ML20276A157
| ML20276A157 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/09/2020 |
| From: | Greg Werner Operations Branch IV |
| To: | Ameren Missouri |
| References | |
| Download: ML20276A157 (8) | |
Text
Callaway Plant 2020-08 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 301-7, Operating Test Review Worksheet, because the licensees operating test submittal was reviewed and overall deemed SATISFACTORY.
Scenario 1 (98% MOL):
- 1. Event Narrative - specify what action statements are entered for each applicable TS (letters only, dont need verbiage) - PBS - updated the narrative description for both Technical Specification determinations
- 2. Event 5, clarify for me, when leak rate increases, it is a new leak on a separate location that increases the rate, requiring a trip and SI? PBS - The leak is in the same location (malfunction BB / BB005) and will grow upon the manual SI, this is labeled event 6.
There are 2 leak locations listed in event 5 and based on validation this was the preferred combination for applicant evaluation. In Summary: Event 5, BB005 malfunction ramps to 100 for a total leak rate of 120 gpm which is within the capability of charging but outside the procedural limit and hence a manual trip and SI are required.
The BB005 leak grows up manual SI. - this was revised after on site validation.
this is a practice Callaway used on the 2019 NRC exam because wither or not the CT present (i.e does RCS pressure reach 1425 psig) is a function of prior crew actions (aka starting ECCS pumps). Therefore this CT may or may not present itself and calling it optional was intended to save the NRC time vice calling it a write in CT. No action taken and will discuss during validation week.. - this was revised after on site validation and is now a CT.
- 4. Event 1, can we advance the starting conditions so crew only has to park 1 bank at 228 steps, and 1 bank at 220? I dont need to see them move 4 banks. - PBS -
Incorporated removed the directions for A and B banks for the applicants. Parking A and B CBs at 228 will be apart of the setup actions.
- 5. Event 2, booth operator cue: wait 1 minute, not 4. No value in sitting around waiting.
Generic for all events where an operator is dispatched consider them to conveniently be in the right place at the right time on their rounds. - PBS - updated as indicated
- 6. Lets try to trim down some pages off of this by more efficiently using space. For example pg 21, I dont need a list of every computer point. - PBS -My practice has been to include the entire procedure step to ease following along. Will discuss during validation week what you would like cut out of each scenario.
- 7. E-0 Step 5, PERFORM Attachment A, Automatic Action Verification, While Continuing With This Procedure. Heres how I want to handle this attachment on all scenarios, reference that the attachment is at the end of the procedure just like you did, but list all the manual actions that the operator will have to take to complete the attachment. For the actual attachment, you can include the pages from the procedure directly, instead of transcribing. Easier to follow along for everybody. - updated to best of my ability for each scenario
- 8. In these guides, if the position is ATC, use that instead of RO, since that is the language we will be using in our writeups. PBS - replaced RO with ATC throughout scenario guide, replaced SRO with CRS on page 1 of D-1.
- 9. It would be helpful if the verifiable actions - those steps where the operator is actually manipulating a component - are bolded. - same reply as comment 7 above.
Post-Validation
- 10. Need to add to D-1 RHR Pump B trip on E-1 entry as part of event 7. PBS - This statement was on event 6 - moved it to event #7
- 11. D-1 Narrative: refer to the major event as a SBLOCA, not an RCS leak. PBS - reworded the narrative's last 3 paragraphs to "SBLOCA"
- 12. Event 5, need steps for placing excess letdown in service since leak still propogates until charging is reduced to seals only, due to 1/4 inch x-conn line between letdown and charging. PBS - Added Attachment G of OTO-BB-00003 to establish excess letdown as an attachment at the end of the scenario. Note: with the size of the leak, charging at seals only, PZR volume per inch, some crews may or may not place a high priority on this as PZR level will be relatively stable and you may or may not want to wait for this evolution. But the steps are added to establish excess letdown to the VCT.
- 13. Event 6, SBLOCA ramps from 0-500 gpm over 4 min. PBS - made event 6 of D-1 this title and on the narrative page.
NRC OK Scenario 2 (50% BOL):
- 1. Add to CT-3, If the RCS reaches saturation conditions (Subcooling = 0) or Pressurizer NR level reaches 100% the depressurization continued for too long and this Critical Task is not met." - PBS - this is already in the CT. It is in the table for "justification for chosen performance limit section", last paragraph. Also added to CT statement
- 2. CT-3 definition, how late is too late to start depressurizing? - PBS - Will discuss during onsite validation - no change to scenario based on this comment.
- 3. Same comment as scen 1 re: Attachment A, and bolding verifiable actions. Highlight those actions necessary to satisfy CT. -addressed
- 4. CT-2 specify what the Red/Orange path RCS temperature is. - PBS - There is no specific temperature associated with the Subcriticality CSF as temperature must lower far enough to add enough positive reactivity to either raise PR NI to greater than 5%
(RED CSF) or make IR NI Startup rate positive (ORANGE CSF). The integrity RED CSF cold leg temperatures are a function of pressure and vary from 175F to 245F. The integrity ORANGE path cold leg temperatures are 245F and independent of RCS Pressure. Will discuss during onsite validation. - no change was made after onsite validation.
