ML23038A136
| ML23038A136 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/12/2023 |
| From: | NRC/RGN-III/DORS/OB |
| To: | Energy Harbor Nuclear Corp |
| Greg Roach | |
| Shared Package | |
| ML21188A236 | List: |
| References | |
| Download: ML23038A136 (5) | |
Text
Perry 2022 Initial License Exam Operating Test Outline Review Comments Page 1 of 5 JPM Outline Comments
- 1.
NRC: (Control Room Systems / In-Plant Systems) - The 3.2-2 forms do not include the KA that each JPM is tied to. A KA from the appropriate safety function and associated with the main system/effort of the JPM must be identified for each JPM. The KA at least must be listed on the cover sheet of the JPM.
Facility: Each JPM cover sheet lists the applicable KA. The KA for each JPM has been added to the RO, SRO-I, and SRO-U Form 3.2-2.
- 2.
NRC: (Control Room Systems / JPM d) - Is called out as Safety Function 4. This JPM should be tied to Safety Function 5 as it is associated with transitioning RHR in containment spray mode to suppression pool cooling which are containment functions. NUREG 1123 specifically titles Safety Function 4 as Heat Removal from the Reactor Core. These modes of RHR are not from the reactor core but from the containment. This JPM was correctly coded as Safety Function 5 when it was used in the 2021 exam.
Facility: Initially, RHR A is in Containment Spray Mode and RHR B is the only Injection Source lined-up for injection. The Initiating Cue directs the candidate to align RHR A from Containment Spray to Suppression Pool Cooling. However, during the termination of Containment Spray, RHR B pump trips and RHR A is the only remaining injection source. RHR A must be realigned to injection to maintain RPV water level, meeting the requirements of Safety Function 4.
- 3.
NRC: (Control Room Systems / JPM f) - Please explain how this JPM will be performed as its type code indicates it is performed in the main control room.
Facility: This JPM will be simulated in the Unit 2 Control Room. Originally Perry was designed as a 2-unit plant with 2 adjacent Control Rooms. Some controls and components in the U2 Control Room support U1 operations. The components manipulated in this JPM are active in the U2 Control Room.
- 4.
NRC: (In-Plant Systems / JPM k) - On the RO 3.2-2 this JPM is listed as occurring in the RCA but does not indicate that on the SRO-I 3.2-2. Please clarify if this JPM will take place in the RCA.
Facility: JPM k will have the later portion of the required actions performed in the RCA at the Control Point (just inside the RCA boundary). The SRO-I 3.2-2 has been updated.
Perry 2022 Initial License Exam Operating Test Outline Review Comments Page 2 of 5 Simulator Scenario Outline Comments
- 1.
NRC: (Scenario 2022-1) - Would initial plant risk still be GREEN with the HPCS pump unavailable?
Facility: PRA Risk has been verified using the current revision of Phoenix (risk assessment software used at Perry) to be GREEN with HPCS OOS.
- 2.
NRC: (Scenario NRC2022-3 / Event #5) - It appears the crew will have already entered TS 3.5.1 for the lineup needed to perform the HPCS surveillance in event #2. Why would the crew re-enter TS 3.5.1 in event #5 when securing from the lineup when the test valve loses power? Please explain timeline for TS entries associated with TS 3.5.1.
Facility: During Event 2, the crew will enter TS 3.5.1 Condition B for use of HPCS in a secondary mode of operation. Upon the failure in Event 5, the crew will address the continued application of TS 3.5.1 due to the failure of a component, not due to a secondary mode of operation. This TS call is not credited for one of the two required calls, and the application of TS 3.6.1.3 is the required TS application for Event 5.
- 3.
NRC: (Scenario NRC2022-3 / Critical Task #2) - With no LOCA present will the crew have a problem maintaining RPV level above the ED requirement? I expect the crew will run SLC and both trains of CRD to maintain level.
Facility: The time to reach Level 1 (when ADS will automatically initiate) is dependent on how expeditiously the crew initiates ARI as the automatic and manual scram and automatic ARI functions will not work. If the crew delays initiation of ARI for 90 seconds following the loss of FW, RPV level will reach L1, ADS will initiate and MSIVs will shut. However, if the crew initiates ARI at ~ 178 (this would be a very quick recognition of the loss of FW and failure to scram) it would take ~ 14 minutes to reach L1. In this case, the crew would be expected to Inhibit ADS and Bypass Level-1 MSIV Isolations. RPV level would continue to lower.
EOP-01-5, ATWS RPV Control allows the RPV to be Rapidly Depressurized to allow low pressure ECCS systems restore level.
The crew would lower RPV pressure to allow Low Pressure ECCS systems to recover level. If the crew initiates SLC, a leak in the downstream piping (caused by the earthquake would prevent SLC from reaching the RPV. If the crew starts a second CRD pump, it will trip on a seized shaft.
