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| issue date = 04/03/2017
| issue date = 04/03/2017
| title = 2017 Fer Ile Administrative Files Outline and Operating Test Comments
| title = 2017 Fer Ile Administrative Files Outline and Operating Test Comments
| author name = Bielby M E
| author name = Bielby M
| author affiliation = NRC/RGN-III/DRS/OB
| author affiliation = NRC/RGN-III/DRS/OB
| addressee name =  
| addressee name =  
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{{#Wiki_filter:NRC ILE Outline and Operating Test Submittal Comments 201 7 FER Power Plant, Unit 2 1 of 5    Outline Submittal Comments RO Administrative JPMs Chief Examiner Comment Facility Action/Response COO1: JP-OP-802-4101-446; Complete Mode 4 Shiftly/Daily Surveillances Was this surveillance administered on either of the previous 2 NRC exams (2013, 2015) or the audit exam?
{{#Wiki_filter:NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Outline Submittal Comments RO Administrative JPMs                 Chief Examiner Comment                         Facility Action/Response COO1: JP-OP-802-4101-446;         Was this surveillance administered on either  This surveillance is new and was not Complete Mode 4 Shiftly/Daily     of the previous 2 NRC exams (2013, 2015)       administered on either of the previous 2 NRC Surveillances                    or the audit exam?                            or audit exams.
This surveillance is new and was not administered on either of the previous 2 NRC or audit exams
COO2: JP-OP-802-4101-450;         Both the RO and SRO perform same COO2         As validated, the original Admin JPM validated Determine the Availability of RPV admin JPM. Please replace at least one         poorly and would take at least an hour to Level Instruments                admin JPM such that one is SRO and the         perform. Replaced with JP-OP-802-4101-431; other RO.                                      Perform Core Performance Parameter Check.
. COO2: JP-OP-802-4101-4 50; Determine the Availability of RPV Level Instruments Both the RO and SRO perform same COO2 admin JPM. Please replace at least one admin JPM such that one is SRO and the other RO. As validated, the original Admin JPM validated poorly and would take at least an hour to perform. Replaced with JP-OP-802-4101-431; Perform Core Performance Parameter Check.
EC: 802-4101-441; Identify                                                       Replaced with JP-OP-802-4101-452; Identify Isolation Boundaries for a                                                      Isolation Boundaries for Steam Leak. Based on Clearance to Replace Pump                                                        feedback from validation crew.
EC: 802-4101-441; Identify Isolation Boundaries for a Clearance to Replace Pump Impeller  Replaced with JP-OP-802-4101-452; Identify Isolation Boundaries for Steam Leak. Based on feedback from validation crew.
Impeller RC: JP-OP-802-4101-416; Enter     Both the RO and SRO perform same RC           Replaced with 802-4101-416; Determine and Exit a Contaminated Area      admin JPMs. Please replace at least one       Dose and Complete a Red Card. Original admin JPM such that one is SRO and the         JPM would be difficult to perform during plant other RO.                                      outage.
RC: JP-OP-802-4101-4 1 6; Enter and Exit a Contaminated Area Both the RO and SRO perform same RC admin JPMs.
SRO Administrative JPMs               Chief Examiner Comment                         Facility Action/Response COO1: JP-OP-802-4101-440;         Was this surveillance administered on either  1) This surveillance is new and was not Complete Mode 5 Shiftly/Daily     of the previous 2 NRC exams (2013, 2015)       administered on either of the previous 2 NRC Surveillances                    or the audit exam?                            or audit exams.
Please replace at least one admin JPM such that one is SRO and the other RO. Replaced with 802
: 2) Modified to JP-OP-802-4101-440; Review Mode 5 Shiftly/Daily Surveillances (PMT).
-4101-416; Determine Dose and Complete a Red Card.
Determination of component operability is more of an SRO function, and also reduces steps from 35 to 6 (decrease JPM time).
Original JPM would be difficult to perform during plant outage. SRO Administrative JPMs Chief Examiner Comment Facility Action/Response COO1: JP-OP-802-4101-44 0; Complete Mode 5 Shiftly/Daily Surveillances Was this surveillance administered on either of the previous 2 NRC exams (2013, 2015) or the audit exam?
COO2: JP-OP-802-4101-450;         Both the RO and SRO perform same COO2         As validated, the original Admin JPM Determine the Availability of RPV admin JPM. Please replace at least one         validated poorly and would take at least an Level Instruments                admin JPM such that one is SRO and the         hour to perform. Replaced with JP-OP-802-other RO.                                      4101-431; Perform Core Performance Parameter Check.
: 1) This surveillance is new and was not administered on either of the previous 2 NRC or audit exams
1 of 5
. 2) Modified to JP-OP-802-4101-440; Review Mode 5 Shiftly/Daily Surveillances (PMT). Determination of component operability is more of an SRO function
, and also reduce s steps from 35 to 6 (decrease JPM time).
COO2: JP-OP-802-4101-4 50; Determine the Availability of RPV Level Instruments Both the RO and SRO perform same COO2 admin JPM. Please replace at least one admin JPM such that one is SRO and the other RO. As validated, the original Admin JPM validated poorly and would take at least an hour to perform.
Replaced with JP-OP-802-4101-431; Perform Core Performance Parameter Check.


