ML23018A041
| ML23018A041 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/22/2022 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Nebraska Public Power District (NPPD) |
| References | |
| Download: ML23018A041 (1) | |
Text
Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE COMMENTS Facility:
CNS First Exam Date:
11/14/22 Written Exam Outline Comment Resolution 1 NRC Generated No changes made to outlines at this point Administrative JPM Outline Comment Resolution General comments:
- 1) It always helps to have a brief narrative of each JPM even during outline reviews so we can see if it will work with overlap, if it is challenging enough, etc. I didnt see this for admin JPM outlines.
Will do on the next exam. Noted that it is now required in rev 12 during draft exam week.
DID not force them to go back and do it at this point but informed them that this is a requirement now (Rev 12).
1 For RO A2 JPM, when was it last used on NRC Exam (if ever)?
Licensee has lost track of their tracking systems since they converted to Vision. All of Entergy is converting to this and having some trouble with tracking some of these items. Licensee verified manually that this was not on previous two exams.
2 For RO A3 JPM, when was it last used on NRC Exam (if ever)?
Licensee verified manually that this was not on previous two exams.
3 For RO A4 JPM, when was it last used on NRC Exam (if ever)?
Licensee verified manually that this was not on previous two exams.
4 For SRO A6, with no database tracking number (such as Ovation or SKL034-20-114) for this I cant tell if this is the JPM from the NRC retake exam 2021-
- 06.
Not SRO without some kind of TS entry requirement.
- 1. Licensee verified manually that this was not on previous two exams.
- 2. Licensee added TS call to JPM.
5 For SRO A7, not SRO unless complete some TS requirement.
- 1. Licensee added TS call to JPM.
6 For SRO A8, marked as direct, confirm that it is not from previous NRC Exams or mark accordingly.
Licensee verified manually that this was not on previous two exams.
For the SRO A9 JPM, modified EAL call, please document somehow what the original JPM was and how it was modified.
OBDI 202 - IOLE Process Rev 3 Control Room / In-Plant System JPM Outline Comment Resolution General Comments:
- 1) Selection criteria for JPMS is not in accordance with NUREG-1021.
a) Step 1 -select number for each applicant type b) Step 2 - select Safety functions and systems to be used c) Step 3-select a task that supports the safety function and system in a meaningful way. Use KA catalog KAs d) So to get to JPMs used from previous two exams is not mathematically in your favor if systems/KAs have not been used in years or ever on an exam.
e) You should randomize safety functions (which looks like you are doing) to prevent predictability. However, systems and KAs dont seem to be selected before checking that you have a JPM in the bank.
- 2) I dont see any documentation on OP Experience events used for the exam so far (see below comment on this aspect).
- 3) There are several systems (not K/As, Systems) that have not been used on previous NRC exams. That needs to be addressed on future NRC Exams (including this one). I have suggested a few improvements for this issue.
- 4) Would like to see NRC exam numbers used instead of class numbers for direct from bank materials. We dont track by class number. I dont know if you guys are tracking this in Ovation but you should be. This is needed by us for overlap reviews.
Licensee understands.
OBDI 202 - IOLE Process Rev 3
- 5) It always helps to have a brief narrative of each JPM even during outline reviews so we can see if it will work with overlap, if it is challenging enough, if it is really alt path, etc. I didnt see this for sim/plant JPM outlines.
- 6) Make sure each control room JPM has multiple switch manipulations to ensure proper level of evaluation of control board mastery. One or two of these looked like they might not involve many switches, but it is hard to tell during outline review without a brief narrative.
1 Based on general comment 1 above, We should use a JPM on rods for SF1 JPM S5 (System 201003) that involves lowering rods or raising rods to meet a new rod line and have a stuck rod that requires more drive water flow or something along those lines (KA A2.06).
I dont think you guys have ever done this type of event. This would be new of course and would be alt path so it still meets your sample plan for JPMs and I dont believe it interferes with the simulator events. Also, the concept of meeting the safety function for reactivity when in mode 3 with recirc pumps is not really meaningful in mode 3. These are the NUREG words used on the outline form. Also, the outline form is incorrect for this JPMs type codes. S5 should be D, S, L, A. It is not an Emergency so no E for type code for this JPM.
Licensee created a stuck rod JPM from scratch and corrected all type code errors.
2 For SF2, JPM S3, this might be challenging to ensure that you are not using the same material on the audit exams because you have two exams in one year in multiple years so I would recommend using a different system in SF2. We can discuss this. L is missing for low power in type code for this JPM.
Was not used on audit exam, therefore no change was needed other than type code changes which are done.
