ML22214A608
| ML22214A608 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/21/2022 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Nebraska Public Power District (NPPD) |
| References | |
| Download: ML22214A608 (9) | |
Text
CNS 2022-06 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 3.6-4, Operating Test Comments, because the licensees operating test submittal was reviewed and overall deemed SATISFACTORY.
Events and Evolutions Checklist
- 1. Form 3.4-1 -- Since only 2 scenarios will be administered, the form should identify which scenario is proposed as the spare, and exclude that from the event count, not add up all three scenarios. As currently filled out it gives an inaccurate representation of how many beans each applicant will receive. Also, combine these into 1 file with multiple pages. (Made changes using Scenario 1 as the spare)
Scenario 1 (100% MOL):
- 1. MAJOR: ATWS
- 2. GENERIC ALL Scenarios: Delete the Exam Policies and Guidelines section /
acknowledgements these are artifacts of a requal scenario. Delete all processes / sections that are part of requal. There are no lessons or lesson plans in an initial exam scenario. Delete CT Individual/Crew performance sheet.
(Made changes)
- 3. The required operator actions formatting (Form 3.3-2) is significantly different from past exams that Cooper has submitted, which were aligned with the formatting in NUREG-1021. It appears Cooper is using its requal scenario format for the initial exam. I can work with this so its not necessary to change it wholesale for this exam, but you should talk to Kelly about what hes comfortable with for his exam. (Told Lance to discuss with Kelly)
- 4. Form 3.3-1 is a formatting mess, extra lines, squeezed text columns, extra columns that arent in the boilerplate form. Use the boilerplate form, turn on layout editor mode so you can see where the fields are supposed to be filled out.
(Made changes)
- 5. GENERIC ALL Scenarios: Form 3.3-1 should be the 1st or 2nd page in package, immediately followed by the Scenario Summary narrative. (Made changes)
- 6. GENERIC ALL Scenarios: The scenario objectives section, simulator setup section, scenario conduct section: examiners dont need this, make it an addendum to the scenario package for station use and dont give it to the examiners during exam administration. (Made changes)
- 7. GENERIC ALL Scenarios: Every event should have symptoms/cues at the top of the event, per format of Form 3.3-2. (Made changes)
- 8. GENERIC ALL Scenarios: Every event should have a transition criteria at end, Proceed to next event when [xxxx], or at discretion of lead examiner. (Made changes)
- 9. Event 1, Lower Power, What procedural direction is the crew is using to lower power? Needs to be included in guide. (Added steps to the scenario guide)
- 10. Event 3, NLO role-play, wait 1 minute vice 3 to call back. (Made changes)
- 11. Event 5 RR Piping Leak: If the ATC is supposed to scram RX then there needs to be a step for him to do so in the event, credited to him as a bean. The first step of Event 6 WHERE CRS directs scramming RX needs to be pulled up into Event
- 5. Specify the leak size on 3.3-1. Scramming starts event 6 and I was under the belief if nothing occurred and it was being credited for the major I could not count it as a component failure? Added leak size to Form 3.3-1.
- 13. Event 6, Examiner Note, Table 41 actions are separated out for the RO and BOP on an approved Operator Aide. Where are these actions listed? Dont see anything labeled as Table 41 actions in the event. Are they on page 34? (Added to the scenario guide.)
- 14. CT-1, specify what the cool down rate limit is. (Added the cooldown rate)
- 15. All the steps from page 36-39, annotate who is performing them. Examiner should not have to flip back 5 pages to determine who is performing a step.
(Made changes)
- 16. CT-3, specify the components that need to be manipulated (RM-452A/B). Do both need to be closed, or only 1 to satisfy CT? (added to the measurable criteria, need to close one group 2 switches but procedure says one other the other group)
- 17. Event 7 - I dont see anywhere where it states 5.2FUEL has been entered.
