ML20301A385

ST-2020-07 Draft Outline Comments

ML20301A385
Person / Time
Site:	South Texas
Issue date:	07/29/2020
From:	Greg Werner Operations Branch IV
To:	South Texas
References
Download: ML20301A385 (9)

Text

Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE COMMENTS Facility:

ST First Exam Date:

July 13, 2020 Written Exam Outline (Feb 17, 2020)

Comment Resolution 1 NRC Generated No comments 2

3 4

5 Administrative JPM Outline Reviewed (Feb 18, 2020)

Comment Resolution General-the process to develop an admin JPM is in section ES-301, page

10. It states to:

1. first select a KA from section 2 of the catalog, then

2. select a performance-based activity from your list

3. To the extent permitted by overlap, quality checks, and predictability: Attempt to select and modify existing op test materials from the banks.

For several of these JPMs the odds of selecting a KA from a list and getting the same KA and the same JPM as the previous 2 or even the third exam (2017) back is not reasonable for exam overlap and predictability. Also, for each area where there are missing admin tasks, you should try to write NEW material to fill those holes that your SAT program is missing. The QA check for these is AT LEAST 1 NEW or Sig. MODIFIED. You have 1 modified.

Should have a database or JPM number for tracking and pedigree. You guys used to do this and maybe you still do but that info is not on the outlines. This info helps with overlap and tracking purposes.

Licensee changed A1 to KA 2.1.19 and RO will calculate Sub-cooling margin using QDPS CET inputs.

OBDI 202 - IOLE Process Rev 3 1

For A1-Your A1 was used on the third exam back (2017) and its just not very likely that the same KA was hit and therefore the same JPM used for this exam.

I would like to see a calculation of SCM from CET inputs during an ICC event.

(example. What is the Westinghouse algorithm for CET inputs to SCM during ICC.highest 5 valid channels, etc).

You give them the list of channels or a screen capture of QSPDS and have them manually calculate the value for SCM. This will give you a new JPM with a new topic and with applied TS will give a new A6 JPM for the SRO.

2 For A2 - Your A2 was used on the third exam back (2017) and its just not very likely that the same KA was hit and therefore the same JPM used for this exam.

I would like to see a time to boil/time to core uncovery calculation. This will give you a new JPM with a new topic and translates well for the SRO portion with containment hatch closure requirements Licensee changed A2 to have RO calculate RCS time to boil following loss of all RHR during mid-loop.

3 For A3 -okay as long as the tags are different or strategy is different (counted as modified-please send the parent JPM in draft exam submittal)

Licensee will submit with draft submittal.

4 For A4 - Both A4 and A8 JPMS on RP topics are exactly the same as the 2018 exam. Too predictable.

I would like to see a stay time calc based on EAD limit from the RWP instead of an admin limit for a given job.

Licensee developed a new JPM.

5 For A5 - Same as A1 with applied TS for CETs that are OOS.

Licensee changed A5 to KA 2.1.19 and SRO will calculate Sub-cooling margin using QDPS CET inputs and Apply TS.

6 For A6 -Same as A2 (TTB) with containment closure requirement for SRO (ie give them a short TTB and hatch closure is required determination for SRO)

Licensee working on this to pair with A2 with TS.

7 For A7 okay. Be sure to send the parent JPM to review for modified JPM.

8 For A8 Determine emergency entry for high dose and who authorizes it Licensee will develop JPM for this topic.

OBDI 202 - IOLE Process Rev 3 9 A9-okay. Be sure to send the parent JPM to review for modified JPM.

Control Room / In-Plant System JPM Outline Reviewed (Feb 18, 2020)

Comment Resolution General comments Too much use of previous material (3 JPMs used from 2017 exam and one on 2018 exam) so we will need to change two of those items to reduce predictability.

Should have a database or JPM number for tracking and pedigree. You guys used to do this and maybe you still do but that info is not on the outlines. This info helps with overlap and tracking purposes.

1 For S1-okay 2 For S2-okay 3 For S3-okay 4

For S4-Need to change this one due to predictability (it was on the 2017 exam).

I would recommend a QPTR JPM. I think you have one in your bank for this that is alt path. Another alternative is starting a CR vent fan and have a valid rad monitor alarm come in but the system fails to auto isolate/re-align the CR and it has to be manually done.

Something like that meets SF7 and is alt path but not use FHB.

Licensee used a similar JPM to the suggested one on the 2019 exam and may use it for the audit.

Licensee will develop another JPM.

5 For S5-This was used on 2018 exam and if we change it to be the normal path JPM then it would be different than the last exam. SF5 Licensee will change to Normal Path 6

For S6-this JPM was also on the 2017 exam but with 2/3 changed (S4 and S7) it is acceptable to keep it. SF4S.

7 For S7-you have a bank JPM on RCB Supp purge that is alt path that I would like to try to use in its place. SF8 Licensee will change to Containment purge Rad Monitors. They normally use this in SF7 but it can fit SF8. (029 Containment Purge)

Also this is alt path and will cover for the change to S5 going to normal path.