NRC ILE Outline and Operating Test Submittal Comments 201 7 FER Power Plant, Unit 2 2 of 5  RC: JP-OP-802-4101-4 1 6; Enter and Exit a Contaminated Area Both the RO and SRO perform same RC admin JPMs. Please replace at least one admin JPM such that one is SRO and the other RO. Replaced with 802
NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 RC: JP-OP-802-4101-416; Enter Both the RO and SRO perform same RC           Replaced with 802-4101-435; Notify Hospital and Exit a Contaminated Area  admin JPMs. Please replace at least one       of Contaminated Injured Worker. Original admin JPM such that one is SRO and the         JPM would be difficult to perform during plant other RO.                                      outage.
-4101-435; Notify Hospital of Contaminated Injured Worker.
Scenario ES D-1               Chief Examiner Comment                           Facility Action/Response Scenario 1                   Scenario 1 is similar to 2013-1 exam scenario. It was significantly modified.
Original JPM would be difficult to perform during plant outage. Scenario ES D
(ES-301, Section D.5.b). Or was it a spare on 2013 exam?
-1 Chief Examiner Comment Facility Action/Response Scenario 1 Scenario 1 is similar to 2013
2 of 5
-1 exam scenario. (ES-301, Section D.5.b). Or was it a spare on 2013 exam?
 
It was significantly modified
NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Operating Test Submittal Comments RO/SRO Admin JPMs Comments Chief Examiner Comment                                 Facility Action/Response RO Admin A1.2             JPM Step 2 (16.b.2(b)), Verify.. is not critical. Revised.
.
COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check RO Admin A2              Update forms to use current revisions.               Recent revision change, updated.
NRC ILE Outline and Operating Test Submittal Comments 201 7 FER Power Plant, Unit 2 3 of 5    Operating Test Submittal Comments   RO/SRO Admin JPMs Comments   Chief Examiner Comment Facility Action/Response RO Admin A1.2 COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check JPM Step 2 (16.b.2(b)), "Verify-.." is not critical.
EC: JPM-802-4101-452; Identify Isolation Boundaries for Steam Leak.
Revised. RO Admin A2 EC: JPM-802-4101-452; Identify Isolation Boundaries for Steam Leak. Update forms to use current revisions.
RO Admin A3            Change JPM to increase accumulated dose for the JPM modified as described. No change to JPM RC JPM 802-4101-416;    year to 1753 mr to allow use of the original survey map steps, only calculation values.
Recent revision change, updated.
Determine Dose and      with much lower dose values to make the JPM more Complete a Red Card    believable. JPM was changed from original submittal because the Fermi 2 administrative limit was changed to 2 mr.
RO Admin A3 RC JPM 802-4101-416; Determine Dose and Complete a Red Card Change JPM to increase accumulated dose for the year to 1753 mr to allow use of the original survey map with much lower dose values to make the JPM more believable. JPM was changed from original submittal because the Fermi 2 administrative limit was changed to 2 mr. JPM modified as described. No change to JPM steps, only calculation values.
SRO Admin A1.2           JPM Step 2 (16.b.2(b)), Verify.. is not critical. Revised.
SRO Admin A1.2 COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check JPM Step 2 (16.b.2(b)), "Verify-.." is not critical.
COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check 3 of 5
Revised.
 
