ML12285A125

2012 Dresden Nuclear Power Station Initial License Examination Operating Test Review Comments and Resolutions

ML12285A125
Person / Time
Site:	Dresden
Issue date:	09/26/2012
From:	Bielby M, David Reeser Operations Branch III
To:
Shared Package
ML11354A120	List: ML12285A082 ML12285A125 ML12285A132 ML12286A338 ML12286A345 ML12297A290
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Download: ML12285A125 (9)

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response Operating Test JPMs RO Admin JPMs A-N-1-R 1) Initial Conditions, Line 4; replace they with 1) Left as is.

he.

2) Initial Conditions, Line 7; Sentence as written 2) Sentence revised to clear up the working hour does not make sense. Consider revising status.

sentence into two statements; one to state that individual was on vacation and second one introducing the work hours table.

3) Revise NOTE to provide procedure when 3) Note revised as suggested.

requested/located.

4) A more operationally valid cue for JPM Step 1 4) Cue revised as suggested.

might be to ask the applicant what requirements must be satisfied to allow him to work the extra hours with the standard for job step 2 revised accordingly.

5) Fix step numbers on the cue sheet. 5) Fixed

6) 15 min seems like long time to apply work 6) Left as is. Facility indicated time is based on hour rules. Is 10 minutes more reasonable? numerous validations/performances of JPM.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response A-N-2-R 1) Delete broken arm and leg. (possibly 1) Change made as requested.

replace with a statement that the individual is in lot of pain) and He is not contaminated from Initiating Cue. Applicant should be verifying conditions (ie, extent of injuries and contamination) based on procedure.

2) Replace initiating Cue #3 with appropriate 2) Changed as suggested.

cues within JPM body.

3) Add note to evaluator that applicant may call 3) Change made (JPM step 3). Additionally 911 on a dedicated outside phone line. specific extension numbers replaced with:

appropriate number from station directory.

4) Add pickup location to standard 4) Added (JPM step 3)

5) Revise standard for step 5 to include with 5) Standard revised to include the specific actions and makes the specified requests. that must be requested for satisfactory completion.

6) What is the validated (time estimate) for 6) Validated completion time added.

completion?

A-N-3-R 1) Perform Off-Site Power Sources Available 1) ES-301-1 allows a repeat of one admin JPM used on 2011 RO admin JPM exam. The from the previous 2 exams.

2011 RO admin JPM is identical to the 2012 RO admin JPM except one listed under 2.1.31 (Conduct of Ops), and one listed under 2.2.37 (Equipment Control).

2) 20 min seems like long time to complete 2) Left as is. Facility indicated time is based on verification of several breaker positions and numerous validations/performances of JPM.

check bus voltages. Is 10 minutes more reasonable?

3) Does applicant have to receive Initial Cue of 3) This is the expected order from the US. No where to find the correct Attachment to use? change made to cue.

4) Cue for JPM Step 8 at bottom of previous 4) JPM Step 8 revised with expectation that page, put at top of the following page with voltage will obtained using computer point and associated JPM Step 8. cue for field reading deleted.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response A-N-4-R 1) What is the validated (time estimate) for 1) Validated completion time added.

completion?

2) Revise INITIATING CUE to direct the 2) Change made as suggested.

applicant to determine the radiological controls needed to investigate the leakage on the RWCU Recirc Pump Suction Valve.

3) JPM Step 1; Is it wrong to use Zone 3 3) Added the word minimum to standard.

garments (full hood, wrist cuffs)?

4) Add cue before JPM Step 2 to query the 4) Cue was not added, but remains an option applicant on items discussed during the brief. available to examiner.

SRO Admin JPMs A-N-1-S 1) JPM Note at top of page, only provide copy of 1) Call Jeff SY-AA-101-132 to applicant because it is the only reference given in the Initiating Cue. He should need to locate/ask for the DOAs if needed.

2) Add NOTES to query the applicant if 2) Reevaluated as unnecessary. Always an necessary to provide justification for their option available to examiner.

assessment.

3) Assessments are somewhat subjective. If 3) Expected detonation time in Initial Conditions applicant assesses threat as NON-CREDIBLE revised to eliminate concern.

or CREDIBLE/ACTUAL initially, is that considered an unsatisfactory critical step?

4) What actions in DOA 0010-18? Identify 4) Revised to state all actions are required to be specific standard(s) to be satisfied from DOA identified.

0010-18, D.4 3 of 9

NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response A-N-2-S 1) Delete INITIAL CONDITIONS 2 through 5. 2, 1) Condition 4 was moved. All others left as is.

3, and 5 are provided in the provided Attachment 1. Condition 4 should be provided as a verbal cue when requested/needed.