The CT should read, Prior to Automatic Depressurization System initiating or the decision to Rapidly Depressurize the RPV based on low RPV level, RCIC is manually initiated or started.
Perry 2022 Initial License Exam Operating Test Outline Review Comments Page 3 of 5
- 4.
NRC: (Scenario NRC2022-4 / Event 3) - Explain why the crew is required to enter TS 3.6.1 for an inadvertent HPCS start?
Facility: Typographical error, TS 3.3.6.1, function 2.e, Reactor Vessel Water Level -
Low Low, Level 2 (HPCS) for the failed instruments that caused the Div 3 actuation.
- 5.
NRC: (Scenario NRC2022-4 / Event 4) - Events #3 and #4 appear to occur simultaneously and both are required to be addressed by the BOP operator with at least one of the events requiring manual control actions. Please explain the timeline for these events and how they will be addressed simultaneously by the BOP.
Facility: Both events occur in short succession. However, initially, the HPCS Pump is tagged out, so there are no applicable ONI-E12-1 Actions to be performed. The BOP will have time to respond to each independently.
Upon HPCS initiation the HPCS DG will start and after ~30 seconds, the HPCS ESW pump should start. The BOP will announce the HPCS inadvertent initiation and monitor for the start of HPCS ESW. When the HPCS ESW Pump fails to start, the BOP will start the ESW Pump by using the control switch, or opening the discharge valve. Due to the invalid initiation, the BOP may also secure the HPCS DG with SRO concurrence.
The BOP will also investigate the cause of the HPCS initiation by looking at the control room back-panels.
- 6.
NRC: (Form 3.4-1, Events and Evolutions Checklist) - SRO candidates should only get credit for manual control evolutions when they are standing in the ATC or BOP position. Per NUREG 1021 manual control actions require specific verifiable action steps for the applicant. In addition, NUREG 1021 specifically indicates that upgrade candidates are not required to perform manual control actions since they are generally not expected to stand watch as an ATC or BOP. Removing manual control credit for the SRO instant candidates when they are in the role as the SRO still leaves all candidates with at least 1 required manual control action so this is an administrative fix only. I have corrected the Form 3.4-1 to reflect this.
Facility: Your clarification of this new topic is appreciated. Manual Control will only be credited to the ATC and BOP positions.
Perry 2022 Initial License Exam Operating Test Outline Review Comments Page 4 of 5 Written Outline vs. Operating Outline Potential Overlap Comments
- 1.
NRC: (Written Outline Item #1) - Ensure there is no significant overlap between scenario 2022-2 event 8 and written question 13 which both are associated with thermal-hydraulic instabilities/power oscillations associated with a partial or complete loss of recirculation/core flow.
Facility: Scenario-2 Event 7 is a downshift of both Recirc Pumps to Slow speed which causes Event 8, Power Oscillations. Inserting Cram Rods is the required action. On the downshift, the Core plate P instrument quickly indicates accurately for evaluation of entry into the Immediate Exit Region of the P/F Map. Total Core Flow is obtained by observation SPDS which takes some time to update to show accurate flow.
Question RO 13 has similar setup. The Candidate will evaluate position on the P/F Map. However, CRD pumps are not available. So, instead of inserting Cram Rods, the correct answer is to insert a Manual Rx Scram.
- 2.
NRC: (Written Outline Item #16) - Ensure there is no significant overlap between scenario 2022-1 event 6 and written question 28 which both have to do with a low reactor water level due to a loss of feedwater.
Facility: No significant overlap exists between the test items.
Scenario-2 Event 6 is a loss of all feedwater resulting in ED or AED.
Question RO-28 asks for the required actions regarding feedwater during an ATWS with low Rx water level and RPV level increasing.
- 3.
NRC: (Written Outline Item #26) - Ensure there is no significant overlap between scenario 2022-4 event 8 and SRO written question 13 which both are associated with procedure actions to address a low suppression pool level.
Facility: No significant overlap exists between the test items.
Scenario-4 Event 8 is an unisolable leak from the Suppression Pool which requires ED.
Question SRO-13 has an isolable leak from the Suppression Pool with SP level low and lowering and asks which procedure will be used for the given conditions. If the proper procedure is selected, ED will not be required.
Perry 2022 Initial License Exam Operating Test Outline Review Comments Page 5 of 5
- 4.
NRC: (Written Outline Item #78) - Ensure there is no significant overlap between alternate path Control Room JPM h and written question 75 which tests pneumatic system malfunctions and their impact on the control room ventilation system.
Facility: No significant overlap exists between the test items.
JPM-h requires the Operator to shift CR ventilation between Recirc and Normal modes. Then upon a failure of a damper, to shift back to Recirc mode.
Question RO-75 asks how CR ventilation will respond to a high rad signal followed by a loss of Instrument Air.