ML102520054

Post Exam Comments and Technical References (Folder 1)

ML102520054
Person / Time
Site:	Ginna
Issue date:	07/16/2010
From:	Geckle M Constellation Energy Nuclear Group, Ginna
To:	Todd Fish Operations Branch I
Hansell S
Shared Package
ML092470059	List: IR 05000244/2010301 ML100400205 ML101680575 ML101720347 ML101720553 ML101720560 ML101720564 ML102320373 ML102320386 ML102320393 ML102320408 ML102520045 ML102520054 ML102710006
References
TAC U01766
Download: ML102520054 (11)

Text

Mark Geckle Training Manager R.E. Ginna Nuclear Power Plant, LLC CENG a joint venture o f - - - - - - - - ,

1503 Lake Road Ontario, New York 14519-9364 585.771 .5214 Mark.Geckle@cengllc.com Constellation .f~ eDF Energy- YI~

July 16, 2'010

.-

Mr. Todd Fish ,

Division of Reactor Safety "

1 U.S. Nuclear Regulatory Commission 1-"0 475 Allendale Road King of Prussia, PA 19406-1415

Subject:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Written Examination Challenges

Dear Mr. Fish,

Enclosed please find material to clarify the Job Performance Measure (JPM) with identification number JPM-N-D . The additional material is included to clarify the position that an Anticipated Transient Without Scram (ATWS) during a Control Room Evacuation is outside the design basis of the procedure.

Also, after additional consulting with Subject Matter Experts and Operations Department and discussions between you and R. E. Ginna Training Supervision, we would like to rescind challenges to written exam questions 14, 24 and 84. We also contend question 75 incorrectly identifies '8' as the correct answer vice

'D'. We still challenge question 12 on the basis both 'A' and 'C' are correct answers and contend question 55 incorrectly identifies 'D' as the correct answer vice '8.'

If you have any questions or comments, please contact the General Supervisor, Operations Training, Kyle Garnish at (585) 771-5321 or via e-mail atKyle.Garnish@cengllc.com.

~Y~

Mark Geckle Attachments (1)

Attachments Enclosed (1)

Background document for AP-CR.1

R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 CENG a joint venture o f - -- - -"-J Constellation ..... eDF Energy" -4~

July 9,2010 Mr. Todd Fish Division of Reactor Safety U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415

Subject:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 2010 License Exam - JPM Clarification

Dear Mr. Fish,

Ginna has four (4) off-normal procedures which contain Immediate Actions (lAs). Three Emergency Operating Procedures contain Immediate Actions: E-O, Reactor Trip or Safety Injection; ECA-O.O, Loss of All AC Power; and FR-S .1, Response to Reactor Restart/ATWS - all of which are part of the Westinghouse Emergency Response Guideline procedures. AP-CR.1, Control Room Inaccessibility, is the only Ginna Abnormal Procedure containing Immediate Actions. In the past (-1989-1990), numerous other Abnormal Procedures also contained lAs, but because of the requirement that lAs be recalled from memory, it was determined that an unnecessary burden was being placed on the licensed operators to recall so many Abnormal Procedural actions from memory, and with the procedures readily available in the Control Room, the lAs were deleted from all Abnormal Procedures except AP-CR.1 .

The requirement to trip the reactor and turbine prior to exiting the Control Room, via AP-CR.1, steps 1 and 2 were still assigned Immediate Action status. In retrospect, given the lower priority of Abnormal Procedures vs . EOPs, and the availability of the procedure to the crew to perform the intended actions, the justification for having these steps at Ginna as immediate actions is indeterminate and deemed unnecessarily conservative.

While the simulator JPM administered during the recent operating exam required that the candidate perform the Immediate Actions of AP-CR.1 as they currently read, the probability of (a) toxic gas entering the Control Room + (b) failure of the reactor to trip + (c) inability to de

"

energize the MG sets by opening the Bus 13 & 15 supply breakers, challenges whether these are actions required of an Abnormal Procedure in a singular toxic gas event or more appropriately belong in E-O and FR-S.1 procedural space - which were the actions taken by a number of the candidates.

Furthermore, it is of the opinion of Operations that without additional cueing in our JPM , the operators found themselves in an area which they had to determine what path to take; that is, insert negative reactivity into the core or continue to evacuate the Control Room . It appears that many of the candidates believed that the immediate hazard had passed and chose to perform actions consistent with FR-S.1 (inserted negative reactivity).

A PCR has been submitted to remove the Immediate Action status of the steps in Abnormal Procedure AP-CR.1 , and an evaluation will be performed as to the need to include RNO actions in this particular fire/toxic gas evacuation procedure.

If you have any questions or comments, please contact the General Supervisor, Operations Training , Kyle Garnish at (585) 771-5321 or via e-mail Kyle .Garnish@CENGLLC.com .

