ML13178A366

2013 Perry Nuclear Power Plant Initial License Examination Administrative Outline and Operating Test Comments Rev 1

ML13178A366
Person / Time
Site:	Perry
Issue date:	03/14/2013
From:	NRC/RGN-III
To:	FirstEnergy Nuclear Operating Co
Bielby, M.
Shared Package
ML11354A269	List: ML13175A081 ML13178A362 ML13178A363 ML13178A365 ML13178A366
References
Download: ML13178A366 (10)

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NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Outline Submittal Comments ES-401-4 Submitted ES-401-4, Rejected KAs, but not required until test is in final.

RO/SRO Admin JPMs Comments Radiation Control Determine radiological conditions for rescue. Is this This JPM was modified, so not P.

OT-3701- same as 2009 ILE RO Admin JPM? If so, identify as ADM_018_RO P Conduct of Make a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> NRC notification. Is this same as Added P designation to outline.

Operations 2009 ILE RO Admin JPM? If so, identify as P OT-3701-ADM_320_SRO Radiation Control Is this same as the RO admin JPM? If so, need to add SRO info was incorporated to make this SRO JPM.

OT-3701- something to make it SRO.

ADM_018_

RO/SRO CR/IP System JPMs Comments No comments.

Scenario D-1 Comments No low power No low power scenario (around 5% power). Had low The spare is a low power scenario if needed.

scenario power scenario on 2009 and 2010 ILEs (reduce submitted. predictability).

TS calls for SROs ES-301-5 requires two TS calls for SROs. Dont count related TS for same call, want separate TSs. ORMs arent TSs.

Scenario 1 Note: Recount M for ES-301-5, deleted M from Events 6 and 7.

Event 1, N-BOP Are there sufficient actions for evaluation? Not just Start sets up degradation of pump.

turn a switch and observe start.

Event 4 C-BOP What is significance of the HPCI initiation? Does the Water injected, small power change.

injection valve open?

Event 5 C-BOP Are there significant actions for evaluation? Isolate steam to SJAE, isolate O/G, plant shutdown.

Event 6 I-ATC How is this an instrument failure for the ATC? He cant Mode switch fails, hits ARI to scram.

do anything about it. Only takes compensatory actions to identify loss of level indication.

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NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Event 6 C-ATC Minimum actions for ATC to take to insert the rods. RPS failure.

Already had ATWS in Scenario 2 and 3.

Event 7 C-BOP Are there significant actions for evaluation? What is Procedure compliance competency.

significance if no action taken?

Scenario 2 Event 1, N-BOP Are there sufficient actions for evaluation? Not just turn a switch and observe start, then trip off other pump.

Event 3, C-ATC Suppose ATC does nothing, or very minimal actions? Must start CBP within 31/2 min or procedure directs What is significance of one CBP trip? plant scram (decreasing hot surge tank level)

Event 4 C-BOP Make sure there are sufficient actions for evaluation. Must start S/B NCC Pp, if not RRP temp increases.

What is significance if no action taken and the pump trips?

Event 5 C-BOP, Why are both given credit for the same failure? Which BOP shift busses; ATC position is responsible for the bus trip and restoration? ATC reset half scram, delete C Wont give TS credit for entering ORM 6.3.1 Testing Lose RP sampling-4 hr alternative method of Requirement 5. sampling.

Event 8 Not M(All), only compensatory action for the major Deleted M.

transient.

Scenario 3 Event 1, N-BOP Are there sufficient actions for evaluation? Not just More than just turn switch, must observe discharge turn a switch and observe start, then trip off other valve, stop at correct position.

pump.

Event 3, C-BOP Suppose BOP does nothing, or very minimal actions, Fan wont trip, ARP tells operator to shift fans.

what is significance? Does BOP have to start another DW cooler?

Event 4, I-ATC, Wont give TS credit for entering ORM 6.2.1. Cant ORM 6.2.1 is RC&IC (rod block); second TS is RPS.

SRO, TS-SRO take credit for a second TS for same event equipment. Add another TS. ORM=Operations Requirement Manual Event 5, C-ATC How is RRP downshift a component failure? He cant Have to insert CRAM rods.

do anything about it. What significant actions does the ATC take?

Event 6 C-ATC What is the C? ATWS? Failure to scram, OPRMs fail to scram. Have to 2 of 10

NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response initiate a scram.

Event 7 M-All, Why is this C for BOP? What significant actions does RHR A fails to initiate, will have to start with H/S.

C-BOP he take? Suppose he takes no actions, what is significance?

Event 8 M-ALL ED is a compensatory actions, not major transient. Delete M Event 9 C-BOP What is significance of the CRD pump trip and Wont be able to drive rods without CRD Pp.

recovery? Suppose BOP doesnt recover pump?

What are the significant actions taken to recover the CRD pump?

Proposed Submittal Comments RO Admin JPM Comments Conduct of Ops, Where is the Administrative component of the During validation, added questions to cues.

