ML20241A246
| ML20241A246 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/04/2020 |
| From: | Greg Werner Operations Branch IV |
| To: | Nebraska Public Power District (NPPD) |
| References | |
| Download: ML20241A246 (11) | |
Text
Cooper Nuclear 2020-04 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 301-7, Operating Test Review Worksheet, because the licensees operating test submittal was reviewed and overall deemed SATISFACTORY.
Scenario 1 (100% EOL):
- 1. CT #1: Since APRM Flux Hi reactor SCRAM is defeated (correct? I didnt see this documented in the setup or scenario guide but I might have missed it), remove the part of the success criteria to manually scram the RX prior to exceeding APRM auto scram setpoint, since this protective action wouldnt work anyhow. Remove this part of the discussion from the Justification section of CT. So the CT is bounded solely by preventing 25% peak to peak oscillations. Will need to include oscillation magnitude as one of the parameters we record for data retention.
Kg - Added wording that automatic scram signals are defeated in order to require the ATC to insert a manual scram to Note to Examiners on page 27. Removed references to APRM high flux from CT#1 and its justification.
- 2. Event 2: Include the English name of Procedure 4.4.1 when referenced (GENERIC TO ALL EVENTS / SCENARIOS)
Kg - Added procedure title for 4.4.1 at first mention (only) in D-2 (page 20). Also added titles at first mentions in D-2 for procedures 2.2.8, 5.3AC120, 2.4HVAC, 2.4MC-RF, 2.4RR, 2.1.5, 2.2.77, EOP-1A, EOP-3A, 2.2.69.3, 5.8, and 2.2.77.1
- 3. When you print documents to pdf, make sure you are printing in color (the scenario guides are in black and white) kg - acknowledged
- 4. Page 25 event 4 specify/highlight what procedure the ATC actions are from.
Kg - Added Performs 2.4RR Attachment 3 actions
- a. Step 1.3, which of these 2 actions will the ATC be expected to perform?
Kg - for step 1.3.1, added (crew is NOT expected to exit region by this method)
[NRC OK]
Post Validation:
- 5. Events 8 and 9 are a single event with single credit. Update quantitative values.
Kg - Combined Events 8 and 9 on D-1 page 2 and within D-2. Updated quantitative values on D-1 page 3 accordingly. Updated ES-301-5 and ES-301-6 accordingly.
- 6. Event 2 NR XMITTER failure is TS credit only, no verifiable actions.
Kg - Deleted malfunction credit for ATC for Event 2 on D-1 pages 2 and 3 and adjusted ES-301-5 and ES-301-6 accordingly.
- 7. Event 3: Proceed to next event when 1 TB Exhaust Fan placed in RUN or as directed by lead examiner.
Kg - Added Note to Examiners on page 22 stating: At Lead Examiners discretion, may proceed to Event 4 after a Turbine Building exhaust fan has been started.
- 8. Event 4, step 1.3.2 include in guide which rods and order.
Kg - Added Note to Examiners on page 25 stating: Control Rods 26-19, 26-35, 18-27, 34-27, and 10-19 must be inserted to exit the Stability Exclusion Region of the Power-to-Flow Map.
- 9. Event 6,7 page 33 Note to examiners, cooling valve permissive switch will fail requiring Kg - Corrected garbled wording in that Note to Examiners.
- 10. Event 8,9 page 38, Note to examiners, have been met when crew has commenced lowering reactor pressure Kg - Changed Note to Examiners (now on page 39) to: Scenario objectives have been met when the crew has commenced lowering reactor pressure, OR at Lead Examiners discretion.
- 11. Crit task 2 page 38, clarify the expected value of PSP.
Kg - Added expected value for PSP, approximately 25 psig, and added value of PCPL-A, 62.7 psig to CT#2 on page 38, and in other mentions of CT#2 within D-1.
Also, on page 20 added CRS and ATC actions in case the CRS directs power reduction to maintain below 2419 MWt due to FW flow perturbation that occurs when level transmitter fails high.
Scenario 2 (5% startup, BOL):
- 1. CT#1 Safety Significance: please include the quantitative value / portion of Loss of FWs contribution to CDF. Kg - Added CDF 4.35% for CT#1 Safety Significance.
