ML111090216

Initial Exam 2011-301 Post Exam Comments

ML111090216
Person / Time
Site:	Saint Lucie
Issue date:	03/24/2011
From:	Florida Power & Light Co
To:	NRC/RGN-II
References
50-335/11-301, 50-389/11-301
Download: ML111090216 (15)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 PPL March 24, 2011 10 CFR 55.5 10 CFR 55.40 Mr. Malcolm Widmann L-2011-114 Attn. Mr. Gerard Laska U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1 257 RE: St. Lucie Units I & 2 Docket Nos. 50-335 and 50-389 Post NRC Written Examination Facility Activities 050000335/2011301 & 05000389/2011301 Facility License Nos. DPR-67 and NFP-16 In accordance with Operator Licensing Examination Standards for Power Reactors, NuREG-1021 Rev. 9, Supplement 1, ES-403 and ES-501, Florida Power & Light St.

Lucie Nuclear Plant is submitting the HLC-20 NRC post examination facility activities.

Specific items provided per those requirements are:

• Signed ES-403-1, Written Examination Grading Quality Checklist

• 15 Original applicant written examination answer sheets

• 15 Photo copied applicant written examination answer sheets

• 15 Graded, photo copied applicant written examination answer sheets

• 15 Applicant written examination signed cover sheets

• 1 Master SRO written examination

• I Master RO written examination

• I Master answer key

• 4 Pages of student questions with proctor responses

• 1 Applicant seating chart

• Written examination performance analysis

• Attachment 1 St. Lucie NRC Examination Facility Comments ES-201-3, Examination Security Agreement, is currently being completed. It will be sent under separate correspondence.

Questions or comments should be directed to Terry Benton at (772) 539-2597, or Dave Lanyi at (772) 532-0106.

Very truly yours, Richard L. Anderson Site Vice President St. Lucie Plant RLA/tlt Enclosures an FPL Group company

ES-501 St. Lucie NRC Operating Exam Facility Comments Attachment 1 JPM S-3, Perform Control Room Actions for Loss of Safety Related AC BusUnit 2 Facility Comment:

Step 3 and Step 4 of the JPM S-3 are incorrectly designated as Critical Steps.

Basis:

The aforementioned steps require the applicant to place the 2A and 2C Charging pump control switches to STOP and place Letdown Isolation valves to close. This is directed in accordance with 2-AOP-47.O1A, Loss of A Safety Related AC Bus.

The basis for these steps is to establish a known configuration for subsequent power restoration. Based upon the conditions established by the JPM, the loss of power automatically isolated letdown and secured charging. In the event these actions are not completed, if an auto action of the charging pump resulted in a pump start, the size of the load would not damage or potentially overload a bus. There is no safety significance by not completing these steps; therefore these steps are not critical for these conditions.

The immediate actions of 2-AOP-02.03, Charging and Letdown, which apply to this event, require that Charging be secured and control switches placed in auto. This is not consistent with the steps of 2-AOP-47.O1A, Loss of A Safety Related AC Bus.

The initial conditions of this JPM has letdown isolated due to loss of the 2A5 480V Load center. Immediate Operator actions of 2-AOP-02.03, Charging and Letdown requires the Operator to STOP the Charging pumps and RETURN the control switches to AUTO in the event of loss of letdown.

If the applicant stopped the Charging pumps and placed the switches to auto, the backup Charging pump would cycle in response to lowering Pressurizer level of -3% deviation from setpoint and stop at +3.6% deviation from setpoint. These setpoints are such that the Tech Spec limits for high/low Pressurizer level are not exceeded. The simulator setup for this JPM requires the Pressurizer Pressure and Level channels be selected to Y channel.

By doing so, the automatic response of the Charging pumps to Pressurizer level deviation is not affected by the loss of 2A5 480V LC.