(Made changes)
Post-Validation
- 1. Crew would not take watch due to power above licensed max power. Fixed
- 3. Event 5: ATC gets credit as well Fixed
- 4. Event 5: In description on Form 3.3-1, CRS direction to SCRAM and ATC attempt should be in event 5, not event 6. Fixed
- 5. CT3 measurable performance indicator on page 9 should include the minimum components to secure venting per 2.2.60 hard card. Fixed
- 6. Event 2 page 14 NLO cue should say 935 psig vice 925. Fixed
- 7. Event 4 pg 19, step 1.5 include steps to transfer A RRMG to S/U XFMR per 2.2.18.1 Fixed
- 8. Event 5 pg 21 step 4.3 need to include steps for venting containment through SGT.
Fixed
- 9. Event 6 the direction to SCRAM needs to be in Event 5. Fixed
- 10. Guide needs to include excerpts from EOP flow charts. Fixed
Fixed
- 12. CT-3: the current fuel leak size takes too long to get to the bounding criteria.
Adjust fuel leak size. Changed the fuel leak following the rods all going in. Caused the CT to be exceeded within 22-24 minutes following the scram. At ~ 5 minutes before exceeding he value the RX Building Exhaust Plenum alarm will come in at 10 MREM.
Scenario 2 (78% EOL):
- 1. MAJOR: ESD
- 2. Event 1 Role Playing: wait 1 minute to report back from field. (Made changes)
- 3. Event 4 ROLE PLAY, wait 3 minutes to report back, not 6. (Made changes)
- 4. Event 5: What is this first Examiner Note about view in RWCU B room? Is this a supposed to be a booth note? Changed to Role play as NLO
- 5. Event 7 pg 36 Error! Reference source not found? (Made changes)
make it consistent. (Made them all MSL Leak)
Post-Validation
- 1. Event 5, ATC took main actions, BOP took action to start all avail reactor building fan coil units and increase REC cooling. Fixed
- 2. Event 9, Failure of SGT A on Group 6 isolation should be event 8, and have its own page in the guide before the MSL Leak on aftershock occurs. Fixed
- 3. Earthquake aftershock and MSL leak should be labeled event 9 on summary and in guide. Fixed
- 4. Event 2, where it says Enter desired value, include that value in brackets. Fixed
- 5. Event 7 pg 21 CRS enters 2.4RR. Fixed
- 6. Event 7: 2.4RR Attachment 2 actions are assigned to both BOP and ATC in the guide. Fixed Scenario 3 (3% MOL):
- 1. MAJOR: Torus Leak, LOOP
- 2. Event 4: reactor power increase should occur as 2nd event of the scenario. (Made changes)
- 3. Event 1: States Examineer in multiple places. (Fixed)
- 4. Event 1: Operator action assignment says ATC/BOP/CRS, it should be broken out into who is actually performing the actions, per the Form 3.3-2 template.
(Fixed)
- 5. How long do we expect Event 1 to take? (estimate less than 15 minutes)
- 6. Event 9, clarify that the malfunction includes failure of DG1 to start manually as well, on 3.3-1. (Made changes)
- 7. Event 9, what is the procedural guidance that directs the BOP to check emergency power and attempt to start DG1 DG2 manually? Needs to be included in the guide, not just paraphrased actions. (Added an Examiner note for procedure 2.0.1.2 to take a failed automatic action.)
- 8. Event 9, need the include the procedural steps of 5.3EMPWR that operators are implementing, not just paraphrasing. (Made changes)
- 9. In the past Cooper has included excerpts of the EOP flow charts at decision points that the CRS is directing. With the 2 column format you are using, you have room to do that on the left. (added several decision points)
Post-Validation
[9.6] feet. Fixed
- 2. Event 9 description pg 3 should specify Loss of Offsite Power as the initiator. Fixed
- 3. Quantitative Attributes Table pg 4 should say opening at least 4 SRVs. Same comment page 10 Event 10 description. Fixed
- 4. Event 2 page 17 through 20 ATC actions can be deleted. Delete page 23 step 10 actions. Fixed
- 5. Event 2 page 21 should be actions from section 4 Single Notch Control Rod Withdrawal. Specify in Note the order of rods to be withdrawn. Fixed
- 6. Event 4 role play wait 1 minute. Fixed
- 8. Event 8, the ATC commenced makeup to the supp pool, not BOP. There were actions taken to close torus area drains as well. Fixed JPM S1:
- 1. No comments at this time.
