ML13178A366
| 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: |
| References | |
| Download: ML13178A366 (10) | |
Text
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 1 of 10 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 OT-3701-ADM_018_RO "Determine radiological conditions for rescue." Is this same as 2009 ILE RO Admin JPM? If so, identify as "P" This JPM was modified, so not "P".
Conduct of Operations OT-3701-ADM_320_SRO "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 2009 ILE RO Admin JPM? If so, identify as "P" Added "P" designation to outline.
Radiation Control OT-3701-ADM_0 18_ Is this same as the RO admin JPM? If so, need to add something to make it SRO.
SRO info was incor porated to make this SRO JPM.
RO/SRO CR/IP System JPMs Comments No comments.
Scenario D
-1 Comments No low power scenario submitted.
No low power scenario (around 5% power).
Had low power scenario on 2009 and 2010 ILEs (reduce predictability)
. The spare is a low power scenario if needed.
TS calls for SROs ES-301-5 requires two TS calls for SROs. Don't count "related TS" for same call, want separate TSs.
ORMs aren't TSs.
Scenario 1 Note: Recount "M" for ES
-301-5, deleted M from Events 6 and 7.
Event 1, N
-BOP A re there sufficient actions for evaluation
? Not just turn a switch and observe start.
Start sets up degradation of pump.
Event 4 C-BOP What is significance of the HPCI initiation? Does the injection valve open?
Water injected, small power change.
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 can't do anything about it. Only takes compensatory actions to identify loss of level indication.
Mode switch fails, hits ARI to scram.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 2 of 10 Event 6 C-ATC Minimum actions for ATC to take to insert the rods
. Already had ATWS in Scenario 2 and 3.
RPS failure.
Event 7 C-BOP Are there significant actions for evaluation? What is significance if no action taken?
Procedure compliance competency.
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? What is significance of one CBP trip?
Must start CBP within 31/2 min or procedure directs plant scram (decreasing hot surge tank level)
Event 4 C-BOP Make sure there are sufficient actions for evaluation. What is significance if no action taken and the pump trips? Must start S/B NCC Pp, if not RRP temp increases.
Event 5 C-BOP, ATC Why are both given credit for the same failure? Which position is responsible for the bus trip and restoration?
BOP shift busses; ATC reset half scram, delete "C" Won't give TS credit for entering ORM 6.3.1 Testing Requirement 5.
Lose RP sampling
-4 hr alternative method of sampling. Event 8 Not M(All), only compensatory action for the major transient.
Deleted "M".
Scenario 3 Event 1, N
-BOP Are there sufficient actions for evaluation? Not just turn a switch and observe start, then trip off other pump. More than just turn switch, must observe discharge valve, stop at correct position.
Event 3, C
-BOP Suppose BOP does nothing, or very minimal actions, what is significance? Does BOP have to start another DW cooler?
Fan won't trip, ARP tells operator to shift fans.
Event 4, I
-ATC, SRO, TS-SRO Won't give TS credit for entering ORM 6.2.1. Can't take credit for a second TS for same event equipment. ORM 6.2.1 is RC&IC (rod block); second TS is RPS. Add another TS. ORM=Operations Requirement Manual Event 5, C
-ATC How is RRP downshift a component failure? He can't do anything about it. What significant actions does the ATC take? Have to insert CRAM rods.
Event 6 C-ATC What is the C? ATWS?
Failure to scram, OPRMs fail to scram. Have to NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 3 of 10 initiate a scram.
Event 7 M-All , C-BOP Why is this C for BOP? What significant actions does he take? Suppose he takes no actions, what is significance?
RHR A fails to initiate, will have to start with H/S.
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 recovery? Suppose BOP doesn't recover pump?
What are the significant actions taken to recover the CRD pump? Won't be able to drive rods without CRD Pp.