3 For SF3 (JPM S8) the outline form is incorrect for this JPMs type codes. S8 should be N, S, L. It is not an Emergency so no E for type code for Type code errors fixed.
OBDI 202 - IOLE Process Rev 3 this JPM and it is low power so it gets a type code of L.
4 Is SF4 JPM (S2) an ENS JPM? Yes.
Then please add this type code to outline and JPM Type code errors fixed.
5 For SF5 (JPM S4) is fine.
Why has there never been a rad monitor JPM? SF7 and SF9.
Dont know. Expect to see one in the future 6
For SF6 (JPM S6) please add type code of L since it is at low power.
Why has there never been an RHR in SDC mode JPM? SF4.
Type change done.
Dont know.
7 SF7 not used on upper section of outline.
8 For SF8, JPM S1, please remove E for type code as these pertain to lower section JPMs only. Also, add L code since at low power.
Type code changes done.
9 For SF9 (JPM S7) please remove type code of E since this applies to lower section only.
Why has there never been a plant or CR ventilation JPM? SF9 Type code changes done.
Dont know.
For SF1 (P3) no changes needed.
10 For SF2, JPM P-2, for performing risk significant systems, resetting RCIC trip throttle valve linkage is very high on the list and I dont see it as ever being done as an in-plant. Do you have a mock-up of this valve? If not we can use pictures and use this instead of the fire pump JPM P2. This has has not been done at CNS in many years.
Also, the type codes are incorrect for this new RCIC JPM. It should not have EN by it since RCIC is not an ENS system. Also, this is an emergency condition so it gets a type code of E for this.
Licensee changed JPM to resetting the RCIC trip throttle linkage. No mockup is available so will use a picture. Corrected all type codes on outlines.
11 For SF7 (P1) this is really SF8 not SF7, so please correct this.
Licensee made change as requested.
12 Please correct all counting numbers in type code counting table in JPM outline with these updates to all the type codes.
Licensee made changes as requested.
Simulator Scenario Outline Comments Comment Resolution
OBDI 202 - IOLE Process Rev 3 General comments:
- 1) We dont have a middle power scenario (something in between startup and 100%). Something like 50% or 75% and bringing on a second feed pump is good or something like that. Even going down for an outage and being around 60% meets the spirit of these directions in the NUREG.
- 2) You dont need to put potential LCO statements on the D-1 if there is no TS entry then leave that info off of the D-1. You could put a note in the D-2 when you get to that event (for the examiner) stating it is potential but no entered but not on the D-
- 1.
1 Scenario 1:
Comments removed. Scenario 1 was removed from the set because it was not needed due to shrinking class size.
2 Scenario 2 (Low Power):
- 1) Event 4 looks like it is really only a TS call with maybe one switch manip. Is this true? Yes and the valve went closed so it doesnt count as a bean. So we would need another event with more switch manips for BOP if we are trying to balance the two boards.
Need to talk about line of site to core and what changes Cooper has made wrt those changes with ATC actions and equipment responsible for in that position.
This affects rotations on schedule during exam week and composition of scenarios.
- 2) Event 8 looks like ATC event but may need to change it to something for BOP depending on who gets CTs and bean counts-we will discuss.
Made adjustments during validation week.
- 1. Changed event 4 to inadvertent RCIC initiation (get TS and switch manips).
- 3. Changed failure of CS-MO-12B to 12A valve to make it different than previously used scenarios on past NRC exams.
3 Scenario 3:
Comments removed since it is the spare.
4 Scenario 4:
- 1. Needed another event for ATC-recommended something with single element control switch Made adjustments during validation week:
- 1. Used event 5 FW flow oscillations-required single element control switch to single element to stabilize
OBDI 202 - IOLE Process Rev 3
- 2. Need a CT after the major so we have two after the major event for balanced exam.
- 10)
Sample CT table for an ATWS CT with all the correct information needed for a current NRC Exam:
Critical Task (CT-1) During failure to scram conditions with power > 5%,
- terminate feedwater injection to lower RPV level to below -70 wide range. The level band of -70 to -130 WR should be initially established.
- maintains control of RPV level such that an automatic MSIV isolation due to low RPV level (-150 WR) does not occur.
Event 6
Safety Significance Regarding lowering level below -70 wide range, to prevent or mitigate the consequences of any large irregular neutron flux oscillations induced by neutronic/thermal-hydraulic instabilities. RPV water level is lowered sufficiently below the elevation of the feedwater sparger nozzles. This places the feedwater spargers in the steam space providing effective heating of the relatively cold feedwater and eliminating the potential for high core inlet subcooling. For conditions that are susceptible to oscillations, the initiation and growth of oscillations is principally dependent upon the subcooling at the core inlet; the greater the subcooling, the more likely oscillations will commence and increase in magnitude.