- 2. Include the table of MSOT values as an attachment to the D-2 Kg - added EOP-5A Table 9 for Examiner reference
- 3. This scenario is very light on the BOP, we may want to consider this for Spare Scenario Kg - acknowledged
- 4. Event description in header for events 6,7,8,9,10 only includes description for 6.
Kg - added titles for events 7-10 to header Kg - Added titles at first mention in D-2 of procedures 2.1.1, 4.1.2, 2.1.10, 10.13, 2.4CRD, 2.4CSCS, EOP-1A, and 2.1.5
[NRC OK]
Post Validation:
- 5. Spare scenario.
- 6. Include in turnover something similar to, 6.LOG.601 checks are complete for MODE 1.
Kg - Added 6.LOG.601 checks are complete for entry into MODE 1 to turnover and ensured associated step 4.21 in Procedure 2.1.1 handout is marked complete.
- 7. Event 9 HPCI failure to auto isolate, move this to a pre-MAJOR event malfunction to better reflect when it occurs.
Kg - Moved failure of HPCI to auto isolate to before major, renumbered this as Event 6, and changed numbering of subsequent events accordingly. Modified D-2 and attributes table accordingly.
- 8. CT 2 clarify that MSOT is 195F.
Kg - Added (195°F) as MSOT in all mentions of CT#2.
- 9. Event 1, add Step 4.26 to examiner guide. Check that the steps documented in the guide are reflective of the numbering in the procedure rev the applicants will use.
Kg - Added steps 4.25 and 4.26 to D-2. Ensured step numbering consistent with Procedure 2.1.1 Rev 200 to be used by examinees.
- 10. Event 3, may need a note in examiner guide that Crew may need cue from Shift Manager to continue startup.
Kg - Added note to examiners for the Lead Examiner to direct the booth to call as Shift Manager to direct resuming control rod withdrawal, and added associated booth operator role play.
- 11. Event 4, I have a note from validation, clarify that caution 2.10 in P&L section of procedure 10.13 is the guidance requiring the crew insert the rod back to step 12.
Kg - Revised crew actions to immediately insert control rod 50-27 to intended position 12 IAW Procedure 10.13 P&L 2.10.
- 12. When crew attempted to insert rod back to 12, it double notched in to 10. Discussed clearing the error.
Kg - Added auto trigger to schedule file to delete the associated malfunction when control rod 50-27 reaches position 14 due to double-notch. Validated on simulator laptop 50-27 will then insert at normal speed to position 12.
- 13. End of scenario: and level is being restored to +3 to +54 Kg - Changed Note to Examiners on page 37 to and level is being restored to +3 to +54 Kg - Also, added note to examiners on page 18 that it takes ~3 minutes for IRMs to fully retract.
Scenario 3 (97% MOL):
- 1. Event 4: insert an examiner note about how much operators are expected to reduce power by to stabilize condenser vacuum.
Kg - Added note to Examiners stating based on validation, it is expected the CRS will direct a Rapid Power Reduction to 40 Mlbm/hr core flow, which results in power lowering to ~70%.
- 2. Event 5/6/7 Page 31 step FS/L-6: states Need to ensure that this is correct path during validation. During station validations, has this been verified yet? If so, remove note.
Kg - Removed old note. This had been verified during validation.
Kg - Added titles at first mention in D-2 of procedures 2.1.10, 2.4CRD, 2.4VAC, EOP-1A, EOP-6A, EOP-7A, EOP-3A, 2.1.5, 5.8.3, 5.8, and 2.2.69.3.
[NRC OK]
Post Validation:
- 3. Event 1, validators said crew may want/need load schedule.
Kg - Added Load Schedule to be provided crew for turnover in panel setup instructions.
- 4. CT 2 - Clarify that the intent is that Hot Shutdown Boron Weight has been injected prior to exceeding the BIIT curve HSB was approximately 54% SLC tank level.