Proposed Submittal Comments RO Admin JPM Comments Conduct of Ops, 2.1.18 Perform ATC Hourly Walkdown Where is the 'Administrative' component of the task? During validation, added questions to cues.
Conduct of Ops, 2.1.25 Determine Time to Boil and Core Uncovery Which graphs in PDB
-A016 are used for in
-vessel after refueling is completed?
Step #3 - What is the acceptable accuracy for this critical step? (~8 hrs + or
- What?)
Step #4 - The acceptable tolerance for the acceptable accuracy may be too large. (44 hrs too high; 43.5 is reasonable for graph readability.)
The graph labeled " After Discharge of 177 Fuel Bundles". 8 hrs only.
Changed to "42.5
-43.5 hrs".
Equipment Control, 2.2.41 Determine Necessary Isolation for Fire Protection Valve Is this tasking following a normal plant process?
Is the applicant actually being asked to develop a clearance (or tagout) to isolate the leak?
Trying to get isolation so pumps can be restarted. Tagout to follow.
Radiation Control, 2.3.7 Determine Does the plant initial Rx power level need to be specified?
No.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 4 of 10 Radiological Conditions for Rescue The first 3 steps of the JPM should be tied directly to the 'tasking' requirement, i.e. 'In the vicinity of the injured person, what is the highest general area dose rate?'
Revised JPM to use readings in direct path to injured person. S RO Admin JPM Comments Conduct of Ops, 2.1.18 Make 4-hour Notification This JPM is designated as 'Time Critical' because of the 4-hour reportability time limit for the valid 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 to evaluate the plant conditions for reportability may be 'cueing' the applicant to the correct answer of the first critical step.
Not Time Critical JPM.
Revised Cue: "-assess the situation and perform the required activities."
Equipment Control, 2.2.41 Determine Necessary Isolation for Fire Protection Valve and Evaluate Impact Establish that the plant is in Mode 1 as an initial condition and then let the applicant decide proper required actions without a 'Cue' to the applicant in Step 4.
Initial Conditions changed to establish that the plant is in Mode 1. Deleted Step 4 cue.
Emergency Plan, 2.4.38 Perform Classification and If Necessary, Notification The Initial Conditions need to clearly state whether or not this is the initial classification for the event, and if so, when (ie, timeline) the indications were available to the crew for Modified Initial Conditions to be 2 cues.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 5 of 10 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-C11_513; Withdraw Control Rods This ALT Path may not be very discriminating since the scenario has the applicant remain in the same procedure, simply double clutch vice 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 recommend using 'Alternate Controls' before providing direction.
What is the required action if 'double clutching' results in overshooting required notch position?
The initial conditions are different on the 'Cue Sheet' than stated in the 'Setup Sheet.'
Modified JPM to require applicant to increase drive water pressure in addition to double
-clutching.
Modified cue to do this.
Added "note" to step 11 regarding FTI
-B0002. Matched Initial Conditions to cue sheet.
Sim b. OT-3701- E51_006 Lineup RCIC to control RPV level per EOP-SPI 6.6 What makes this a 'New' JPM?
EOP SPI 6.6 is a new procedure, created in June of 2012. Licensee did not have a JPM covering this previously.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 6 of 10 SPI 6.6 Sim c. OT-3701- B21_009 Open MSIVs What makes this a 'New' JPM?
Step 4 of JPM: When and why would N22
-F455 already be shut?
EOP SPI 6.6 is a new procedure, created in June of 2012. Licensee did not have a JPM covering this previously.
1N22-F455 is closed IAW IOI-0003, Power Changes (our at power integrated operating procedure) and would not be normally opened until depressurizing the RPV in IOI
-0004, Shutdown.
Sim d. OT-3701-E12_506 Re-establish SDC Why is this an ALT Path JPM? The scenario has the applicant remain in the same procedure, even the same section of the procedure.
(Cueing) The cue to secure the running RHR
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 understand why this could not be accomplished 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
'Cue Sheet' than stated in the 'Setup Sheet.'