2-AOP-47.O1A, Loss of A Safety Related AC Bus directs the Operator to ENSURE the Train A Charging pump control switches placed in STOP. This step is based on possible cycling of the backup charging pump due possible failure of selected Pressurizer level channel from loss of power. That is not the case for this JPM as stated in the above paragraph. Therefore, not placing the control switches in STOP is NOT critical.

This step is an action step, therefore, in accordance with the stations procedure writers guide, the step is capitalized and bolded. This is consistent with all action statements in PSLs upgraded procedures.

Facility Recommendation:

Revise JPM S-3, Perform Control Room Actions for Loss of Safety Related AC Bus Unit 2, steps 3 and 4, to remove the critical step designation.

ES-501 St. Lucie NRC Operating Exam Facility Comments Attachment 1

References:

• 2-AOP-47.O1A, Loss of A Safety Related AC Bus

• 2-AOP-02.03, Charging and Letdown

• PSL OPS 0711206, Pressurizer Pressure and Level Control System (PPLCS)

• NuReg 1021, Appendix D, Simulator Testing Guidelines for Critical Task Methodology.

4ny-JOB PERFORMANCE MEASURE PERFORMANCE CHECKLIST START TIME:

2-AOP-47.OIA, Loss of A Safety Related AC Bus Train A.

General Actions CAUTION SAT Various instruments and equipment normally used for assessment of critical safe Lunctions may NOT be OPERABLE. All available indications should be used.

UNSAT STEP 1 (4.2.1.1): IF letdown was in service prior to the loss of power event, THEN VERIFY letdown flow.

STANDARD: DETERMINES Letdown flow has been lost.

EXAMINERS CUE:

EXAMINERS NOTE: Letdown valve V2515 closed on loss of Bus COMMENTS:

STEP 2(4.2.1.1.1): SECURE charging CRITICAL STEP STANDARD: STOPS 2A charging pump SAT EXAMINERS CUE:

UNSAT COMMENTS:

STEP 3 (4.2.1.1.2): ENSURE Train A charging pump control switches are in STOPç CRITICAL

( STEP STANDARD: PLACES 2A AND 2C charging pump control switches to in STOP. (

SAT EXAMINERS CUE:

UNSAT COMMENTS:

.JPM NRC S-3 Rev. 0 Simulator Page 4 of 14

JOB PERFORMANCE MEASURE PERFORMANCE CHECKLIST STEP 4 (4.2.1.1.3): ENSURE the following valves are CLOSED:

( CRITICAL STEP

• V2515, STOP VALVE-IC SAT

• V2516, CONTAINMENT ISOL VALVE - IC

• V2522, CONTAINMENT ISOL VALVE - OC UNSAT STANDARD: PLACES V2515, V2516 and V2522 to the CLOSED position.

EXAMINERS CUE:

COMMENTS:

STEP 5 (4.2.1 .2): IF ll of the following conditions exist:

SAT

• Unit 2 is in MODE 3 through 6

• SIAS blocked UNSAT THEN VERIFY at 1 5 minute intervals that SFSC criteria are met per Low Mode AOP for current plant conditions.

STANDARD: DETERMINES step is N/A EXAMINERS CUE:

COMMENTS:

JPM NRC S-3 Rev. 0 Simulator Page 5 of 14

Vc REVISION NO.: PROCEDURE TITLE: PAGE:

0 CHARGING AND LETDOWN 6 of 39 PROCEDURE NO.:

2-AOP-02.03 ST. LUCIE UNIT 2 I INSTRUCTIONS I I CONTINGENCY ACTIONS I 4.0 OPERATOR ACTIONS 4.1 Immediate Operator Actions

1. IF letdown flow is lost, THEN PERFORM the following:

A. STOP charging pumps.

B. RETURN charging pump control switches to AUTO.

CAUTION Severe thermal stress and flashing may occur in the Regenerative Heat Exchanger if letdown flow is NOT immediately isolated.