Manager, Operations

Question 12 Plant Conditions:

• Reactor power is stable at 100% when the following alarms actuated:

o A-17, RCP 1A NO. 1 SEAL HI-LO FLOW 5.0 GPM 1.0 o B-3, RCP A STANDPIPE HI LEVEL +1 FT

• "A" RCP #1 seal leakoff is 0.9 gpm and steady

• The Head Control Operator calculated the leak rate to the RCDT to be 2.0 gpm and steady.

• The Crew entered AP-RCP.1, RCP SEAL MALFUNCTION Given the above plant conditions, which of the following are required actions per AP RCP .1?

A. Secure the "A" RCP in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

B. Trip the reactor and "A" RCP and close #1 seal leakoff isolation valve after 4 minutes.

C. Continue operation and increase surveillance frequency of the "A" RCP parameters.

D. Be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Original Answer Explanation:

A. Correct. Total #1 Seal Flow is defined as the sum of #1 Seal Leakoff Flow and #2 seal leak rate to the RCDT.

B. Incorrect. Plausible because the actions would be correct per AP-RCP.1 if the Total

1. 1 Seal Flow from the "A" RCP was greater than 8 GPM .

C. Incorrect. Plausible because the actions would be correct if the #3 seal failed vice the number #1 seal.

D. Incorrect. Plausible because the actions for #1 seal failure is to prepare for MODE 3, but there is not any requirement to be in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Licensee's Justification for Change AP-RCP.1 background for step 6 states that we must calculate the #2 seal leak rate based on the rate of level increase in the RCDT, since other sources of leakage to the RCDT may exist.

The question stem does not provide the initial leak rate to the RCDT. Therefore, the rate of level increase cannot be determined.

For example:

Assuming the initial leak rate into the RCDT was 2 gpm, the RCP #2 seal leak rate would =Ogpm. This would make answer "C" a correct response per AP-RCP.1 step #6.

With the absence of an initial leak rate Answer "A" or "C" could be the correct procedural response.

Regrade Request "A" and "C" should be accepted as correct responses based on AP step actions and the stem lacking adequate information to determine a leak rate.

Question Statistics C Question 12 was missed by 6 of 12 students. Answer "X' was selected by 4 of the 6 who missed it. Answer "8" was selected by 2 of the 6 who missed it.

Post Examination Review References AP-RCP.1

COP : TI TL [ :

RE'tv7

01800 AP-RCP . l RCP SEAL MALFUNCTION PAGE 4 of 11 Rli S PONSi I I ED ~I----------------~

- #2 seal fail leak determination

• ~ ~ *

• s *

• known leakage has to be factored into definition of leak size IF AN~ Re p ~ s SECU RED B E CA L S ~ OF A HE~rA R 1ED JN~IL THE CAUS~ OE THE M COR R~ C1ED .

• * * * * * * * * * ~ ~ * * * ~ * * * * ~ * ~ *

• NO'l I~ : 0 I~ a Reactor ed wh~le pe rf orming STe p 1 . t ransi~ion t o E- co ~ ple t ~ng s~bse q ue n t ac t ions of t he o F2 Seal ~eak ra~e is to~al ReDT l ea~ rate rni~us any kn ow~

in lea kage TO Re DT f r cm a~o t her sour ce .

a Toral #1 Seal Flew is ~e f inet t o r eac~ Kep as t h e Silrn o f indica t ed

>> Seal Leakoff flow a nd #2 seal ~eak rate TO ReDT (PPCS Poi nT iD 003 . 3 . 2 ga~/% i , ~he ~o [ ~al o pe r a t ing ra~ge) .

~ Check Rep J!2 Seal Indications: .Y a ll " l ed iH:1' j! II1'a1 !~akr'L ll ow . olfr,el::g . 'l'H£N f.i il u r 2 (11 N~

o A!lr.*.m~:; i.I LC L 3 "",;P it STiJt:Jrl <,, ~C:& .. ::o.i.lj' ">e i:-.rli~. a Led .

!H ~EV L +1 II'. I!..'<T ~!;GL I SIcJ!.D

!"'.'2d: at? #1 -:ea t I f'Elk I'a lela ReD1' o ':'.n~u!:ci i! tor: B t, . RCF' 3 s t A.:.DP[PE (PPCS Poin t ~~ ~l nOl. ] .! gall% i~

Po:  ;..EVIL H F'r UX f WGU1 Sbl!D lr.t! "o r aal r.' f' t?t'l :';;8 ra.::.ge) .

he total leakrate to the ReDT is 2Qi)rTi, ,5 . 1I ".tP Nl g'~ il1 lak Late to RC:JT this is .composed of the foll owing iss 1 . 1 !1.pm . :'PE' rontinue components: pla::1 0pGr;; jon whilE' clr.s!' l ','

1. 2 seal lea.koff from A Rep monitoLinR il l' ~-al i ndications .

