ML16217A286

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Outline and Operating Test Comments Final
ML16217A286
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 08/02/2016
From: Kweiser J
Operations Branch III
To:
FirstEnergy Nuclear Operating Co
Shared Package
ML15274A364 List:
References
L-16-213
Download: ML16217A286 (7)


Text

NRC ILE Outline and Operating Test Submittal Comments 2016 Davis-Besse Nuclear Power Station Outline Submittal Comments Chief Examiner Comment Facility Action/Response Admin JPMs No Comments Lic:

Outline NRC:

Sim/Inplant JPMs No Comments Lic:

Outline NRC:

JPMs-Admin No Comments Lic:

NRC:

JPMs-System No Comments Lic:

NRC:

JPMs-In-Plant No Comments Lic:

NRC:

Scenario ES-D-1s No Comments Lic:

NRC:

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Operating Test Submittal Comments RO/SRO Admin JPMs Comments Chief Examiner Comment Facility Action/Response RO Admin A1.1 Applicant must earn the DB-PF-06703 procedure, then Lic: This JPM administered in classroom setting evaluator may provide a copy to the applicant. with the curve book.

Reword the initiation cue to state Shift Manager directs you to calculate...

RO Admin A1.2 What determines the acceptable limits placed on the Lic: Steps 3, 9 and 13 are based on +/- half Steps 3, 8, 9, 13, & 14 answers? (i.e. Step 14 should increment of graph grid reading. Step 8 calculation be 860-880 MWe min and 920-940 MWe max.) based on max/min readings. Revised Step 14 to say Acceptable is calculation of +/- 30 applied to value determined in previous performance step.

RO Admin A2 What determines the acceptable limits placed on Lic: Tightened Step 2 limits to half of increment that portions of the Step 2 pressure readings? (Isnt that can be read. Values are not exact, will have to why the allowable tolerance is 100 psi?) revise based on where simulator is frozen for the JPM.

Why doesnt the cover sheet need to be signed-wouldnt that be expected for this activity? Cover sheet is signed.

RO Admin A3 If the applicant is expected to initial off Step 4.2.13 Lic: Correct.

(per initiating cue), then the evaluator needs to sign as the IV once the applicant states that an IV is NRC: The evaluator will sign as the IV on the required to complete the step. Attachment 24 referenced by Step 4.2.13.

SRO Admin A1.1 Does determining correct notification requirements Lic: No time limit required.

normally include specifying the required notification time limit? Consider including.

SRO Admin A1.2 Add cue for evaluators to have applicant continue Lic: Discussed with examiners, practice is to cue with review if TS entry identified and reported during applicants to continue with review to identify all errors.

review process. (Do the applicants need to correct Applicants are only expected to identify the errors and the identified errors?) return to responsible party to correct them.

SRO Admin A2 No Comments Lic:

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Chief Examiner Comment Facility Action/Response SRO Admin A3 No Comments Lic:

SRO Admin A4 The JPM Task begins 5 minutes after the EAL Lic: Revised JPM. Task will begin at t=0, no 5 minute threshold has been met. This is unrealistic since the credit. Wallboard will be staged and marked. TC for initial conditions state that the applicant is the ED. the phone call ends when the applicant makes the The 10 minute Time Critical Task is not justified call, not when someone answers. It should be based upon ICs. alternate path.

The wallboard charts should be staged and marked up for the initial SU1 declaration, again because the initial conditions state that the applicant is the ED.

The 2nd Time Critical Task is 15 minutes after declaration of the new emergency classification, but the clock should be stopped when a party answers the 4-way ring-down phone, not when the applicant picks it up.

Is this considered alternate path since Lucas County isnt initially on the 4-way ring-down line?

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RO/SRO CR/IP System JPMs Comments Chief Examiner Comment Facility Action/Response SIM JPM S1 What indications are available for CC 1328 failing Lic: There are panel indications for CC 1328.

closed?

The applicant will pull copy of the ARP which allows Need to check copy of DB-OP-02523 for actions on starting the pump under the stated conditions.

CCW System Malfunctions - what allows the attempt to start CRD Booster pump 1 under these plant MCR operator opens CC 1328.

conditions? Check Alarm Response Procedure. (Is BE2206 open? Is this a centrifugal pump?) The CRD Booster Pump 1 must be running to complete the JPM.

Who actually opens CC 1328? (If valve is opened by an EO, then Performance Step 13 may not be a critical step.)

Must CRD Booster pump be running to successfully complete the JPM?

SIM JPM S2 Would the Command SRO normally direct the step- Lic: The Command SRO would normally direct the by-step performance of Attachment 7? step-by-step performance of Att 7. However, the ROs are required to know how to perform the LPI suction Limit time to review to simulate actual plant conditions transfer to the Emergency Sump task. For the response. (Dont impose artificialities on the purpose of JPM evaluation of the task the ROs are applicants.) evaluated based on their actions to perform the task without the SRO Command function. Will also do the Initial Conditions/Initiating Cue before stepping into simulator.