Kg - The intent is to start SLC Pumps before exceeding BIIT, as stated in CT#2. PSTGs state the basis for SLC initiation before BIIT ensures HCTL curve will not be exceeded before the reactor is shut down by SLC injecting HSD Boron Weight. In this scenario, MSIVs close due to loss of vacuum, and Suppression Pool temperature will soon exceed the
limit depicted on the BIIT curve. The crew scrammed with SP temp ~80°F. The crew initiated SLC three minutes later; SP temperature had risen to 94°F. Within a few more minutes SP temperature exceeded the BIIT limit of 110°F at the existing power level, ~40%.
When the scenario ended, HSD Boron Weight had not yet been injected, SLC tank level was down to only 59%. Also, since we are now allowing all rods to fully insert when the ATC inserts a scram after the scram has been reset once, the CRS will direct SLC injection terminated, probably before HSD Boron Weight is injected. Changed wording of CT#2 to crew initiates SLC injection versus injects SLC.
- 5. Event 8, I have note to add details to start alternate RHR SWBP.
Kg - Added steps for starting another RHR SWBP after BOP recognizes first pump tripped.
- 6. Hydraulic ATWS: We discussed that booth can allow rods to fully insert after the 1st iteration of SCRAM-Reset-SCRAM has been completed.
Kg - Modified schedule file to delete ATWS malfunction when ATC resets scram following initial scram. Added Note to Examiners immediately preceding the first scram attempt after the scram has been reset once.
- 7. Event 1, Proceed to next event when power raised > 99%, or as directed. Important for next CT.
Kg - Revised Booth Operator instruction to Proceed to next event after power has been raised to > 99%, or as directed by Lead Examiner and added Note to Examiner at beginning of Event 1 explaining why power should be at least 99% before triggering Event 2.
- 8. Event 4, Add turbine trip steps per 2.4VAC, to event 4 or to Major.
Kg - At major event, added CRS direction to trip turbine (page 28) and BOP actions to trip turbine (page 41).
Kg - Also, repeated CT#2 (from ATC section page 34) before CRS direction to initiate SLC injection (page 30). Added detail from procedure 2.2.70 for starting RHR SWBP on page
- 46.
JPM S1:
- 1. You dont have to repeat 3. Withdrawn Control Rod Operability IST Test; 3.7 For each control rod for every substep under 3.7. Just state it once, will save some paper.
Kg - Removed redundant wording from each subsequent step per CE comment.
- 2. Believe Task Standard should read exercised control rods 22-07 and 26-07 1 notch IAW recognized since both rods were cycled 1 notch.
Kg - Changed task standard to Examinee exercised control rods 22-07 and 26-07 IAW Procedure 6.CRD.301 section 3.7, recognized control rods 22-07 and 26-07 were drifting in, and inserted a manual scram IAW Alarm Card 9-5-1/C-4, Rod Drift or Procedure 2.4CRD, CRD Trouble per CE comment.
- 3. If applicant takes MODE SW to SHUTDOWN, would that satisfy task standard? (Step
- 24)
Kg - CNS operators are trained to use scram push buttons to insert a manual scram.
But since placing the RMS in Shutdown accomplishes the safety function, added OR by placing the Reactor Mode Switch to SHUTDOWN to JPM step 24 standard.
[NRC OK]
Post Validation:
- 4. Only need to state For each control rod at 48, perform following once at beginning.
Kg - Removed mentions of step 3.7 For each control rod at 48, PERFORM following: from subsequent steps.
- 5. Combine various steps into one, as discussed for efficiency.
Kg - Combined substeps of steps 3.7.2 and 3.7.5 as noted during prep week.
JPM S-2:
- 1. Try to combine some steps where you can esp. if its just reading a note or caution and then giving a direction to an NLO (steps 6.22, 6.22.1), and try to get more than 1 step per page just trying to make these packets a little more efficient.
Kg - Combined steps as recommended by CE (3 fewer pages now)
[NRC OK]
JPM S-3:
- 1. If I understand the task standard right, applicant just needs to shut 1 of the 3 listed MSIVs, is that right? If so, rephrase TS to isolated the main steam lines by closing at least one of the following:.
Kg - Changed task standard to Examinee opened Outboard MSIVs and began warming main steam lines IAW 2.2.56 section 6, recognized a main steam line leak, isolated the main steam lines IAW Procedure 2.0.3, Conduct of Operations, by closing at least one of the following: MS-MO-74, MS-MO-77, or MS-MO-78.