2) Revise Initiating Cue to read: Complete the 2) Initiating Cue revised as suggested. Step 5 cue applicable portions of the Fire Protection determined to be unnecessary.

Impairment Permit. Provide a Cue prior to JPM step 5 to Initiate the required fire-watch if not initiated by the applicant.

3) Add NOTE prior to JPM step 7 to query 3) Reevaluated as unnecessary. Always an applicant as needed to provide justification for option available to examiner.

decision on Comp Measures.

4) Add NOTE prior to JPM Step 1 that number 4) Added may be entered during completion of Section II of Impairment Permit (step 4.4.1.2.G of procedure).

5) Where is guidance for determining the need 5) NEIL notification not required since impairment for Comp Measures or the need to notify not expected to last more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

NEIL?

6) Why are JPM Steps 2, 3, 11, 16, 21, 22, 23, 6) Determined not to be critical since information and 27 not critical? is obtained elsewhere during performance and copied to appropriate blocks.

A-N-3-S 1) Review Calculated DW Leakage and Identify 1) ES-301-1 allows a repeat of one admin JPM TSs used on 2011 SRO exam. 2011 and from the previous 2 exams. Need to update 2012 SRO admin JPMs essentially the same, ES-301-1 to indicate repeat from previous different numbers. exam.

2) Standard for JPM Step 4 TS action specifies 2) Standard corrected to specify only Condition A both Condition A and B, but previous version referenced only Condition A.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response A-N-5-S 1) Can anything be added to make this less 1) Evaluated with no changes made.

simplistic?

2) Validated time of 15 minutes is not 2) Left as is. Facility indicated time is based realistic. Would expect something more on numerous validations/performances of around 5 minutes. JPM.

3) Is this action consistent with the 3) Evaluated as acceptable. No change notification requirements of DOA 0010-18 Simulator JPMs S-N-a 1) Add a JPM step after JPM Step 7 to include 1) Step is not included in procedure so it was verification of flow light status. not changed.

2) Revise ES 301-2 to reflect modified JPM 2) JPM was not modified from last use.

S-N-b 1) Is it necessary to direct the applicant to the 1) Step/paragraph reference removed.

specific procedure paragraph in the Initiating Cue? If not, delete that direction, let applicant identify.

S-N-c 1) Is it necessary to direct the applicant to the 1) Left as is.

specific procedure paragraph in the Initiating Cue? If not, delete that direction, let applicant identify.

2) JPM step 1 should have already been 2) Moved to Initiating Cue.

completed if US is directing restoration.

Include in Initial Conditions.

S-N-d 1) Is it necessary to direct the applicant to the 1) Left as is.

specific procedure paragraph in the Initiating Cue? If not, delete that direction, let applicant identify.

2) NOTE should be place before JPM step 5 not 2) Note moved.

after.

3) Should JPM Step 6 be critical? 3) Reevaluated as non-critical

4) Should JPM Step 10 be critical? 4) Reevaluated as non-critical; unnecessary to stop pump.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response S-N-e 1) Should JPM Step 4 be critical? 1) Changed to a Critical Step

2) Validated time of 16 minutes seems long, 2) Left as is. Facility indicated time is based would expect something more around 10 on numerous validations/performances of minutes. JPM.

S-N-f 1) EDG-Perform Surveillance Testing, With 1) ES-301-2 allows a repeat of 3 JPMS from the Scram is essentially same as 2010 JPM. previous 2 exams.

2) Delete direction to review Sections F and G 2) Removed from cue.

from the Initiating Cue (Ops expectation for operators to review limits and precautions).

3) Why is this alternate path? It seems this could 3) Task is a response to an abnormal condition just as easily been initiated before during the assigned task.

commencing a load reduction.

4) Why is JPM complete if EDG is not 4) To continue would not add value to evaluation.

shutdown? 5) Added tolerances to standard for frequency and voltage adjustments.

S-N-g 1) Is this alternate path? What is the alternate 1) Response to unexpected condition (failure of path? status light to re-energize; alternate path is to bypass IRM channel due to inoperability.

2) Initial Condition #2 and Initiating Cue #1 on 2) Fixed applicant cue sheet do not match initial condition and Initiating Cue listed on page 4

3) Surveillance activity (I.9 through I,12) should 3) Evaluated as unnecessary to task evaluation.

be completed 4) Revised standards in JPM steps 3 and 6 to reflect that two actions are required (select and drive)

S-N-h 1) Typo in equipment ID number in JPM step 27 1) corrected 6 of 9

NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response Inplant JPMs S-N-i 1) Is it necessary to direct the applicant to the 1) Step number deleted specific procedure paragraph in the Initiating Cue? If not, delete that part of direction, let applicant identify.

