credit Facility Response: The rapid down power is an (R) for the RO and an (N) for the BOP and SRO.
o Event 8 - What action is the BOP taking to receive credit in response to the SG tube leak? The RO will be taking action to attempt to stabilize PZR level and determine a leakrate, in which case, the RO would receive (C) component credit.
Facility Response: The event has been changed. The Tube leak stays within charging capacity but probably does NOT have verifiable actions for the BOP. As the crew trends the leak rate, it grows to a tube rupture requiring a trip and SI.
o Event 10 - How are the BOP and RO both receiving component credit for the auto SIAS failure?
Facility Response: Actuating the SIAS pushbuttons will not cause any equipment to respond. The ATC will start the ECCS pumps and open/ close valves. The BOP will start SWS and CCW, and stroke other valves per EOP Supplement 5.
o Concerns for the BOP not receiving adequate event credit for this scenario, based on the questions with the events and credit for the events, as discussed above.
Facility Response: The BOP receives credit for 1 Normal, 1 I/Cs (low lube oil on cooling tower pump), 1 Major (SGTR with Faulted SG), 1 post trip I/C (auto SI failure). Additionally, since every candidate will be in 3 scenarios, the total bean count for each license will be met.
Scenario 3 o Turnover information needs enhancing, such as procedures in progress, expected ramp rate, etc.
Facility Response: Turnover information enhanced. A turnover sheet will be prepared and handed to the oncoming crew.
o Will need to determine bounding conditions for each CT.
Facility Response: Bounding conditions for each CT added.
o Is PCP trip criteria expected to be met during the scenario (CT needed?)?
Facility Response: Not expected o Event 2 - RO will receive reactivity credit, while BOP and SRO receive normal (currently has ALL applicants receiving normal credit and the RO receiving an additional reactivity credit).
Facility Response: Corrected o Event 5 - require TS or ORM call?
Facility Response: Neither o Event 6 - require TS or ORM call?
Facility Response: Neither
o Events 7 & 8 - appear to be a singular cause-effect event, as the GV failure will cause the ESDE. As such, the verifiable action required for that singular event is trip the Rx and isolate MSL (which will not work due to Event 11). For Events 7, 8, 9, 11 - the BOP would receive separate credit for tripping the turbine and isolating MSL by manually closing the MSIVs, not credit for 4 different component failures.
Facility Response: Agree that Events 7 and 8 are related as a cause effect, that leads to 9, 10 and 11. The intent is to have the GV closure cause the initial small steam leak, have the crew diagnose the need for a reactor trip. When the crew trips the reactor and the rest of the GVs close, the steam leak gets much bigger.
The BOP should be credited for manually tripping the main turbine because auto trip doesnt work and manually closing the MSIVs that fail to auto close.
Scenario 4 o Turnover information needs enhancing - any equipment out of service? Why is 25F7 being closed?
Facility Response: 25F7 is being closed to restore the ring bus. It is a (N) for the BOP. The Oncoming crew will get a complete enhanced turnover.
o Will need to determine bounding conditions for each CT.
Facility Response: Bounds for each CT updated.
o Is tripping the PCP critical if a LOOP occurs and a failure of both EDGs requires manual restoration of bus 1C or 1D? Wont the PCP trip on a loss of power in that case? If so, the task is should not be critical, unless damage will occur prior to PCP prior to the loss of power, for example.
Facility Response: The LOOP wont occur (and the EDG loading problems wont be presented) until the operator trips the PCP with high vibrations (or the pump destroys itself in about 5 minutes after exceeding the hi vibration trip criteria in the AOP.
o Event 3 & 4 - What verifiable actions will the RO (at-the-controls operator) take such that these events count as component failures? AOP-29 does not appear to have the applicant perform verifiable actions to mitigate a transient under these conditions, until the high vibration comes in as part of Event 7. It appears that Event 3 & 4 are simply conditions leading to the reactivity manipulation in Event 5. *See 2017 ILE Scenario 2, Event 6*
Facility Response: The PCP Seal failure problems have been removed, the PCP vibrations will get worse over time requiring a trip. There is little that the ATC can do for the PCP problem other than monitoring, but he does have to take an action after the upcoming Reactor Trip, to trip that PCP. That is the verifiable action for the PCP malfunction.
o Event 6 - require TS or ORM call?
Facility Response: No o Event 8 & 9 - Appear to be a singular event. What verifiable actions are taken such that ALL applicants receive credit for a component failure in Event 8, when the action taken in response to the LOOP is by the BOP in Event 9?
Facility Response: The events have been renumbered. When the reactor is tripped, a vapor space LOCA starts. Its severity does not require tripping PCPs.
(However, the PCP with high vibrations does need to be tripped after verification of the reactivity safety function). After that PCP is tripped, a LOOP occurs. Both EDGs are available but require different operator actions to get them to restore power to the buses. One needs to be manually started, the other needs to have its output breaker manually closed. Additionally, Air Compressors, Charging pumps, and CACs will also have to be manually started.
These actions for this event have been encompassed into the one event, as they are cause effect related.
o Credit for each event should be revised to include all applicants who will receive credit for each event (i.e. Event 2 SRO should receive component and TS credits, Event 4 SRO should receive TS credit, Event 5 SRO and BOP should receive normal credit, etc).
Facility Response: Revised the D-1s, Summaries, and ES-301-5 forms.
Written Outline Written outline comments provided to NRC and concurrence provided back to licensee on 8/7/19. No additional comments, other than review of the audit exam outline is required when available (for development methodology and potential overlap review) o Facility Response: An Audit written outline is available.