NRC ILE Outline and Operating Test Submittal Comments 201 7 FER Power Plant, Unit 2 4 of 5      RO/SRO CR/IP System JPMs Comments   Chief Examiner Comment Facility Action/Response Chief Examiner Comment Facility Action/Response SIM JPM S7(g) JP-OP-802-4101-445; SRM/IRM Overlap Verification and SRM Withdrawal During Startup Incorporate critical JPM Step 3 into Step 2 and make Step 2 critical. Renumber JPM steps accordingly.
NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 RO/SRO CR/IP System JPMs Comments Chief Examiner Comment                                   Facility Action/Response Chief Examiner Comment                                   Facility Action/Response SIM JPM S7(g)       Incorporate critical JPM Step 3 into Step 2 and make    Lic: Incorporated.
Lic: Incorporated.
JP-OP-802-4101-     Step 2 critical. Renumber JPM steps accordingly.
SIM JPM S8(h)  JP-OP-315-0166-002; Restore RBHVAC to Operation After Auto Isolation JPM Steps 3 and 4 not critical.
445; SRM/IRM Overlap Verification and SRM Withdrawal During Startup SIM JPM S8(h)        JPM Steps 3 and 4 not critical.                         Lic: Incorporated.
Lic: Incorporated.
JP-OP-315-0166-002; Restore RBHVAC to Operation After Auto Isolation IP JPM P3(k)         NRC: In-Plant Systems JPM (k) JP-OP-315-0167-           Lic: The change was based on the ALARA principle 005,Shift RBCCW Supplemental Cooling Chilled Water     that during licensee validation 3 radiological hot to Mode 2 was changed to Adjust Chilled Water         spots were identified in the area of the JPM and Temperature Set-point.                                during JPM performance significant dose could be obtained.
IP JPM P3(k) NRC: In-Plant Systems JPM (k) JP
4 of 5
-OP-315-0167-005,"Shift RBCCW Supplemental Cooling Chilled Water to Mode 2" was changed to "Adjust Chilled Water Temperature Set
 