2.1.18 Perform task?

ATC Hourly Walkdown Conduct of Ops, Which graphs in PDB-A016 are used for in-vessel The graph labeled After Discharge of 177 Fuel 2.1.25 Determine after refueling is completed? Bundles.

Time to Boil and Core Uncovery Step #3 - What is the acceptable accuracy for 8 hrs only.

this critical step? (~8 hrs + or - What?)

Changed to 42.5-43.5 hrs.

Step #4 - The acceptable tolerance for the acceptable accuracy may be too large. (44 hrs too high; 43.5 is reasonable for graph readability.)

Equipment Is this tasking following a normal plant process? Trying to get isolation so pumps can be restarted.

Control, 2.2.41 Is the applicant actually being asked to develop a Tagout to follow.

Determine clearance (or tagout) to isolate the leak?

Necessary Isolation for Fire Protection Valve Radiation Control, Does the plant initial Rx power level need to be No.

2.3.7 Determine specified?

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NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Radiological Conditions for The first 3 steps of the JPM should be tied Revised JPM to use readings in direct path to injured Rescue directly to the tasking requirement, i.e. In the person.

vicinity of the injured person, what is the highest general area dose rate?

SRO Admin JPM Comments Conduct of Ops, This JPM is designated as Time Critical because Not Time Critical JPM.

2.1.18 Make 4- of the 4-hour reportability time limit for the valid hour Notification RPS actuation. Since the applicant will be performing only a portion of the time critical activity, with the recognition of meeting the reportability requirement and filling out only a part of the Event Notification form, and the fact that the JPM validated time was 20 minutes, this is not a Time Critical JPM.

The fact that the initiating cue tells the applicant Revised Cue: assess the situation and perform the to evaluate the plant conditions for reportability required activities.

may be cueing the applicant to the correct answer of the first critical step.

Equipment Establish that the plant is in Mode 1 as an initial Initial Conditions changed to establish that the plant is Control, 2.2.41 condition and then let the applicant decide proper in Mode 1. Deleted Step 4 cue.

Determine required actions without a Cue to the applicant Necessary in Step 4.

Isolation for Fire Protection Valve and Evaluate Impact Emergency Plan, The Initial Conditions need to clearly state Modified Initial Conditions to be 2 cues.

2.4.38 Perform whether or not this is the initial classification for Classification and the event, and if so, when (ie, timeline) the If Necessary, indications were available to the crew for Notification 4 of 10

NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response exceeding an EAL threshold (i.e. Site Area based upon RPV level). If this will be the initial Emergency Declaration if must be made within 15 minutes of the indications being available, not 15 minutes from when the initial conditions are read.

RO/SRO CR/IP System JPM Comments Sim a OT-3701- This ALT Path may not be very discriminating Modified JPM to require applicant to increase drive C11_513; since the scenario has the applicant remain in the water pressure in addition to double-clutching.

Withdraw Control same procedure, simply double clutch vice Rods adjusting Drive Pressure, and is terminated as soon as the rod moves following the first attempt.

This would be more discriminating if the applicant is required to adjust Drive Pressure and then required to subsequently lower the Drive Pressure prior to attempting to move another gang step.

Evaluator should wait for the applicant to Modified cue to do this.

recommend using Alternate Controls before providing direction.

What is the required action if double clutching Added note to step 11 regarding FTI-B0002.

results in overshooting required notch position?

The initial conditions are different on the Cue Matched Initial Conditions to cue sheet.

Sheet than stated in the Setup Sheet.

Sim b. OT-3701- What makes this a New JPM? EOP SPI 6.6 is a new procedure, created in June of E51_006 Lineup 2012. Licensee did not have a JPM covering this RCIC to control previously.

RPV level per EOP-SPI 6.6 5 of 10

NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response SPI 6.6 Sim c. OT-3701- What makes this a New JPM? EOP SPI 6.6 is a new procedure, created in June of B21_009 Open 2012. Licensee did not have a JPM covering this MSIVs previously.

Step 4 of JPM: When and why would N22-F455 1N22-F455 is closed IAW IOI-0003, Power Changes (our at power integrated operating procedure) and already be shut?

would not be normally opened until depressurizing the RPV in IOI-0004, Shutdown.

Sim d. OT-3701- Why is this an ALT Path JPM? The scenario has Deviation from Normal mode, SDC is required, and E12_506 Re- the applicant remain in the same procedure, even the applicant needs to select the correct subsection of establish SDC the same section of the procedure. the procedure.

(Cueing) The cue to secure the running RHR Revised cue to force applicant to make decision.

pump should only be given if the applicant recommends the action due to the P&L limit of 8 seconds max at shutoff head. (This is a critical step and we should not be telling the applicant how to complete it successfully.)

Step 7 of JPM: Need to see the Attachment 42 to Will have Att 42 filled in ahead of time and given to understand why this could not be accomplished the applicant as part of the cue.

by the applicant. Even during an emergency, the applicant should ensure pre-start data is obtained if conditions permit. (Maybe simply cueing the applicant that another RO has completed recording pre-start data is adequate, but it still needs to be done prior to starting the pump.)

Again, the initial conditions are different on the Corrected.