24 below the lowest nozzle in the feedwater sparger has been selected as the upper bound of the RPV water level control band. This water level is sufficiently low that steam heating of the injected water will be at least 65% to 75% effective (i.e.,
the temperature of the injected water will be increased to 65% to 75% of its equilibrium value in the steam environment). This water level is sufficiently high that most plants without the capability to readily defeat the low RPV water level MSIV isolation should be able to control RPV water level with feedwater pumps to preclude the isolation.
With reactor power > 5%, an MSIV isolation (when avoidable) would unnecessarily add heat to the suppression pool at a rate greater than that capable of being removed by RHR A and B. This could result in exceeding the Heat Capacity Temperature limit and subsequent loss of the primary containment due to over pressurization.
Note: This info comes from the USAR, EOP basis documents, Design basis documents, and soon to be new CT list from the BWR owners group (hopefully) and should be quoted from your particular group of documents in this table to support the license decisions that are made if an applicant misses them.
Cueing A scram is initiated (either automatically or manually) and numerous control rods indicate beyond position 02 and reactor power is > 5% on panel XXX indications and SPDS and RPV level is > -70 wide range on SPDS and PDS.
Measurable Performance Indicators To terminate/prevent Feedwater:
ON panel TTT:
Reduces feedwater discharge pressure to below RPV pressure.
Closes startup level control valve.
Closes N21-F009A, FW HTR 6A OUTL VLV.
Closes N21-F009B, FW HTR 6B OUTL VLV.
Closes N21-F040, FW SU BYP VLV.
To control RPV level once in band:
Selects Speed Auto on RFP used and raises RFP discharge pressure > reactor pressure.
OBDI 202 - IOLE Process Rev 3 Opens startup level control valve (nameplate name) as required to control RPV level.
Performance Feedback To terminate/prevent Feedwater:
On panel YYYY Controller nameplate name, Feedwater level master controller output indicates -
5.00%.
Controller nameplate name, Startup level controller output indicates -5.00%.
N21-F009A/B, and N21-F040 indicate green light on and red light out.
Feedwater flow to the RPV indicates 0.
To control RPV level once in band:
On panel ZZZ Nameplate name,Speed Auto pushbutton is backlit.
RFP discharge pressure indicates > reactor pressure on indicator nameplate name.
Raises output of controller nameplate name, Startup level controller output indicates
> 0.
Observes feedwater flow to the RPV.
Another example CT with all the required parameters within the table Critical Task (CT-2) All injection except boron, CRD, and RCIC are terminated and prevented when criteria specified in EP2A step L5 are met before Suppression Pool temperature reaches 120°F.
Event 6
Safety Significance 02-S-01-40, EP Technical Bases, Attachment V Step L8 A combination of high reactor power, high suppression pool temperature, and an open SRV or high drywell pressure indicates that heat is being added to the suppression pool faster than it is being removed by available suppression pool cooling. This condition could ultimately result in overpressurization and loss of primary containment integrity.
Loss of containment integrity could, in turn, lead to a loss of adequate core cooling and uncontrolled release of radioactivity to the environment. RPV water level is therefore lowered to reduce reactor power while efforts to shut down the reactor continue.
A suppression pool temperature of 110°F is the temperature at which Technical Specifications requires a reactor scram and the most limiting value of the Boron Injection Initiation Temperature. A temperature above this value indicates that suppression pool heatup is occurring. If power is not reduced, emergency depressurization may be required before the reactor can be shut down with boron.
120°F Suppression pool temperature is used due to it is the initial temperature used on the HCTL graph and Tech Specs Bases 3.6.2.1 states Continued addition of heat to the suppression pool with pool temperature >120°F could result in exceeding the design basis maximum allowable values for primary containment temperature or pressure.
Cueing Rx power indicating > 5% on Panel XXX and SPDS.
Suppression pool temperature indicating > 110°F on SPDS.
Performance Indicator Operator verifies Startup Level Controller in MANUAL on panel XXX and lowers output to -5.00% to stop feedwater injection until RPV water level lowers below -70 wide range.
Feedwater flow indicates 0 panel XXX / SPDS.
When RPV level is < -167, restores feedwater flow and controls level -167 to -191 CFZ.
Performance Feedback Startup Level Controller output indicates -5.00% on panel XXX.
Observes Feedwater flow indicates 0 panel XXX / SPDS.
Observes Feedwater flow restored on panel XXX / SPDS.
Observes RPV level within band of -167 to -191 CFZ on panel YYY instrument nameplate and/or SPDS as required.