2. IF charging flow is lost, THEN ISOLATE letdown by performing the following:

A. CLOSE V2522, CONTAINMENT ISOL VALVE-OC.

B. CLOSE V2515, STOP VALVE-IC.

C. CLOSE V2516, CONTAINMENT ISOL VALVE-IC.

REVISION NO.: PROCEDURE TITLE: PAGE:

LOSS OF A SAFETY RELATED AC BUS TRAIN A 5 of 67 PROCEDURE NO.:

2-AOP-47.OIA ST. LUCIE UNIT 2 I INSTRUCTIONS I I CONTINGENCY ACTIONS I 4.0 OPERATOR ACTIONS 4.1 Immediate Operator Actions None 4.2 Subsequent Operator Actions 4.2.1 General Actions CAUTION Various instruments and equipment normally used for assessment of critical safety functions may NOT be OPERABLE. All available indications should be used.

LI 1. IF letdown was in service prior to 1.1 SECURE charging.

the loss of power event, THEN VERIFY letdown flow. .&.. 1.2 ENSURE Train A charging pump 4 control switches are in STOP.

1.3 ENSURE the following valves are CLOSED:

• V2515, STOP VALVE-IC

• V2516, CONTAINMENT ISOL VALVE IC-

• V2522, CONTAINMENT ISOL VALVE OC-

2. IF aM of the following conditions 2.1 IMPLEMENT Low Mode AOP for exist: current plant conditions.

• Unit 2 is in MODE 3 through 6

• SIAS blocked THEN VERIFY at 15 minute intervals that SFSC criteria are met per Low Mode AOP for current plant conditions.

)

0711206, Rev. 19 vx-\- \

1 dr Page48of 123 FOR TRAINING USE ONLY UNIT I

SUMMARY

OF PRESSURIZER LEVEL CONTROL ACTIONS PZR. LEVEL AUTOMATIC ACTION

+10% Deviation High Pressurizer Level Alarm (Increasing)

+9% Deviation Maximum Letdown (128 gpm) (Increasing)

+3.6% Deviation

• All Heaters ON (Unless Handswitch In Off)

• Both Backup Charging Pumps Receive Stop Signal 0% Deviation Normal Level (Setpoint From RRS)

-1% Deviation

• Minimum Letdown (29 gpm) (Decreasing)

• First B/U Chg. Pump STOP Signal (Increasing)

-2% Deviation

• Second B/U Chg. Pump STOP Signal (Increasing)

-3% Deviation First B/U Chg. Pump START Signal (Decreasing)

-4% Deviation Second B/U Chg. Pump START Signal (Decreasing)

-5% Deviation Low Pressurizer Level Alarm, All Chg. Pumps Get Backup START Signal (Decreasing) 28% Indicated Level All Pressurizer Heaters OFF (Decreasing)

UNIT 2

SUMMARY

OF PRESSURIZER LEVEL CONTROL ACTIONS PZR. LEVEL AUTOMATIC ACTION

+10% Deviation High Pzr Level Alarm (Increasing) RTGB 203

+9% Deviation Maximum Letdown (128 gpm) (Increasing) 67% Indicated Level High Pzr Level Alarm (Increasing) PACB Alarm

+3.6% Deviation

• All Heaters ON Signal (Unless Handswitch In Off OR Pressure >2275 Psia)

• B/U Chg. STOP Signal (Increasing) 0% Deviation Normal Level (Setpoint From RRS)

-1% Deviation

• Minimum Letdown (29 gpm) (Decreasing)

• B/U Chg. Pump STOP Signal (Increasing)

-3% Deviation

• B/U Chg. Pump START Signal (Decreasing)

-5% Deviation Low Pressurizer Level Alarm B/U Chg. Pump Gets Backup START Signal (Decreasing)

Low Pzr Level Alarm (Decreasing) PACB Alarm 27% Indicated Level With Channel X <27%; A Side 4160v Pzr Heater X-Former Feeder Bkr Trips And B Side Heater Power Supply Contactors Open.