Post Validation week:
Change validation time to 5 minutes. Add to Task Standard after IOAs prior to reaching 100% speed.
Add note on Step 3 that this needs to be done prior to lowering speed. Could do one controller lower speed then perform step 3 for other RR pump prior to lowering its speed.
Changed the validation time to 5 minutes, added prior to reaching 100% RR speed. to the Task standard and to Step 6 standard. Added note about order of changing to the S value. Rev. 2 JPM S-2:
- 1. The step numbering is off in alignment, almost hidden in my view might be my version of word, check how it looks in your view. Fixed Rev. 2 Post Validation week:
Remove ensuring the wear test trip switch in Disable from the Task Standard.
Add before the RFP trips automatically to the task standard following IAW alarm cards.
On Step 7 in title add the alarm to the title. A-1/F-5
On step 10, add before the RFP trips automatically to the standard following RFPA in second sentence.
Removed the ensure step in the Task standard. Added before A RFP trips automatically to task standard and the standard on Step 10, added alarm tile to the alarm card title on Step 7. Rev. 3 JPM S-3:
- 1. No comments at this time.
Post Validation week:
Change validation time to 5 minutes.
Changed the validation time to 5 minutes. Rev. 2 JPM S-4:
- 1. No comments at this time.
Post Validation week:
No comments JPM S-5:
- 1. No comments at this time.
Post Validation week:
No comments JPM S-6:
- 1. No comments at this time.
Post Validation week:
Change validation time to 5 minutes.
Changed the validation time to 5 minutes. Rev. 2 JPM S-7:
- 1. No comments at this time.
Post Validation week:
Change validation time to 5 minutes.
Changed the validation time to 5 minutes. Rev. 2 JPM S-8:
- 1. No comments at this time Post Validation week:
Change validation time to 15 minutes.
Change Step 16 to not critical. Controller already in correct position.
Move Step 22 to Step 20. Operators will address alarm card and then get back to verifying the procedure step.
Changed validation time to 5 minutes per CE request during NRC Validation Week.
Changed step 16 to non-critical, Moved step 22 up to step 20. Rev. 2
JPM P-1:
- 1. JPM step 4, does examiner need to provide applicant cue for SJAE steam pressure rising to > 20 psig on PANEL B, MS-PI-77A/B, A/B INLET PRESS?
Fixed formatting issue and clarified when SJAE should be given as a cue to the operator. Added boilerplate statement to JPM. Rev. 1 Post Validation week:
On Step 5 fix standard to correct step number (13.4.3 not 12.4.3) (fixed Rev 2)
On cue of Step 5 separate the reports, first line valves second line pressure if asked.
(fixed Rev 2)
JPM P-2:
- 1. Place a note before or in JPM step 6 that ALTERNATE PATH STARTS HERE.
- 2. After applicant places MANUAL BYPASS SWITCH to ALT SOURCE TO LOAD position in step 7, will the NBPP be energized at that point, or does the applicant still have to press ALTERNATE SOURCE SUPPLYING LOAD button in step 8?
If step 7 energizes NBPP, then step 8 is not critical. Added a note in step 6 for Alternate Path starting. The operator must press the ALTERNATE SOURCE SUPPLYING LOAD button to restore power. Added boilerplate statement to JPM.
Rev.1 Post Validation week:
On Step 8, change to not critical and add cueing information of powering the bus to Step 7 from Step 8. (fixed Rev 2)
JPM P-3:
- 1. Include same boilerplate statement in in-plant JPM task standards as in Sim JPMs. The applicants actions did not degrade the condition of the plant beyond that introduced by the JPM as developed. Added to JPM. Rev. 1 Post Validation week:
C pump preferred, not D pump.