Deviation from Normal mode, SDC is required, and the applicant needs to select the correct subsection of the procedure.
Revised cue to force applicant to make decision.
Will have Att 42 filled in ahead of time and given to the applicant as part of the cue.
Corrected.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 7 of 10 Sim e. OT-3701-R43_501 Shutdown Div. 2 Diesel Generator Again, this is not a discriminating ALT Path? The scenario has the applicant direct the operator in the plant to take one action to open an electrical 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 and not the Balance of Plant Operator? What are the plant initial conditions?
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.
Modified JPM to do Normal or Emergency shutdown upon discovery of failure to auto trip RO is generic term, we use ATC, BOP and FS for Perry. JPM is independent of plant initial conditions
. Changed task to eliminate "to Standby".
Sim f. OT-3701-D17-001 Startup DW ARM Why must this JPM be performed in the Control room? JPM Step 7 should have a second part added to 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.
Changed to simulator. Modified as suggested.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 8 of 10 Sim g. OT-3701-P41-001 Shift Service Water Pumps JPM Step 1 states that the applicant will contact an NLO to perform procedure step 7.1.2; is that the correct procedure step? Should it be 7.1.1.a?
(Editing) Corrected.
Sim h. OT-3701-M25-5 01 Shift CR Ventilation to ER JPM Step 1
- If the 'A' train is tagged out, should M25-S7 actually be repositioned?
JPM Step 2
- Why wouldn't the applicant initially place the 'B' train Initiate Switch to 'STOP?'
Yes He would ask the US for direction to perform Supplemental Actions.
IP i. OT-3701-P54-5 0 2 Emergency Run of Motor Fire Pump Again, same question about discriminating ALT Path. JPMs should have realistic initial conditions and tasking, i.e., if the Motor Fire Pump did not start with lowering fire header pressure, wouldn't 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.
Replaced JPM.
IP j. OT-3701-T23-0 0 4 Containment Closure This is the RCA In
-Plant JPM.
All 4 of the JPM Steps (steps are mis
-numbered and there are only 4) are written as 'Critical
Steps,' with the indicated cues stating that all airlocks, doors, floor hatches, and shield blocks Replaced JPM.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 9 of 10 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-R10-3 0 3 Shed Non-essential Divisional Loads This JPM is designated as 'Time Critical' because off-normal procedure ONI
-R10 requires the load 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 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
'non-essential divisional bus loads' such that the required tasking is complete prior to ending the JPM? (Procedure Steps 1.9
- 1.13) Add to cue that SBO occurred 2 hrs 15 min ago.
Added additional step.
Scenario D
-1 , D-2 Comments Scenario 1 Event 3, C-BOP , TS Does the D
-2 need documentation of expected SRO actions for evaluating TS LCO entry?
Added documentation.
Event 7, C
-BOP Does not provide enough response by the applicant to be a creditable 'C' failure.
Added 3 more SRV failures.
Critical Task 2 Are 'at least 2 SRVs' enough for satisfying an
'ED' event?
5 per EOP bases.
Critical Task 3 How long will it take to inject to the RPV to get level above the MSLs? (Noted by RPV pressure increase of 10# and SRV temp lowering) Approximately 8 min.
Scenario 2 Event 6 , M-All; C-BOP What is 'RD?' Should be 'ED?' (Last page
-Editing) Corrected.
NRC ILE Outline and Operating Test Submittal Comments 2013 Perry Nuclear Power Plant Chief Examiner Comment Facility Action/Response 10 of 10 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 SRO actions for evaluating TS LCO entry?
Does the described action constitute a 'C' failure for the BOP?
Added clarification of expected actions.
No. Event 4, C
-BOP Does the D
-2 need documentation of expected SRO actions for evaluating TS LCO entry?
Added documentation.
Critical Task 6 Why is this a critical task?
Critical for adequate core cooling.