With Channel Y <27%; B Side 4160v Pzr Heater X-Former Feeder Bkr Trips And A Side Heater Power Supply Contactors Open.

ES-501 St. Lucie NRC Operating Exam Facility Comments Attachment 1 Admin JPM A-6, Respond to Security Event Facility Comment:

Step 14 and 16, of the JPM A-3, is incorrectly designated as a Critical Step.

Basis:

The aforementioned steps requires the applicant to annotate on the Florida Nuclear Plant Emergency Notification Form that This is a Drill, and selection of the affected unit.

These steps are procedurally directed per EPIP-08, Off-site Notifications and Protective Action Recommendations.

The basis for theses steps are to identify that this is a drill rather than documentation of an actual emergency, and specify the affected unit. In accordance with EPIP-08, A step 1, During exercises, drills, or tests, each message shall be checked THIS IS A DRILL. Additionally, selection of the affected unit is required to be only one with additional information provided if both units are impacted. These are asterisked steps on Attachment 1 of the Florida Nuclear Plant Emergency Notification Form, which states, items are evaluated for NRC Performance Indicators. During development of the JPM, the standards for NRC performance indicators acceptance criteria were used to define the critical steps for the applicants exam.

In accordance with ADM-25.02 Appendix L, Drill/Exercise Performance step C, source documents for the NRC performance indicators are; Drill Reports, LOCT Simulator Evaluation Critique Sheets, and Actual Event Reports. This applicant JPM does NOT fall under this criteria and is not used for NRC performance indicators. Therefore the asterisk step on Attachment 1 of the Florida Nuclear Plant Emergency Notification Form does not apply.

The JPM initial condition does not inform the applicant that this is a drill or simulated condition. Applicant confusion can arise as to the condition to which they respond to this step. Emergency Drills and LOCT Simulator evaluations conduct a pre-exercise drill brief.

There is no safety significance for selecting either this is a drill or actual emergency. The state watch office was not actually contacted. Selecting both units as being affected, again has no safety significance. These issues are solely with procedural compliance.

Since the stations administrative procedures do not apply, the stations position is that these two steps should be designated an NOT Critical.

Facility Recommendation:

Revise JPM A-6, Respond to Security Event, steps 14 and 16, to remove the critical step designation.

ES-501 St. Lucie NRC Operating Exam Facility Comments Attachment 1

References:

• EPIP-08, Off-site Notifications and Protective Action Recommendation

• ADM-25.02, NRC Performance Indicators, Appendix L, Drill/Exercise Performance

• Donna Calabrese, PSL EP Manager

• NuReg 1021, Appendix D, Simulator Testing Guidelines for Critical Task Methodology.

ATTACHMENT I CRITICAL FLORIDA NUCLEAR PLANT EMERGENCY NOTIFICATION FORM STEP STEP 14 (Line 1): SAT I.* A. THIS IS A DRILL B. El THIS IS AN EMERGENCY UNSAT STANDARD: Checks A EXAMINERS CUE: NONE EXAMINERS NOTE: Per EPIP-08, Attachment IA step I, drill, exercises or tests, each message shall be checked this is a drill COMMENTS:

STEP 15 (Line 2): CRITICAL STEP

2. A. Date: I / B.

• Contact Time: Reported by: (Name)

D. Message Number: Reported from: Control Room LI TSC Li FOE F. [1 Initial! New Classification OR LI Update Notification SAT STANDARD: A. Todays Date B. ime contact made left blank at this time UNSAT C. Applicants name D. Fssage # I E. Contol Room F. Initial / NewClassification EXAMINERS CUE: NONE EXAMINERS NOTE: Part B Contact time must be within 15 minutes of the emergency classification time EXAMINERS NOTE: Contact time shall be filled in when contact is made with the state.