- 2. Combine steps 1-4 into 1 step. Same with 5-7.
Kg - Combined steps 1-4 into 1 step and steps 5-7 into 1 step.
[NRC OK]
Kg - Also from NRC prep week comment, added to Examiner Note on page 8, OR Event 3 may be manually triggered at the discretion of the Examiner when equalizing header pressure is > 50 psig and added corresponding Booth Operator note.
JPM S-4:
- 1. Want to confirm task standard: applicant needs to attempt to raise turbine speed in ALL of the following: auto, man, and speed test mode before tripping rcic turbine in order to pass JPM, is that correct?
Kg - Intent of JPM is to recognize RCIC speed will only operate below the minimum required speed to prevent turbine damage and to trip RCIC. Removed references regarding attempts raising speed manually from the task standard.
- 2. BC Comments: For Step 8 of the JPM, Procedure Step 2.7.1, what directs the operator to place the controller in manual? After JPM Step 9, does there need to be an examiner cue in case the candidate asks for direction? For Step 10, similar question, does there need to be an examiner cue in case the candidate asks for direction? In Note to Examiner, before Step 11, it states in part, that the examinee may proceed to shutting RCIC down. This would not meet the task standard for the speed test mode before tripping the RCIC turbine.
Kg - added taking manual control of RCIC flow controller is expected by Operations for RCIC flow controller failure. Added examiner cue at JPM step 9 stating if the examinee asks for directions, respond by asking examinee what they recommend. Regarding comment on note to examiner before JPM step 11, elements of manual control were removed from the task standard.
[NRC OK]
Post Validation:
- 2. Modify turbine speed to 1900 RPM when start.
Kg - Modified schedule file to make RCIC turbine speed go to 1900 rpm after start and go to 0 when RCIC steam supply is isolated.
- 3. Evaluate why FIC-91 is going to MAN mode, when guide says it shouldnt be.
Kg - Guide was incorrect. Malfunction used does not prevent controller from displaying manual mode. Revised JPM step 10 accordingly.
Also, specified printed copy of RCIC hard card as handout, removed by depressing the TURBINE TRIP pushbutton from end of task standard, and modified note on JPM step 14 accordingly.
JPM S-5:
- 1. Combine steps 1 and 2, 3-4, 5-6, 7-8, 9-10.
Kg - Combined steps 1 and 2, 3-4, 5-6, 7-8, 9-10, 15-16.
[NRC OK]
Post Validation:
- 2. Procedure Step 1.6, I documented from validation that we wanted the applicants to be able to reference EOP-5A in the vicinity of the JPM to determine MSOWL = 9.5 FT.
Kg - Added to panel setup to ensure a copy of EOP-5A is available near Panel C / VBD-H in case the examinee needs to reference it for MSO water level JPM S-6:
- 1. Combine steps 7-10.
Kg - combined steps 7-10.
- 2. BC Comments: Steps 7-10, modify standard to Examinee verified components running, per board indications and initial conditions.
Kg - changed standard for combined step 7 (previously steps 7-10) to Examinee verified components running, per board indications and/or initial conditions.
[NRC OK]
Post Validation:
- 3. Task Standard, clarify to include critical steps.
Kg - Revised task standard, adding detail for critical steps.
JPM S-7:
- 1. This JPM seems like LOD = 1, effectively a single step. Some JPMs are going to be easier than others, but recommend something to make this slightly more robust.
Kg - Per conversation with CE, replaced with bank JPM that removes RPS logic jumpers.
[NRC OK]
Post Validation:
Kg - Added instructions to panel setup to place a marked up ATWS hard card, EP 5.8.3 on usual cart at Panel 9-5.
JPM S-8:
- 1. Combine steps 1 and 2 Kg - Combined step 1-2.
[NRC OK]
Post Validation:
- 2. Confirm proper simulator operation, during first run the low flow alarm didnt clear on SGT A, and heaters didnt auto start. I believe we determined it was operating properly, but confirm.
Kg - Confirmed proper operation of SGT.
Also, designated steps 12 and 13 not critical since controller is already in Manual with V displayed.