We will use C CW pump if possible.
JPM A-1:
- 1. Steps 3 and 4 are critical steps. Changed steps 3 and 4 to critical steps. Rev.2
- 2. Include table 2 in answer key. Included Table 2 to the answer key. Rev.2
- 3. There is enough time before the exam that you should be able to get the typographical errors you annotated corrected in the procedure beforehand.
Discussed with a SRO on exam security but will need to discuss with you during prep week about using a procedure other than the frozen procedures.
Post Validation week:
Do a pen and ink on typographical errors in the procedure on day of test to give to the applicants and have the Operations Representative put in a pen and ink change following the test.
We will do the pen and ink prior to giving the reference material.
JPM A-2:
- 1. Revise this part of The task standard : Concurrent Verification on individual scram switches it isnt clear what this is, dont paraphrase. Dont paraphrase the second part of the task standard either. Revised the task standard. Rev. 2 Added that the examinee needs to determine that selecting a control rod for an I&C surveillance that a rod is not intended to move is exempt from the peer checking requirements following NRC Validation Week. Rev. 3 Post Validation week:
Removed the reviewed part of the standard on Step 2 and added determining that selecting a control rod for I&C is not required to being critical.
(fixed Rev 3) fixed task standard and standard of Step 2 for verification of a control rod.
JPM A-3:
- 1. Still need to specify what the components in red mean on the answer key. Why are the fuses not red if theyre on the task standard? (repeat from outline comments) Changed the fuses to red and added a note to the answer key to explain what the placement sequence in red means. Rev. 1 Post Validation week:
Have the equalizing valve and minimum flow valve already tagged and indicate the reason on the Initiating Cue. Remove the statement on Step 4 referring to the equalizing valve and minimum flow valve. Fix answer key with valves tagged.
Fixed. The min flow valve and the case equalizing tie valve are shown to already be tagged and this is discussed in the initiating conditions. Updated the answer key to reflect these valves not in the sequence.
JPM A-4:
- 1. A lot of empty space, see if you can get more than one step per page. Fixed Post Validation week:
Change the initiating cue to read meets NUREG 1.97 reliability requirements vice considered Reliable.
Changed Stem to read meets NUREG 1.97 reliability requirements following NRC Validation Week. Rev. 2 JPM A-5:
- 1. No comments at this time.
Post Validation week:
No comments
JPM A-6:
- 1. The changes that were directed on the Outline Comments were not made.
Again: The acceptable band of dates is excessive on answer key, and doesnt match task standard. Feb 9-11 is a reasonable band, since the answer falls 3/4 of way between Jan 30 and Feb 13. This range should be explicitly included in the Task Standard as well. Changed the date range to 2/9 to 2/11 on the answer for the critical step. Rev. 1 Post Validation week:
Change the date range to 2/6 to 2/14 for answer of critical step.
Changed the date range to 2/6 to 2/14 for answer of critical step. Rev. 2 JPM A-7:
- 1. No comments at this time.
Added note that the startup to critically was done IAW procedure and successful to ensure they should know that following BPWS was used and that more than 12 rods had to have been pulled.
Post Validation week:
Put brackets on Step 2, in standard around [C2.1.1 or C2.1.2], add in the initiating conditions after the reactor has just been declared critical, during a correctly performed startup.
Added (all procedural requirements were followed and completed successfully) to the stem. Added brackets to the standard on Step 2 around [C2.1.1 or C2.2.2] Rev. 1 JPM A-8:
- 1. No comments at this time.
Post Validation week:
Fix the answer key to match the standard. Change 7.75R to change 7.76R Fixed the answer key to match the standard on Step 4.
JPM A-9:
- 1. No comments at this time.
Post Validation week:
No Comments