1. 2 seal leakoff from 8 Rep b . IF dCF' ~l. Foeel l psk L dt" ' 0 RCD n ,

i s :l,t"£'a I "r: 'l r.an * . 1 ; pm . T~:

p&r .-rm the fQ~ j ow i ni .

1. 2 seal leakoff rate 0-2.0 gpm 1) P~('ra r r 101' Q~dprly pum r

~hu de*..:: :,V ?_i.l ,- i:: g t::E p~a:l l depending on leakrate from A in l-let "nunl,yon:. II°::':-./! I. -,2.1.

Rep.  ;~'F'.M.A:' SHI: nO'Ntl!O !:Ir'

!>HlT:)O a.lf leakrate > 1.1gpm b.1t leakrate < 1.1 gpm ecur~ t~E ~t l rc l EC Re p w:thi" 6 r.OU L ll .

~

5££ fst-He. t\ I ~ *',2.30 -+Or 7o \-~~(Ct..L_SD0(,.S:e.S r£ i",,-V0Q,e 'Aha ';::cc'lo.T. S <2C-+/--;OA ~\, L. . 7...3. ~ J;:;,\\DW*~C/>""I\e. .

11.2.2.3 Reactor Coolant Drain Tank and Pumps TIle reactor (Drawing 33013-1272, Sheets 1 and 2) collects all water SOlU'ces tllat are potentially tritiated, TIlis water is recycled as much as practicable to minimize tritilUll release to tlle environment. Its SOlU'ces include tlle following:

• Reactor coolant system loop drains.

• Reactor coolant ptullp No.2 sealleakoff.

• Excess letdown,

• Valve and reactor vessel flange leakoffs.

• Safety injection acctullulator drains.

• Presstu'izer relieftank drain.

• Refueling canal drains.

6 Step: Check Rep #2 seal indications Purpose: To determine if #2 seal malfunction is indicated.

Basis: Standpipe high level alarms are the most direct indication of

1. 2 seal malfunction . *If high standpipe level is noted , then other conditions are checked to help confirm the malfunction.

Additional infomlation:

The upper limit on #2 seal leak rate is from Westinghouse Product Update and Technical Bulletin information, which implies, but does not clearly state, that #2 seal leak rate above the limit warrants immediate reactor trip and Rep shutdown , similar to guidance for failure of #1 seal early in the proGedure. However, Ginna has no direct indication of ti2 seal leak rate, but must calculate the leak rate based on rate of level increase in the RCDT. Since other sources of leakage to the RCDr may exist or occur, and it may not be possible to detefl11ine the exact #2 seal leak rate, Ginna has chosen not to immediately trip the reactor, but instead to follow guidance for a controlled plant and RCP shutdown.

This provides plant staff time to evaluate Rep seal conditions and provide additional guidance if warranted.

AP-RCP.1 7 Rev. 2

f~

EO P: TITLE:

REV: 01800 AP-RCP.l RCP SEAL MALFUNCTION PAGE 8 of 11 ACTION/EXPECTED RESPONSE t---......f RESPONSE NOT OBTAINED 1-------""

NOTE: ATT-lS.l. ATTACHMENT RCP DIAGNOSTICS may be used to aid in diagnosis.

5 Check Rep Cooling: Perform the following:

o Annunciator A-7. RCP A CCW a. Verify RCP CCW supply and return RETURN HIGH TEMP OR LOW FLOW valves open.

EXTINGUISHED

• RCP A. MOV-749A and MOV-7S9A o Annunciator A-IS. RCP B CCW

• RCP B. MOV-749B and MOV-7S9B RETURN HIGH TEMP OR LOW FLOW EXTINGUISHED b. Ensure open CCW outlet valves from RCP thermal barriers.

• RCP A. AOV-7S4A

• RCP B. AOV-7S4B 6 Check RCP #2 Seal Indications: II affected RCP #1 seal leakoff flow lowering. THEN failure of #2 0 Annunciator B-3. RCP A STANDPIPE seal may be indicated.

HI LEVEL +1 FT EXTINGUISHED Check RCP #2 seal leak rate to RCDT 0 Annunciator B-4. RCP B STANDPIPE (PPCS Point ID LI003. 3.2 gal/% in HI LEVEL +1 FT EXTINGUISHED the normal operating range).

a. I I RCP #2 seal leak rate to RCDT is ~ 1.1 gpm. THEN continue plant operation while closely monitoring RCP seal indications.

b. lL RCP #2 seal leak rate to RCDT is greater than 1.1 gpm. THEN perform the following:

1) Prepare for orderly pump shutdown by placing the plant in Hot Shutdown using 0-2.1.

NORMAL SHUTDOWN TO HOT SHUTDOWN.

2) Secure the affected RCP within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.