Cue Sheet than stated in the Setup Sheet.

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NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Sim e. OT-3701- Again, this is not a discriminating ALT Path? The Modified JPM to do Normal or Emergency shutdown R43_501 scenario has the applicant direct the operator in upon discovery of failure to auto trip Shutdown Div. 2 the plant to take one action to open an electrical Diesel Generator disconnect, and then the JPM is cued as complete once the action is reported complete.

The applicant does not have any manipulations to perform as part of the alternate path. (As a minimum, does the Unit Available Light go out in the simulator and should the applicant observe this to ensure that the ordered action produces the required effect?)

Why is the Reactor Operator doing this evolution RO is generic term, we use ATC, BOP and FS for and not the Balance of Plant Operator? What are Perry. JPM is independent of plant initial conditions.

the plant initial conditions?

Changed task to eliminate to Standby.

Why is the Task to shutdown the SBDG to Standby Readiness (Remote) and the Task Standard to shutdown the SBDG to Standby Readiness from the control room and then put in PTL? (Conflicting?) Also, the initial conditions are not reasonable if the SBDG is properly unloaded following the maintenance run. (Speed and voltage should be higher than as found.

Sim f. OT-3701- Why must this JPM be performed in the Control Changed to simulator.

D17-001 Startup room?

DW ARM JPM Step 7 should have a second part added to Modified as suggested.

have the applicant correctly verify that no alarms are present so that the next step (Step 8) for the IV may be identified as required.

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NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Sim g. OT-3701- JPM Step 1 states that the applicant will contact Corrected.

P41-001 Shift an NLO to perform procedure step 7.1.2; is that Service Water the correct procedure step? Should it be 7.1.1.a?

Pumps (Editing)

Sim h. OT-3701- JPM Step 1 - If the A train is tagged out, should Yes M25-501 Shift CR M25-S7 actually be repositioned?

Ventilation to ER JPM Step 2 - Why wouldnt the applicant initially He would ask the US for direction to perform place the B train Initiate Switch to STOP? Supplemental Actions.

IP i. OT-3701-P54- Again, same question about discriminating ALT Replaced JPM.

502 Emergency Path. JPMs should have realistic initial Run of Motor Fire conditions and tasking, i.e., if the Motor Fire Pump Pump did not start with lowering fire header pressure, wouldnt the control room try to start it and then when it trips, call someone to go perform an emergency start? This JPM may then become too simple to be used on an exam.

If this JPM is written as an ALT Path, and the Motor Fire Pump will always trip after 10 seconds if started using the START push button on H13-P970, why is JPM Step 1 a Critical Step?

If JPM Step 1 is not a Critical Step, then the JPM only has 1 simple, single action, Critical Step, and is no longer acceptable.

IP j. OT-3701-T23- This is the RCA In-Plant JPM. Replaced JPM.

004 Containment All 4 of the JPM Steps (steps are mis-numbered Closure and there are only 4) are written as Critical Steps, with the indicated cues stating that all airlocks, doors, floor hatches, and shield blocks 8 of 10

NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response are as found upon verification. If the plant is on-line when this JPM is performed, there will not be any required actions by the applicant, therefore no Critical Steps. The JPM becomes unacceptable as written.

IP k. OT-3701- This JPM is designated as Time Critical because Add to cue that SBO occurred 2 hrs 15 min ago.

R10-303 Shed off-normal procedure ONI-R10 requires the load Non-essential shed be accomplished within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Since the Divisional Loads applicant will be performing only a portion of ONI-R10, with other personnel doing other parts, and the JPM validated time was 26 minutes, this is not a Time Critical JPM.

How is the applicant assessed on identifying the Added additional step.

non-essential divisional bus loads such that the required tasking is complete prior to ending the JPM? (Procedure Steps 1.9 - 1.13)

Scenario D-1, D-2 Comments Scenario 1 Event 3, C-BOP, Does the D-2 need documentation of expected Added documentation.

TS SRO actions for evaluating TS LCO entry?

Event 7, C-BOP Does not provide enough response by the Added 3 more SRV failures.

applicant to be a creditable C failure.

Critical Task 2 Are at least 2 SRVs enough for satisfying an 5 per EOP bases.

ED event?

Critical Task 3 How long will it take to inject to the RPV to get Approximately 8 min.

level above the MSLs? (Noted by RPV pressure increase of 10# and SRV temp lowering)

Scenario 2 Event 6, M-All; C- What is RD? Should be ED? (Last page- Corrected.

BOP Editing) 9 of 10

NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response Event 8 Is this really separate from Event #7? Added LPCS start failure to Term/Prev in Event 6.

Scenario 3 Event 3, TS Does the D-2 need documentation of expected Added clarification of expected actions.

SRO actions for evaluating TS LCO entry?

Does the described action constitute a C failure No.

for the BOP?

Event 4, C-BOP Does the D-2 need documentation of expected Added documentation.

SRO actions for evaluating TS LCO entry?

Critical Task 6 Why is this a critical task? Critical for adequate core cooling.

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