2) JPM Step 5 critical? 2) Changed to critical

3) Revised JPM step 6 from tasks to in-plant actions are S-N-j 1) Is it necessary to direct the applicant to the 1) OK as is.

specific procedure attachment in the Initiating Cue? If not, delete that part of direction, let 2) Added cue for engine RPM applicant identify. (for step JPM step 2)

S-N-k 1) Is it necessary to direct the applicant to the No changes were made.

specific procedure step in the Initiating Cue?

If not, delete that part of direction, let applicant identify.

2) Is 1st cue necessary? Cant this be verified locally? Make them earn the information.

OPERATING TEST SCENARIOS Overall comment: No electrical bus failures that require manipulation of power sources.

Scenario 1 Scenario will be replaced with the previously identified Spare scenario.

Event 2, C 1) Minimal actions for BOP, but there are at least Meets minimum requirements.

two required steps.

Event 3, C, TS 1) Minimal actions for BOP, but there are at least Acceptable as a TS event for SRO, but insufficient to two required steps. There does not appear to credit as a component malfunction for the BOP (only be any required manipulations; no credit for one verifiable action with no significant consequence if component failure. not performed).

Event 4, C 1) Minimal actions for ATC Meets requirements. Add Flow Control Valve manipulation to list of ATC actions.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response Event 5, I, TS 2) Note: TS allows 12 hrs to put channel in trip. Acceptable as a TS event for SRO, but only one verifiable action for ATC (manually insert 1/2 scram) but with no apparent consequence since scram functionality maintained.

Event 6, C 1) Minimal actions for BOP, only 1 required step (start 2B CW pump). Would not consider this an adequate C for BOP as written.

Event 7, M 1) Insert relevant vacuum numbers, ie, trips Will be inserted.

Scenario 2 Event 1, N 1) Minimal actions for BOP, but there are at least 2) CRS direction not procedural direction but two required steps. order to simply swap fans.

2) Appears the BOP stops fan, then starts other fan in lieu of CRS procedural direction to start fan, then stop other fan. Which is correct method?

Event 3, C 1) Minimal actions for ATC, but there are at least two required steps.

Event 4, C 1) Does HPCI remain available? Is there any 1) HPCI remains available but inop. It is not chance that the crew would isolate HPCI at anticipated that crew would isolate HPCI.

this point?

2) Reword field report on Turning Gear status to 2) Revised to state that TG appears to be binding indicate that it is prevented from engaging. and not engaging.

Scenario 3 Event 2, C 1) Will crew continue to operate with CRD 1) Yes controller in MANUAL? 2) Operator must take manual control and return

2) Basically, operator responds by putting system parameters to normal.

controller in MANUAL, then restores parameters. Sufficient for C?

Event 3, C, TS 1) Clarify that operator actions will stop the leak, NOTE at beginning of event indicates that leak is slow otherwise, it would not matter what actions enough that TS limit is not expected to be reached.

operator takes because leak would not stop. Role play provides feedback that leak slows to a trickle (consistent with draining of pipe) after shutting pump suction valve and that operator will continue to monitor to ensure that leak is isolated.

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NRC ILE Operating Test Submittal Comments Dresden Nuclear Power Station, Units 2 and 3 Operating Test Exam Date Weeks of 08/06 and 13/2012 Chief Examiner Comment Facility Action/Response Events 5&6 1) This can only be counted as one Major Event Will be counted as only one Major Event.

2) There is no substantive EOP actions. The operators simply pass through DEOP 100 on a. RPV level does drop due to loss of all feed the way to DEOP 400-5 (initiating event)

a. With minimum steam flow, RPV level b. EOP actions (restore RPV level and stabilize may not drop below RPV L3 and with RPV pressure) occur after control rods are power <6%, there may not be any inserted and ATWS contingency is exited.

entry conditions for DEOP 100.

b. DGP 2-03 directs entry into DEOP 100, but still no substantive actions are required.

Scenario 4 This scenario is now Scenario 1.

Event 1, C 1) Restructure so the initiating cue is the 1) Revised as suggested.

TBCCW Press Lo alarm rather than the field report. Retain field report as follow-up to dispatch of field operator to investigate.

Event 2, C 1) Typo in equipment number in last bullet of 1) Typo corrected.

Role Play.

Event 3, I (will 1) Due to potential for premature SCRAM, move 1) Event was moved prior to validation run.

become Event 6) event to after MPT malfunction (event 6)

Event 6, C (will 1) Provide ability to manually actuate Trigger 13 1) Added.

become Event 5) at evaluators discretion if load drop drags out.

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