EXAMINERS NOTE: Only the

• step is CRfl1CAL COMMENTS:

NRCADMJPMA6 Page 12 of 20

STEP 16 (Line 3): CRITICAL STEP /

K) 3* Sfte: A. LI Crystal River Unit 3 B. LI St. Lucie Unit 1 C. St. Lucie Unit 2 D. LI Turkey Point Unit 3 E. LI Turkey Point Unit 4 SAT STANDARD: C, St. Lucie Unit 2 (St. Lucie Unit 2 is expected, Unit 1 is acceptable, but not both marked)

UNSAT EXAMINERS CUE: NONE EXAMINERS NOTE: EPIP Attachment IA step 3 requires only one affected unit be selected (either one can be selected but not both).

COMMENTS:

STEP 17 (Line 4): CRITICAL STEP 4* Emergency Classification:

A. LI Notification of Unusual Event B. LI Alert C. Site Area Emergency 0. LI General Emergency SAT STANDARD: C, Site Area Emergency UNSAT EXAMINERS CUE: NONE COMMENTS:

NRC ADM JPM A6 Page 13of20

REVISION NO.: PROCEDURE TITLE: PAGE:

25 OFF-SITE NOTIFICATIONS AND PROTECTIVE 37 of 55 PROCEDURE NO.: ACTION RECOMMENDATIONS EPIP-08 ST. LUCIE PLANT

¶6 ATTACHMENT IA DIRECTIONS FOR COMPLETING THE FLORIDA NUCLEAR PLANT EMERGENCY NOTIFICATION FORM (Page 1 of 8)

ITEM ENTRY NOTE On-line verification occurs when notification of the State Watch Office (SWO) is initiated.

On-line Verification Check the appropriate boxes as the State Watch Office Florida Division of Emergency Management (DEM) requests that the Department of Health Bureau of Radiation Control, St. Lucie County Department of Public Safety and the Martin County Department of Emergency Management get on the line, prior to initiating the notification. All four agencies must be notified (includes Florida DEM) through the SWO or alternate means.

1. Check appropriate box for drill or actual emergency as the case may be. During exercises, drills, or tests, each message shall be checked THIS IS A DRILL.

2A. Enter todays date.

2B. Enter the time (using the official time, normally synchronized with ERDADS (DCS))

when contact is made with the State Watch Office. For initial notification of classification, this shall be within 1 5 minutes of the Emergency Declaration time in item 5.

2C. Enter the name of the person making the notification call.

2D. Enter the message number beginning with #1 and following sequentially in all facilities (e.g., if the Control Room transmitted two messages the TSC would start with #3).

2E. Check the box for the facility from which the notification is being made.

2F. Check the box for Initial / New Classification or Update Notification.

3. Site Check the affected site / unit. Do not check more than one unit. For dual unit events such as the approach of a hurricane or loss of off-site power, the fact that the other unit is affected by the condition should be stated in the Additional Information or Update section.

4. Emergency Classification Check the box corresponding to current accident classification declared.

REVISION NO.: PROCEDURE TITLE: PAGE:

24 OFF-SITE NOTIFICATIONS AND PROTECTIVE 36 ° f PROCEDURE NO.: ACTION RECOMMENDATIONS EPIP-08 ST. LUCIE PLANT ATTACHMENT I FLORIDA NUCLEAR PLANT EMERGENCY NOTIFICATION FORM (Page 1 of 1)

On-lire Venficetton Q SWPIt)EM DOH/BRC [] St. Lucia Cosrty.lFt Pierce C Martin County

1. A. EJTHISISADRILL B. U THIS IS AN EMERGENCY

2. A. Date / / B.

• Contact line: C. Reported by: Nave)

0. Messeqe Number E. Reported from: Control Ronm [] TSC [] EOF F. InitIal I New ClassIficatIon OR El Update Nodficetion 3 .: A. fl Crysdo Rrecr Unit 3 B. ElSt.LucieUnutl C. C.]St.LucieUnit2 D. {j Turkey Point Use 3 E. U Turkey Point Unit 4

