ML13308A686

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2013 DAEC Initial License Examination Operating Test Comments with Resolutions
ML13308A686
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 04/08/2013
From:
NRC/RGN-III/DNMS/MLB
To:
Duane Arnold
Randal Baker
Shared Package
ML11354A335 List:
References
Download: ML13308A686 (5)


Text

Review of DAEC 2013 ILT Operating Test RESOLUTION:

All comments were addressed during the validation week numerous small changes were made to the JPMs and Scenarios to address NRC comments but all the JPMs and Scenarios were accepted.

COMMENTS:

Control Room JPMs:

S-1. Start a Recirc MG Set and Recirc Pump - This is ALT Path and MOD Performance Step # 8 - If the Caution prior to this step states that the amount of time the operating Recirc pump is <50% speed, why is it already at <50%speed? Why doesnt the applicant adjust speed as part of the JPM?

The applicants action is one simple step and may not be very discriminating. (This would be more discriminating if the applicant is required to now reestablish single loop operating conditions for continued operation, i.e., adjust operating Recirc pump speed > or = 50%,

lower RPV level, inspect Recirc pump discharge valve breaker, etc.

S-2. LPCI Initiation While in Shutdown Cooling - BANK No Comments.

S-3. Manual Arming of LLS - This is ALT Path and NEW Performance Step #2 - Does PSV-4401 (PSV-4407) actually shut when handswitch is placed back in AUTO?

S-4. HPCI Pump Discharge Transfer from the CST to The Reactor Vessel - BANK The applicant should demonstrate control of RPV level by maintaining level within band, once flow to the vessel is re-established, prior to stating the JPM is complete.

S-5. Air Purge Cooling of the Drywell - This is NEW Why are Performance Steps #3 & #4 not Critical Steps?

S-6. B Standby Diesel Generator Operability Test - This is ALT Path and NEW What makes this JPM NEW? (Just the ALT Path choice?) No Additional Comments.

S-7. Withdraw Control Rods During Reactor Startup - This is ALT Path and MOD Performance Step #12 - Why is this a Critical step?

Performance Step #19 - Why is this a Critical step? Will the applicant actually move the affected rod to a different notch to verify the reed switch failure? Which direction will the rod be moved?

S-8. Perform Required Actions for SBGT Overheating - This is ALT Path and BANK Performance Step #10 - The applicant must recommend performing the deluge prior to the Role Play CRS concurring with the action and directing it since this is a Critical step.

In-Plant JPMs:

P-1. Perform Required Actions for RPV Injection with the SBLC Test Tank - BANK No Comments.

P-2. Shift CRD Flow Control Valves - BANK No Comments.

P-3. Establish Alternative Power to 125 VDC and 250 VDC Chargers - BANK Performance Steps #3-#6 and Steps #15-#16 should clearly state that the actions associated with the Steps Standard are Simulated actions.

What is the discriminating purpose of the Fault presented in Performance Step #15 if this JPM is not ALT Path and the system malfunction is not mitigated and the task is not accomplished? What is the success path?

Administrative JPMs-RO:

COO1 Perform Reactor Coolant Leakage Calculations per STP 3.0.0-01:

No Comments.

COO2 Perform Control Rod Exercise Test Prerequisites:

No Comments.

EC01 Using Mechanical Drawings Determine the Isolation Boundaries for Leak on the Core Spray System:

No Comments.

RC01 Inspection of High Radiation Areas and Determine Personnel Entry Requirements:

No Comments.

Administrative JPMs-SRO:

COO1 Review STP 3.4.2-01, Daily Jet Pump Operability Test:

Performance Step #3 - Since the incorrect information in the STP does not result impact the Jet Pump operability, this Step is not critical.

COO2 Determine Risk and the Resultant Protected Systems for Removing a Safety Related Piece of Equipment from Service:

No Comments.

EC01 Determine Tech Spec Implications for an Inoperable System Valve:

No Comments.

RC01 Determine Personnel Eligibility to Perform Rad Area Task:

No Comments.

EP01 Classify an Event and Implement the Emergency Plan as Required:

No Comments.

Scenarios:

(NOTE: They have a spare scenario ready to be validated by the examiners.)

Scenario #1 Event #6 - The BOP must place Torus Cooling in service to receive credit for the C failure (SRV). If the ATC operator performs a Fast Power Reduction, this also counts as a Reactivity manipulation and should be assessed.

Critical Task #1 - Should be listed on the D-2 as an action accomplished by the BOP position.

Scenario #2 No Comments.

Scenario #3 No Comments.

Spare Scenario Works!