Post-Validation
- 6. The D-1 event types are still alternating between CRS (C) BOP (C) format and C (CRS, BOP) format. Make consistent - See Scenario 4 comment 1. PBS - fixed
- 7. We made a change during validation to ensure that B MSIV would not close even with Fast Close, and remain open during the scenario. Make this clear in the D-1 and narrative. PBS - fixed Added wording to the effect of "the 'B' MSIV will fail to close (automatically or with its handswitch) which will require the crew to fast close all other MSIVs" and "Failure of 'B' MSIV (AB HIS-17) to close, fast close all other MSIVs."
- no as the remaining steps in the RNO are 'if all " which isnt the case.
- 9. Event one Start MFP was replaced with new event to transfer MFP A from MAN to AUTO control. PBS - yes incorporated
- 10. Event 3, CCW leak rate reduced from 200 gpm to 150 gpm to make a RX trip on low Surge Tank level less likely. PBS - Added 150 to narrative and D-1.
- 11. Event 4 TS, I have a note that TS 3.7.5 Cond A will only be declared if ABV0085 is shut before the RX trips. PBS - yes 3.7.5 Condition A would apply if ABV0085 (Steam Supply to the TDAFP from B SG) but if the crew doesnt before the major event it wouldnt be appropriate at this time. Reworded TS determination to "IF ABV0085 is closed, the CRS should declare Tech Spec 3.7.5 Condition A not met."
NRC OK Scenario 3 (22% BOL): (SPARE)
- 1. Same comment as above, re bolding verifiable actions. -updated as appropriate
- 2. CT-2, still want to discuss bounding criteria when we run this scenario during validation week. - discussed. After on site validation, CT 1 bounding was discussed and determined to be 30 minutes vice 15 minutes.
Post-Validation
- 3. The D-1 event types are still alternating between CRS (C) BOP (C) format and C (CRS, BOP) format. Make consistent - See Scenario 4 comment 1. - PBS - fixed made the D-1 read as C (CRS, BOP) etc for all.
NRC OK Scenario 4 (80% EOL):
- 1. Page 1 of D-1, make the event type documentation consistent - some are listed by position (SRO(C)) and some are listed by type (I (CRS, ATC BOP)). Make all event all scenarios the same (second example is correct). Also use the term CRS and ATC instead of SRO and RO (all events, all scenarios). PBS - replaced RO with ATC throughout scenario guide, replaced SRO with CRS on page 1 of D-1.
- 2. examiner note in the lefthand column (pg 9 of 45) not really readable when they go so long in one narrow column. This column is a lot narrower than others. - PBS - Fixed
- 3. Same comment as scen 1 re: Attachment A, and bolding verifiable actions. Highlight those actions necessary to satisfy CT. - updated to the best of my ability.
Post-Validation
- 4. The D-1 event types are still alternating between CRS (C) BOP (C) format and C (CRS, BOP) format. Comment 1 of this scenario is uncorrected. Event 1 format is the correct one, for all scenarios. PBS - fixed made the D-1 read as C (CRS, BOP) etc for all.
- 5. Event 2 replaced.
- 6. Event 2 TS call should read as follows: PBS - changed as indicated NRC OK
- 1. All JPMs: make it immediately clearer which JPM this is. This JPMs title is OTO-RO-S-004 which makes it look like it is S-4, although it is S-1. I see the small font S1 in the corner but this needs to be clearer. - Fixed JPM S1:
- 1. Why is the Charging System not available, and how does the applicant identify it in alternate path? Is a fault occurring after starting the JPM or does it exist from the outset?
Not clear to me from the JPM. - PBS - The charging system is not available from the beginning of the JPM and the directions for the JPM setup explain how. The fact that charging is not available, and the operator must determine that from the indications given, provides the alternate path for using the B SI pump for boration per Attachment B.
- 3. At Step 5, what prevents the candidate from starting SI Pump B (EM HIS-5)? Shouldnt there be a cue from the CRS to emergency borate using SI Pump A? - PBS - Can not provide cue in initiating cue as this would cue the alternate path of implementing Attachment B. Procedure Step B1 says start one SI pump and the applicant could start the B pump at this point, in which the non critical JPM steps #6-9 would be N/A.
Validation results were that the operators would always start A Pump first. Updated Notes of JPM step #5 to say "If the applicant starts B SI pump first, then JPM steps #6-9 are N/A.". Additionally Steps #6 - 8 had a note stating " Note: Step applicable If the Applicant initially started the 'A' SI Pump"
- 4. Doesnt there need to be step to start SI Pump B in the JPM. I see flow path, but nothing that shows pump was started using EM HIS-5. - PBS - The note in JPM step
- 5 explained that Step #5 tracked the critical action of starting the 'B' SI pump. No action taken.
Post Validation:
- 5. 10 min vice 12 min validation time. Changes to simulator setup such that whatever train applicant attempts to borate from first will not work.
- PBS 8/18/2020 made change as requested. Also updated wording in JPM Step 9.
The wording in all 3 JPM steps now states "CHECK Boration Flowpath For Safety Injection Pump B/A" NRC OK.