-point". Lic: The change was based on the ALARA principle that during licensee validation 3 radiological hot spots were identified in the area of the JPM and during JPM performance significant dose could be obtained.
NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Scenario Comments Chief Examiner Comment                                       Facility Action/Response Scenario 1         1. Incorporate Events 3 and 4 into Event 2 and              1. Incorporated Events 3 and 4 into Event 2 and renumber events.                                            renumbered events.
NRC ILE Outline and Operating Test Submittal Comments 201 7 FER Power Plant, Unit 2 5 of 5    Scenario Comments   Chief Examiner Comment Facility Action/Response Scenario 1   1. Incorporate Events 3 and 4 into Event 2 and renumber events.
: 2. Event 5, add TS condition.                              2. Added TS condition to Event 5 (now Event 3).
: 2. Event 5
: 3. Event 7, add TS condition, move CT 1, RPV-               3. Added TS condition to Event 7 (now Event 5).
, add TS condition.
LEVEL, to Event 10, Drywell Leak.                          Moved CT 1 to new Event 7 (Drywell Leak).
: 3. Event 7, add TS condition, move CT 1, RPV-LEVEL, to Event 10, Drywell Leak
: 4. Event 9, rename CT 2, RPV-ED, and move to               4. Renamed and moved CT 2 to new Event 7 Event 10, Drywell Leak.                                    (Drywell Leak).
. 4. Event 9, rename CT 2, RPV-ED, and move to Event 10, Drywell Leak.
: 5. Event 10, rename CT 3, RPV-TAF.                         5. Renamed CT 3, now part of new Event 7.
: 5. Event 10, rename CT 3, RPV
: 6. Event 10, rename CT 4, PC-DWS, and move to               6. Renamed CT 4, now part of new Event 8.
-TAF. 6. Event 10, rename CT 4, PC
Event 12. Delete CT 5.                                     Deleted CT 5.
-DWS, and move to Event 12. Delete CT 5.
Scenario 2         1. Event 2, add conditions to each of the 4 TSs.           1. Added conditions to TSs, incorporated Event 3 Combine Event 3 into Event 2.                              into Event 2, and renumbered events.
: 1. Incorporated Events 3 and 4 into Event 2 and renumbered events.
: 2. Event 5, delete CT 1 to reduce power with CRAM           2. Deleted CT 1 for Event 5 (new Event 4).
: 2. Added TS condition to Event 5 (now Event 3).
Array rods.                                                 3. Incorporated comment (now CT 1, ATWS-ADS,
: 3. Added TS condition to Event 7 (now Event 5). Moved CT 1 to new Event 7 (Drywell Leak). 4. Renamed and moved CT 2 to new Event 7 (Drywell Leak).
: 3. Relabel CT 2 as CT 1, ATWS-ADS.                         new Event 5).
: 5. Renamed CT 3, now part of new Event 7.
: 4. Relabel CT 3 as CT 2, ATWS-SLC.                         4. Incorporated comment (now CT 2, ATWS-SLC,
: 6. Renamed CT 4, now part of new Event
: 5. Relabel CT 4 as CT 3, ATWS-RODS.                         new Event 6).
: 8. Deleted CT 5.
: 6. Relabel CT 5 as CT 4, ATWS-T&P, and add CT 5,           5. Incorporated comment (now CT 3, ATWS-RODS, ATWS-INJ.                                                   new Event 7).
Scenario 2   1. Event 2, add conditions to each of the 4 TSs. Combine Event 3 into Event  
: 6. Incorporated comment (now CT 4, ATWS-T&P, and CT 5, ATWS-INJ, new Event 8).
: 2. 2. Event 5, delete CT 1 to reduce power with CRAM Array rods.
Scenario 3         1. Event 2, change event to have rod drift out, vices, into 1. Incorporated comment.
: 3. Relabel CT 2 as CT 1, ATWS
the core. More significant reactivity event, but will lose 2. Incorporated comment.
-ADS. 4. Relabel CT 3 as CT 2, ATWS
the TS.                                                     3. Incorporated comment.
-SLC. 5. Relabel CT 4 as CT 3, ATWS
: 2. Incorporate Event 4 into Event 3 and renumber Events. Add condition to TR.
-RODS. 6. Relabel CT 5 as CT 4, ATWS
-T&P, and add CT 5, ATWS-INJ. 1. Added conditions to TSs, incorporated Event 3 into Event 2, and renumbered events.
: 2. Deleted CT 1 for Event 5 (new Event 4).
: 3. Incorporated comment (now CT 1, ATWS
-ADS,  new Event 5).
: 4. Incorporated comment (now CT 2, ATWS
-SLC,  new Event 6).
: 5. Incorporated comment (now CT 3, ATWS
-RODS,  new Event 7).
: 6. Incorporated comment (now CT 4, ATWS
-T&P, and CT 5, ATWS
-INJ, new Event 8).
Scenario 3   1. Event 2, change event to have rod drift out, vices, into the core. More significant reactivity event, but will lose the TS. 2. Incorporate Event 4 into Event 3 and renumber Events. Add condition to TR.
: 3. Event 5, delete TS.
: 3. Event 5, delete TS.
: 1. Incorporated comment.
5 of 5}}
: 2. Incorporated comment.
: 3. Incorporated comment.}}