JPM P-1:
- 1. Explain better in JPM how applicant is procedurally directed to transition to Procedure 2.2.20 Section 4 or Attachment 1, upon failure of DG to trip via EMERGENCY STOP pb.
It is acceptable if its part of conduct of ops or other documented site expectation, but should be documented in examiner guide.
Kg - Added an additional cue to JPM step 6 stating If the examinee asks for directions, as the ASD Operator state: DG1 must be shut down, what do you recommend? and added examiner note prior to JPM step 7 stating Operations expects examinees to perform Procedure 2.2.20 Section 4 or Attachment 1 (DG shutdown methods) when the DG fails to stop, and this response is per Conduct of Operations requirements.
[NRC OK]
Post Validation:
- 3. Ensure applicants have appropriate keys before starting JPM. Give each applicant a set.
Kg - Listed keys for each examinee under Special Tools section and on our separate to do list
- 4. Procedure step 5.1.3 cue, specify that midpoint position is 5.
Kg - Specified approximately 5 in the cue.
Also, made steps 8 and 9 not critical and steps 9 and 10 not alternate path, and added and VOLTAGE ADJ potentiometer is at midpoint to item 3 in Initial Conditions per NRC comment.
JPM P-2:
Kg - Modified task standard to and repressurized the scram air header.
[NRC OK]
Post Validation:
- 2. Make validation time 10 min.
Kg - Changed validation time from 15 min to 10 min. Formatted to eliminate open space.
JPM P-3:
- 1. No comments.
Post Validation:
- 2. Make validation time 10 min.
Kg - Made validation time 10 min.
- 3. Step 12.1.4, add to cue that handle is perpendicular to pipe when closed.
Kg - Added as-found and as-left position of the valve handle to cues in JPM steps 7 and 8.
- 4. End JPM after procedure step 12.1.13.
Kg - Added cue to end JPM after step 12.1.13 has been performed and deleted subsequent JPM steps.
ALL ADMIN JPMS COMMENT: For any JPM that the applicant has to use a plot or a form to conduct calculations, include a filled-out key for the examiner to quick-reference.
JPM A-1:
- 1. No comments.
JPM A-2:
- 1.
Get rid of The motor space heater breaker and control switches should be identified but are not critical steps from task standard. Document in response why the components that are not listed as critical, are not critical (i.e. are they not procedurally required to be cleared?)
kg - Removed The motor space heater breaker and control switches should be identified but are not critical steps from the task standard per CE comments.
The statement The motor space heater breaker and control switches should be identified but are not critical steps was requested to be added to the task standard by the two Operations Representatives and the Operations Management Final Reviewer on the exam team. These Operations personnel also requested steps related to the vent and drain valves to be considered as not critical. The reason the motor space heater breaker is not procedurally required to be identified as a danger tag is because the scope of work in the initial conditions is limited to the pump, and the motor cover is not required to be removed. There would be no exposure to an electrical hazard. The motor feeder breaker is required to be danger tagged to prevent pump rotation, which is a personnel hazard for the scope of work. The vent and drain valves are not listed as critical because the REC pump would not contain a high pressure or high temperature fluid that would pose a safety hazard to personnel breaching the pump boundary for the scope of work in the initial conditions.
[NRC OK]
Post Validation:
- 2. Include printout for motor heater although its not critical Kg - Added B&R Dwg 3035 Sheet 4 to handout list
- 3. Include hard copy printouts Kg - Specified hard-copy, full-sized prints for handouts
- 4. Clarify in cue sheet that job is for pump impeller replacement.
Kg - Specified work is to replace pump impeller in Initiating Cue.
JPM A-3:
- 1. No comments.
JPM A-4:
- 1. Include with examiner key marked up attachments 8, 10.
Kg - Added marked-up Procedure 5.7.16 Att. 8 and 10 as answer keys
- 2. As a point of clarification for me, the evolution is to vent from the torus, but Procedure step 7 directs to determine DRYWELL venting flowrate, and table 7-1 column (8) is labeled Drywell Venting Flow Rate are drywell and torus venting flow rate supposed to be interchangeable for the purposes of documenting this JPM? Or should the language of the above referenced steps be modified in the source procedure to be inclusive of both drywell and wetwell venting?