SIM JPM S3 Same comment on step-by-step performance as noted Lic: The Command SRO would normally direct the in previous JPM. step-by-step performance. However, the ROs are required to know how to perform actions for recovery If MU 3971 is not critical because MU2 pump is not from MU/HPI/PORV Cooling task. For the purpose of running, then why is in this section (Only MU1 pump JPM RO evaluation, they are expected to perform the running-Step 4) of the procedure? task without the SRO Command function.

Performance Step 16 STANDARD should state, and Part of the procedural transition to the remaining steps verify RC 11 closes. and the alternate path.

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Chief Examiner Comment Facility Action/Response SIM JPM S3 Insert comment.

(continued)

SIM JPM S4 Need to review marked-up copy of DB-OP-06224, thru Lic: Incorporated.

step 3.16.43 to validate JPM.

Step 14 not critical (pump starts then trips).

Initiating Cue: add local operator in field for local transfer. (Step 11)

SIM JPM S5 What determines which containment isolations are Lic: Procedure guides provided by the SM. JPM required? Which ones are they? Step 4-bases-Level 1 and 2. Lists valves that can be closed from the MCR.

SIM JPM S6 Since the JPM actions must be started no longer Lic: The licensee JPM time critical task is for 15 than 15 minutes from the initiation of the event, minutes, therefore, we wouldnt normally do recommend changing the initial conditions to state anything less even though the validation time is 8 that something less than 15 minutes have elapsed minutes.

and adjust the time critical task accordingly.

(Validation time is actually 8 minutes; is this really Can adjust Initiating Cue accordingly to wait for time critical?) applicant to ask if operator dispatched to perform Att 14, or get to JPM Step 2 of Attachment 5.

Also recommend not informing the applicant that another operator has been dispatched to perform Add cue to only do 1 AFP.

Attachment 14 until they either ask or get to Step 2 of Attachment 5.

SIM JPM S7 Where does the applicant obtain keys for opening the Lic: Keys are located in MCR cabinet.

cabinet doors?

Examiners will use time compression to cue the Recommend adding an evaluator cue that states that applicant that the NI has been repaired and enough time has elapsed to repair and test the failed NI tested, and is ready to be re-energized per channel, and now the Unit Supervisor directs the Section 4.4 of DB-OP-06403.

applicant to complete subsection 4.4 of DB-OP-06403.

SIM JPM S8 Do expected alarms need to addressed as part of a Lic: Expect applicants to reference ARP, mark it and pre-evolution brief item to be announced as expected? identify expected alarms.

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Chief Examiner Comment Facility Action/Response IP JPM P1 Is there more than one Low Voltage Switchgear Room? Lic: There are two low voltage switchgear rooms and The JPM title and the initiating cue should match. the applicant will access both.

If this procedure step is an Immediate Action, why is The cue to hand copy to applicant will be deleted.

the applicant initially handed a copy of the procedure?

Step 1 is N/A if applicant not handed a copy of What is the purpose of Performance Step 1? procedure.

How does the applicant earn the information that the Applicant must earn information based on the trip flag reactor has (or has not) tripped? Is a cue required to be color. Add cue for examiner.

provided by the evaluator?

Not alternate path because JPM started in the RNO How are E2 & F2 normally deenergized? Is this Alt Path? step.

IP JPM P2 Once Instrument Air has been restored, and the Lic: Operator will verify Steps C 5 c. and d.

applicant is directed to restore IA to ICS11A, either have the applicant verify steps C 5.c & d, or add an evaluator cue to state that the actions will be completed by another operator, and then the JPM is complete.

IP JPM P3 No Comments Lic:

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Scenario D-1 Comments Chief Examiner Comment Facility Action/Response Scenario 1 No comments on scenario events. Lic: Will make this the spare scenario and eliminate (DB NRC 2016) the CT conflict with Scenario 3.

This scenario has the same Critical Task (CT-1) as Scenario 3. Since Crew A will see both scenarios, recommend changing the Spare to Scenario 3 and use Scenario 4 in place of Scenario 3.

NOTE: This is the only low power scenario submitted.

Scenario 2 No comments on scenario events. Lic: Remove bold. Was errata.

(DB NRC 2016)

Why is Event 2 Description Bolded?

Scenario 3 See comment for Scenario 1 above. Lic: Will use this scenario, make Scenario 1 the (DB NRC 2016) spare.

Make this one the Spare.

Scenario 4 No comments on scenario events. Lic: Will use Scenario 4 in place of Scenario 1.

(DB NRC 2016)

Use in place of either Scenario 1 (or 3). Remove bold. Was errata.

Why is Event 6 Description Bolded?

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