Latest revision as of 00:12, 30 October 2019

2017 Fer Ile Administrative Files Outline and Operating Test Comments
ML17214A104
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/03/2017
From: Bielby M
Operations Branch III
To:
NRC/RGN-III/DRS/OLB
Shared Package
ML17061A771 List:
References
Download: ML17214A104 (3)


Text

NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Outline Submittal Comments RO Administrative JPMs Chief Examiner Comment Facility Action/Response COO1: JP-OP-802-4101-446; Was this surveillance administered on either This surveillance is new and was not Complete Mode 4 Shiftly/Daily of the previous 2 NRC exams (2013, 2015) administered on either of the previous 2 NRC Surveillances or the audit exam? or audit exams.

COO2: JP-OP-802-4101-450; Both the RO and SRO perform same COO2 As validated, the original Admin JPM validated Determine the Availability of RPV admin JPM. Please replace at least one poorly and would take at least an hour to Level Instruments admin JPM such that one is SRO and the perform. Replaced with JP-OP-802-4101-431; other RO. Perform Core Performance Parameter Check.

EC: 802-4101-441; Identify Replaced with JP-OP-802-4101-452; Identify Isolation Boundaries for a Isolation Boundaries for Steam Leak. Based on Clearance to Replace Pump feedback from validation crew.

Impeller RC: JP-OP-802-4101-416; Enter Both the RO and SRO perform same RC Replaced with 802-4101-416; Determine and Exit a Contaminated Area admin JPMs. Please replace at least one Dose and Complete a Red Card. Original admin JPM such that one is SRO and the JPM would be difficult to perform during plant other RO. outage.

SRO Administrative JPMs Chief Examiner Comment Facility Action/Response COO1: JP-OP-802-4101-440; Was this surveillance administered on either 1) This surveillance is new and was not Complete Mode 5 Shiftly/Daily of the previous 2 NRC exams (2013, 2015) administered on either of the previous 2 NRC Surveillances or the audit exam? or audit exams.

2) Modified to JP-OP-802-4101-440; Review Mode 5 Shiftly/Daily Surveillances (PMT).

Determination of component operability is more of an SRO function, and also reduces steps from 35 to 6 (decrease JPM time).

COO2: JP-OP-802-4101-450; Both the RO and SRO perform same COO2 As validated, the original Admin JPM Determine the Availability of RPV admin JPM. Please replace at least one validated poorly and would take at least an Level Instruments admin JPM such that one is SRO and the hour to perform. Replaced with JP-OP-802-other RO. 4101-431; Perform Core Performance Parameter Check.

1 of 5

NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 RC: JP-OP-802-4101-416; Enter Both the RO and SRO perform same RC Replaced with 802-4101-435; Notify Hospital and Exit a Contaminated Area admin JPMs. Please replace at least one of Contaminated Injured Worker. Original admin JPM such that one is SRO and the JPM would be difficult to perform during plant other RO. outage.

Scenario ES D-1 Chief Examiner Comment Facility Action/Response Scenario 1 Scenario 1 is similar to 2013-1 exam scenario. It was significantly modified.

(ES-301, Section D.5.b). Or was it a spare on 2013 exam?

2 of 5

NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Operating Test Submittal Comments RO/SRO Admin JPMs Comments Chief Examiner Comment Facility Action/Response RO Admin A1.2 JPM Step 2 (16.b.2(b)), Verify.. is not critical. Revised.

COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check RO Admin A2 Update forms to use current revisions. Recent revision change, updated.

EC: JPM-802-4101-452; Identify Isolation Boundaries for Steam Leak.

RO Admin A3 Change JPM to increase accumulated dose for the JPM modified as described. No change to JPM RC JPM 802-4101-416; year to 1753 mr to allow use of the original survey map steps, only calculation values.