Kg - drywell and torus venting flow rate are interchangeable for the purposes of documenting this JPM. Procedure 5.7.16 does not distinguish venting from the torus as other than drywell venting and makes no reference to wetwell. Venting the drywell via the torus vent line is preferred is torus water level is low enough to allow the vent line to be used. The term wetwell is not commonly used at CNS.
[NRC OK]
JPM A-5:
- 1. Lets consider giving the applicant all of Procedure 6.SC.202 (16 pages), instead of just a few pages.
Kg - The examinee will be given all of procedure 6.SC.202.
- 2. Include entry into TS 3.6.4.2 in task standard. Include the required action statement which applies in task standard and step 4 standard.
Kg - Added TS 3.6.4.2 specific required actions A.1 and A.2 (not wording of action A.1 and A.2, since wording is lengthy) to task standard and JPM step 4 standard, added entire procedure 6.SC.202 as an additional handout, removed page from 6.SC.202 section 7 from examinee cue sheet, since entire procedure will be given as a handout.
Post Validation:
- 3. Eliminate examiner note on key that immediate retest is not critical.
Kg - Deleted examiner note on key.
- 4. Immediate retest is reqd per 0.26 6.2.1.3 Kg - Acknowledged JPM A-6:
- 1. No comments.
Post Validation:
- 2. Include NUREG 1022 as a reference.
Kg - Added action item on to do list to copy NUREG 1022 to memory sticks supplied for references
- 3. Task standard, clarify 50.72(b)(3)(v)(D)
Kg - Clarified task standard 50.72(b)(3)(v)(D)
JPM A-7:
- 1. The answer key doesnt actually reference the term TS 3.10.5. Specify that this is where the guidance is coming from.
Kg - Added TS LCO 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling as preface to TS requirements on answer key.
Post Validation:
- 2. Initiating Cue: You ARE to determine Kg - Changed You to determine to You are to determine
- 3. The task standard is awkwardly worded. Specify that The examinee determined that in order to remove CRD 10-11 under the given conditions, the following conditions must be satisfied:. Impacted rods as identified on answer key.
Kg - Revised task standard to Examinee determined that in order to remove CRD 10-11, the following conditions must be satisfied IAW Technical Specification LCO 3.10.5:
all other control rods are fully inserted, all other control rods in a 5X5 array centered on the withdrawn control rod (10-11) are disarmed (impacted rods as identified on the answer key), a control rod withdrawal block is inserted and LCO 3.1.1. Shutdown Margin, Mode 5 requirements may be changed to allow the single control rod withdrawn
to be assumed to be the highest worth control rod; and no other core alterations are in progress.
[NRC: Put task standard requirements in bulleted list for easier verification]
Kg - Put task standard items in bulleted list.
JPM A-8:
Kg - For JPM step 5, Procedure 5.7.14 would require entry for estimated dose > 5 Rem thyroid CDE. Examinee should determine entry is not required relative to 10 mRem estimate in initial conditions.
[NRC OK]
Post Validation:
- 2. Modify to account for adding 10mRem thyroid dose to exposure, for a final estimated dose of 7.76 R.
Kg - Changed calculation to add 10mR Thyroid CDE for a total of 7.76R and modified task standard and answer key accordingly. Also split Initial Conditions item 9 into three separate items (now 9, 10, 11) for human factoring.
- 3. I documented to Use Note 2 of 5.7.12.
Kg - Listed Att. 1 Note 2 as the procedure step requiring summing 10 mR Thyroid CDE with calculate whole body dose to obtain total estimated dose.
JPM A-9:
- 1. No comments.
Post Validation:
- 2. Provide hard copy EAL charts.
Kg - Specified hard-copy EAL charts on list of handouts Generic: Provide exam materials electronically in color. Scenarios and some JPMs seem to be printed electronically in grayscale.
Kg - Not sure what the problem was, since exam materials I have received are in color and are the same files reportedly sent to NRC. I will check that future conversions to pdf result in color pdfs.
Kg - Generic for all JPMs, added JPM number to header for JPM Attachments to be given to examinees and ensured not hidden text..