ML19099A377

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CW-2019-03 Draft Outline Comments
ML19099A377
Person / Time
Site: Callaway 
Issue date: 03/13/2019
From: Greg Werner
Operations Branch IV
To:
AmerenUE
References
50-483/19-03 50-483/OL-19
Download: ML19099A377 (5)


Text

DRAFT OUTLINE COMMENTS Facility:

Callaway First Exam Date:

March 4, 2019 Written Exam Outline May 29, 2018 Comment Resolution 1 NRC Generated 2

3 4

5 Administrative JPM Outline Oct 10, 2018 Comment Resolution 1

Need to see a refueling admin (ie a fuel move during refueling or offload to a canister) for SRO A1. This is really important in the CFR for the SRO and Callaway has not done this in a long time. Reject SRO A1 and put this in its spot.

Licensee wrote a refueling admin JPM and it is now included on this exam.

Control Room / In-Plant System JPM Outline Oct 10, 2018 Comment Resolution General Comments on JPMs

1. You have not used SF9 in your sampling for at least the past 5 exams.
2. Also, use of purge and mini purge in SF8 is high over the past several exams and this was an event for scenario 4 on 2014 exam.
3. Too much predictability with SF alignment therefore we need to write new JPMs based on review of this material and previous exam material. SF 4, 6, and 8 have been the SF used for the three in-plant JPMs 4 of the last 5 NRC exams. We need to

sample different SFs on this exam to prevent predictability.

The below comments go JPM by JPM for the changes needed. Call for help or questions.

1 S1-good as is.

2 For S2, modify the failure to be a sheared shaft.

Licensee agreed.

3 For S3, Adjust accum pressure or level or draw a bubble in the pressurizer are good topics and meet the pressure control SF.

Licensee Looking for accumulator press or level JPM.

4 For S4, would like to see an RHR JPM. Licensee incorporated the requested change for this exam.

5 For S5 I would like to use a bank JPM on H2 like putting H2 analyzer in service during LOCA, ID# URO-SGS01C29J.

Licensee incorporated the requested change for this exam.

6 S6-good as is 7

For S-7, Lets use SF9 and do an inadvertent gaseous release (alt path) to replace S7. In this JPM you get high rad alarms and CR ventilation does not realign as required and the applicant has to realign it.

Licensee wrote a new JPM on SF9.

8 S8-good as is 9 P1-good as is.

10 P2-need a different SF and therefore different JPM.

New P2 not from SF6, SF8. Licensee incorporated the requested change for this exam.

11 P3-need a different SF and JPM for this one too. Also, this JPM does not appear to be new based on what info I have. It reads like the JPM from your bank ID#

EOI-SKC-00-018J used on 2003 NRC exam? Regardless we need to get some different SF in-plant JPMs. If the P-1 for MG set parallel is not in the RCS then P2 or P3 would need to be an RCA JPM.

New P3 not from SF6, SF8. Licensee incorporated the requested change for this exam.

Simulator Scenario Outline Comments Oct 10, 2018 Comment Resolution General comments about scenarios

1. Same majors and events used over and over, sometimes with other majors
2. Changes are necessary to a) prevent and reduce predictability, b) insert new material into the exam process per the NUREG and SAT, c) exercise procedures and skill of the craft for industry events, d) Vary the events and majors so that they all are covered on some basis.
3. Critical tasks must be bounded to a proper parameter or value that is both achievable in the short duration of a 90 minute scenario and also can be failed if not performed correctly within constraints reasonable for the scenario. For example, during at ATWT (ATWS), it is unacceptable for an RO/ATC to continue with other steps in the EOP if he/she has not taken all actions to ensure SF1 is met within the steps of the procedure, not by the end of E-0. If the ATC abandons SF1 and starts other equipment and has not done the actions required to get the rods or reactivity inserted, then they have failed to ensure SF1 was met.
4. CTs should be numbered in the table at the top for the order they occur in the scenario (CT1, CT2, etc). This is not to renumber them if they came out of the owners group table (leave that cross reference in the block at the bottom as you currently have it)

Changes required are communicated below:

1 Scenario 1 MFP vibrations followed by E-0, rx trip failure was on 2014 exam in that order and since you use the last NRC exam Licensee agreed to make the requested changes.

as the audit this is too close for predictability.

For this scenario, use the following:

Event 1 - Alternate trains of CR ventilation (normal)

Event 2 - Tave failure Event 3-PZR pressure Inst fails high Event 4-Loss of one cond pump, Event 5-Loss of PB03-Loss of all three cond pumps, trip MFPs Event 6 - ATWT LOMFW, for the Majors.

Loss of NB01 is an event by itself on the D-1 and B sequencer failure is another event by itself. They are Malfunctions after EOP entry so it is more clear to see it that way from the D-1.

2 Scenario 2 Event 1 and event 2 were both used on 2017 exam low power scenario 3. The Tube leak and tube rupture events 4 and 5 were on scenario 4 of 2017 exam (as events 4 and 5).

For this scenario, lets use the following:

Just beyond point of adding heat:

Event 1 - pull rods to increase power (RO-normal)

Event 2 - Inadvertent start of 1 MDAFW pump (BOP)

Event 3-event 2 same as written (ASD A fails open) (BOP)

Event 4-RCP A vibration (RO)

Event 5-DBA LOCA on the A RCS hot leg for the major, which hasnt been done in several exams. Finish off with CTs appropriate for the DBA LOCA Licensee agreed to make the requested changes.

3 Scenario 3:

Event 1 - This was event 2 as submitted MT vlv 3 failure (load reject fails however, must manually reduce power)

(ALL)

Event 2-dropped rod as is Event 3-RCS high act as is Event 4-DFWfailure as is Event 5-keep everything else the same.

Licensee agreed to make the requested changes.

4 Scenario 4: Stays mostly the same as submitted with the exceptions below:

Event 2 - since this event was used on scenario 1 (event 3) of the 2017 exam Licensee checking on CT criteria, other changes agreed to change.

we need to change it to N44 failing high (not N43).

CT1 is bounded well if dryout can occur inside of a 90 minute scenario.

CT2 is not bounded well. Is there a time with no power that the seal starts to degrade? If so, how do you tell, monitor for a leak out the seal package? If so what is the time to this or what amount of leakage is not acceptable for pass/fail criteria (I assume it is none)?