Determine Dose and with much lower dose values to make the JPM more Complete a Red Card believable. JPM was changed from original submittal because the Fermi 2 administrative limit was changed to 2 mr.

SRO Admin A1.2 JPM Step 2 (16.b.2(b)), Verify.. is not critical. Revised.

COO2: JP-OP-802-4101-431; Perform Core Performance Parameter Check 3 of 5

NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 RO/SRO CR/IP System JPMs Comments Chief Examiner Comment Facility Action/Response Chief Examiner Comment Facility Action/Response SIM JPM S7(g) Incorporate critical JPM Step 3 into Step 2 and make Lic: Incorporated.

JP-OP-802-4101- Step 2 critical. Renumber JPM steps accordingly.

445; SRM/IRM Overlap Verification and SRM Withdrawal During Startup SIM JPM S8(h) JPM Steps 3 and 4 not critical. Lic: Incorporated.

JP-OP-315-0166-002; Restore RBHVAC to Operation After Auto Isolation IP JPM P3(k) NRC: In-Plant Systems JPM (k) JP-OP-315-0167- Lic: The change was based on the ALARA principle 005,Shift RBCCW Supplemental Cooling Chilled Water that during licensee validation 3 radiological hot to Mode 2 was changed to Adjust Chilled Water spots were identified in the area of the JPM and Temperature Set-point. during JPM performance significant dose could be obtained.

4 of 5

NRC ILE Outline and Operating Test Submittal Comments 2017 FER Power Plant, Unit 2 Scenario Comments Chief Examiner Comment Facility Action/Response Scenario 1 1. Incorporate Events 3 and 4 into Event 2 and 1. Incorporated Events 3 and 4 into Event 2 and renumber events. renumbered events.

2. Event 5, add TS condition. 2. Added TS condition to Event 5 (now Event 3).
3. Event 7, add TS condition, move CT 1, RPV- 3. Added TS condition to Event 7 (now Event 5).

LEVEL, to Event 10, Drywell Leak. Moved CT 1 to new Event 7 (Drywell Leak).

4. Event 9, rename CT 2, RPV-ED, and move to 4. Renamed and moved CT 2 to new Event 7 Event 10, Drywell Leak. (Drywell Leak).
5. Event 10, rename CT 3, RPV-TAF. 5. Renamed CT 3, now part of new Event 7.
6. Event 10, rename CT 4, PC-DWS, and move to 6. Renamed CT 4, now part of new Event 8.

Event 12. Delete CT 5. Deleted CT 5.

Scenario 2 1. Event 2, add conditions to each of the 4 TSs. 1. Added conditions to TSs, incorporated Event 3 Combine Event 3 into Event 2. into Event 2, and renumbered events.

2. Event 5, delete CT 1 to reduce power with CRAM 2. Deleted CT 1 for Event 5 (new Event 4).

Array rods. 3. Incorporated comment (now CT 1, ATWS-ADS,

3. Relabel CT 2 as CT 1, ATWS-ADS. new Event 5).
4. Relabel CT 3 as CT 2, ATWS-SLC. 4. Incorporated comment (now CT 2, ATWS-SLC,
5. Relabel CT 4 as CT 3, ATWS-RODS. new Event 6).
6. Relabel CT 5 as CT 4, ATWS-T&P, and add CT 5, 5. Incorporated comment (now CT 3, ATWS-RODS, ATWS-INJ. new Event 7).
6. Incorporated comment (now CT 4, ATWS-T&P, and CT 5, ATWS-INJ, new Event 8).

Scenario 3 1. Event 2, change event to have rod drift out, vices, into 1. Incorporated comment.

the core. More significant reactivity event, but will lose 2. Incorporated comment.

the TS. 3. Incorporated comment.

2. Incorporate Event 4 into Event 3 and renumber Events. Add condition to TR.
3. Event 5, delete TS.

5 of 5