4. Emergency Ciesslfcation: A. Li Nollficatlcar of Unusual Event B. Li Alert C. El &te Nee Emergency 0. []Genecel Emergency 5* A. Li Erneroency Declaration: B. Q Emergency Ttirmiratign: Date: / / Time:

6. Reason for Err erger cy Declaration A. fl EAi.Number OR B. Dencrcn.

7. A. Q None OR 8. Q Description.

8. Westiren Data: A. WrO erection from degrees B. DWnwind Sectors A1tectec

9. Release Status: A. Li None 1 oto Scm 11) B. In progress C. El Has ocurred. but stoçcpef 1)30 to Item 11) 10.

A. Under Svstuation B. )J Retee wthn normal erating limits t 3.5 0-1 Ci/sec ndote gas, r: 4.6 E5 Ci/sec ioOine)

C. Q Non.Signttcsnt Fraction Of PAD Range treleese Is> normel limits and 500 mrem T000 and 1000 mrem CDEI

0. El PAD Rurige l SOC Irf em TEDE or 1000 mom CDEi E. [] Liquid release rio actions requireol l1, UTILITY PROTECTIVE ACT1ON RECOMMENDATIONS ROR THE PUBLIC.

A. C No utility recommended actiOns at this time.

B. U The utility recommence the following protective actions:

Evacuate Sectors Snelter Sectors No Action Sectors Evucuatri Zones. OR Cl -.2 Sheller Zones 2 - S 510 AND consider issuance of potassium iodide (NW If fonso is completed In the Control Room, go to Item 15. If completed fri rite TSC or EOF continue with irem 12.

12. Plant Condolons: A. Reac:o Shutdown? Q Yes [3 No B. Core Adequately Cooled? Q Yes fl No C. Containment Intact? El Yes El No 0. Core Coodition El SteEle El Degrading

13. Wathec Data: A.

• MrC Speed mph B. StabIlity Class

14. Adr5tionat Release tntormation A, El N/A OR Read rtrs statement i hcur prc4ecteci doses an follows Distance )iroiectert I C- fm I krriir Prciiecled TrIal Dose I FUEl *or 1 HOur I Mile ISle Bormndary) B. mmiii C. mrent 2 Miles D. mrvrn E. mrem S furIes F. inriem 0.

10 Mtles H. rivers mrerr

15. lOo Not Read EC or RM Aopro*el çiatsre Date I / Time.

Message Received Dy Name:_______________________________ Date: I / Time Items are evatuetec for NPC Performance lrtdlcSIQra (PIsi Fern Resrsioii 0 END OF ATTACHMENT I

REVISION NO.: PROCEDURE TITLE: PAGE 25 NRC PERFORMANCE INDICATORS PROCEDURE NO.:

82 J...cof ADM-25.02 ST. LUCIE PLANT APPENDIX L DRILL I EXERCISE PERFORMANCE (Page 1 of 7)

A. Indicator value =

FI # of timely & accurate classifications, notifications, & PARs from DE & AEs during the previous 8 quarters 1ixlOO L The total opportunities to perform Classifications, Notifications & PARs during the previous 8 quarters ]

• DE & AEs Drills, Exercises, and Actual Events B. NEI 99-02, Reference current revision.

C. Source Documents

1. Drill Reports

2. LOCT Simulator Evaluation Critique Sheets or similar form (with attached state notification forms)

3. Actual Event Reports D. Special Considerations Purpose This indicator monitors timely and accurate licensee performance in drills, exercises, and actual events when presented with opportunities for classification of emergencies, notification of offsite authorities, and development of protective action recommendations (PARs). The indicator is the ratio, in percent, of timely and accurate performance opportunities to total opportunities.

Indicator Definition Unless previously excluded, this indicator is the percentage of drill, exercise, and actual opportunities that were performed timely and accurately during the previous 8 quarters, as measured on the last calendar day of the quarter.