JPM S-2:
- 1. No comments Post validation
- 2. 5 min vs 10 min validation time.
NRC OK.
JPM S-3:
- 1. Provide reference to a procedural direction that would require the applicant to take the actions he does for the alternate path. Need something procedural to reference if applicant does not take action. - PBS - updated note for 2 handed operation with procedure step. Added procedure steps for JPM step #5,6, & 7. Added note explaining the procedural actions OTO-BB-00006, PZR Pressure Control Malfunction, Step #20 RNO.a provides the procedural actions. Per ODP-ZZ-00001, Ops Department Code of Conduct, the applicant can take these actions prudently, as there is a pressing operational need.
Post Validation:
- 2. 5 min vice 8 min validation time. - PBS 8/18/2020 made change as requested
- 3. Mark up cue sheet to show completed 5.4.1 preparatory actions and notifications.
JPM S-4:
- 1. This is the second JPM that enters an alternate path before the applicant takes a single action (S1 is the first). I can agree to one, but two is not what Im used to seeing for meeting the intent of an alternate path JPM. This JPM doesnt not substantively satisfy the intent of an Alt Path for me. - PBS - Updated the JPM and cues to start at ES-0.2 Step #6 such that the applicant performs some actions prior to the alternate path beginning.
Post Validation:
- 2. 10 min vice 20 min validation time
- 3. Modified task standard to started at least 3 CRDM fans and simplified
PBS 8/18/2020 made change as requested JPM S-5:
- 1. Put the task standard in a bulleted list for clarity. Same with other task standards that look like this. - PBS - reformatted task standard as indicated above NRC OK JPM S-6:
- 1. Two verifiable actions (not counting matching flags) Im not sold that this is greater than LOD = 1. - PBS - This JPM is LOD 2 because the operator must perform two handed operation to satisfy interlocks allowing the operator to complete the task. This complexity and motor skills of having to hold one switch in a given position and manipulate another switch requires an ability greater than LOD = 1. Updated JPM critical step to explain this.
- 2. Updated JPM during validation week to required procedure section 5.3 and 5.6.
Post Validation:
- 3. Replaced with new JPM.
- 4. 10 MIN validation time NRC OK JPM S-7:
- 1. No Comments
Post Validation:
- 2. 10 min validation time NRC OK JPM S-8:
updated as directed.
Post Validation:
- 2. 10 min validation time
- 3. Removed critical requirement from opening EF HIS-51 and 59 from task standard.
NRC OK JPM P-1:
- 1. Why is examiner providing a cue sheet for OPEN and CLOSED indications? ). - PBS -
to better model actual plant indications that would be available the operator performing this task. Removed cue sheet after validation week.
- 2. I dont like that this is being credited as alternate path, because the applicant KNOWS that if everything is in the expected position, there would be NO actions to take. So the applicant knows that something is going to be out of position. Nothing is responding unexpectedly, the applicant is just finding things passively out of position. Same basic theme as my comments on S-4. OK as a normal path JPM. - PBS-Changed to normal path JPM. This puts all applicants at the minimum acceptable number of alternate path JPMs. On site Validation results - No longer Alt path and no replacement ALT path was made.
- 3. Validation time = 15 min vice 20 min.
- 4. Various changes to examiner cues and component indications post-validation.
NRC OK.
JPM P-2:
- 1. No comments
- 2. Validation week - provide additional picture cue. Reviewed potential alternate path option for this JPM and was determined not feasible. Remains normal path. 15 min validation time vice 19 min.
NRC OK.
JPM P-3:
- 1. No comments BC comments:
- 1. For Step 5, should examiner cue also include flow noise? Assuming you would hear the flow going through the pipe, since it is being throttled, even though flow is not that high (approx. 130 gpm). - PBS - added to the step #5 cues "and flow noise can be heard" and "and the flow noise is louder than before".
Post Validation:
- 2. 10 Min vice 15 min validation time.
NRC OK.
ALL ADMIN JPMS COMMENT: For any JPM that the applicant has to use a plot or a form to conduct calculations, include a filled-out key for the examiner to quick-reference.
JPM A-1:
- 1. No comments. - PBS - Inserted a page in order to provide curve book figure for evaluator quick reference.
NRC OK.
JPM A-2:
- 1. Edit cue to What additional shifts in the next 6 days shouldnt change the correct answer. - PBS - updated as directed.
NRC OK.
JPM A-3:
- 1. No comments
- 2. Validation time = 15 min vice 20 min.
NRC OK JPM A-4:
- 1. No comments.
NRC OK JPM A-5:
- 1. No comments.
NRC OK JPM A-6:
- 1. No comments.
NRC OK JPM A-7:
- 1. You can remove in writing from initiating cue, it already says document. - PBS -
updated as directed.
NRC OK JPM A-8:
- 1. No comments.
- 2. Various changes made to demographic data of volunteer employees post-validation.
NRC OK JPM A-9:
- 1. Need to include within 15 minutes of start of JPM in task standard. - PBS - added "within 15 minutes of the start of the JPM." to the end of the task standard.
NRC OK