8 For S8-okay SF2 9 P1, P2, and P3 are good

OBDI 202 - IOLE Process Rev 3 Simulator Scenario Outline Comments Reviewed (Feb 19, 2020)

Comment Resolution General comments -

1. The NUREG requires that scenarios are varied over core life and core power. We need to have one scenario at mid-level power (approx. 50%) since we have six scenarios. Also, none of the scenarios have a designated time in core life on the D-1 form.

The low power is most operationally valid at BOL, while the 100% power scenarios should have at least one at MOL and at least one at EOL to meet the NUREG. The mid-power is probably best at BOL.

2. You need to have a balanced set of beans for each scenario-so at least two for the BOP and two for the ATC, before the major.

3. The reason normal events can be substituted with malfunctions starting in rev 9 of the NUREG was to provide more competencies for grading and to allow for demonstration of control when the plant is moving (rx and secondary, via transients). It also raises the LOD of each scenario.

We dont need the normal in most cases if you want to remove them (the low power rod pull does not count against overlap or as a normal so dont remove it). We will see how it all looks during validation for time.

4. At least two CTs must be unique for an entire scenario set (affects predictability from day to day).

See scenario 2 and 3 for details.

5. We need to have an inadvertent start event on one scenario to see if the station can handle it.

That would give you a different but new bean. There has been more industry OP Ex on this-Licensee main comments here is that they lost another SROI from class. Now at 19 total. (6 RO, 10 SROI, 3 SROU)

However, this will allow us to reduce down to 5 total scenarios instead of 6. We will not use scenario #2 which will take care of one of the biggest concerns and that was with having similar CTs on scenario #2 and #3.

It will also allow us to use some of the events from scenario #2 on other scenarios to fill in the gaps where we had concerns about having enough events per scenario for each RO.

On all scenarios, CT numbers will be put on the first page of the D-1.

Licensee will put an inadvertent start into one of the scenarios.

OBDI 202 - IOLE Process Rev 3 switchyard events that started all injection pumps.

6. I have proposed changes that reduce the overlap events and balance the loading for the two board positions. See scenario suggested changes at end of comment file.

1 Scenario 1 comments

1. We might need another bean for the ATC position to have a balanced scenario (we have 2 BOP and 1 ATC now). Also the ATC bean is a normal and this one doesnt give much insight on ATC performance on several grading competencies such as alarm response, diagnosis, manual control, etc. A better bean would be adjust ASI-then get a rod control fault that could be reset.

2. The second bean to add for the ATC could be something like putting a different orifice in service for letdown. This is a more challenging normal.

3. Put CT-13 and CT-46 on first page of D-1

4. To make CT-13 more challenging should have to trip EHC pumps to trip the turbine.

5. On CT-46-how long does it take to get to 1200F on CETs? If it takes a long time (greater than 30 or so minutes, then this CT is not bounded properly).

Licensee comments that AFD adjustment may not work because they typically adjust for AFD at only 1/2 step at a time.

Suggest a malfunction with a perturbation in CCW flow and have one RCP CCW Thermal Barrier isolation valve go closed. Will check at validation ad provide comments then if it works.

Licensee suggested have two orifices in service and we close one. We typically do not close and open orifices at the same time even though there is a section in the procedure to do it. Sounds reasonable.

This can be added for EHC.

Licensee stated that we maybe use orange path to make it bounded properly. Will check during validation and adjust as needed.

2 Scenario 2 comments

1. Put CT-10 and CT-17 on first page of D-1

2. We might need another bean for the BOP position to have a balanced scenario (we have 2 ATC and 1 BOP now).

3. Because CT-17 is on this scenario and scenario 3 we will need a third CT in order to meet the NUREG for two unique CTs per scenario or modify CT-17 to be different.

Licensee removed Scenario #2 due to class shrinkage.

3 Scenario 3 comments

OBDI 202 - IOLE Process Rev 3

1. To change the condensate pump trip event to a different event for overlap, all you have to do is make it the other pump that trips

(#11?)

2. Put CT-17 and CT-34 on first page of D-1

3. We need a different malfunction after EOP entry for CT-17 to make it different than the normal CT-17 (ie a different failure for isolation), otherwise it is too similar to CT-17 on scenario 2 and that would require a different major. I would also recommend calling them CT-17a and CT-17b not only to distinguish them but also to alert the examiner/auditor that different items are required to be manipulated to isolate the SG in the two scenarios.

4. Because CT-17 is on this scenario and scenario 2, if we dont modify it then we will need a third CT in order to meet the NUREG for two unique CTs per scenario.

5. Event 6 is two events post major and should be split to events 6 and event 7 (op bkr for E1C/2A to E1C2 fails to auto close)

Licensee making changes and will see how well it works during validation.

4 Scenario 4 comments Became the spare as scenario 3 after validation.

These comments were resolved however they were removed since it was the spare and was not used.

Licensee renumbered scenarios after validation week so this scenario became scenario 3 for final submittal (hence the difference it withheld scenario numbers) 5 Scenario 5 comments

1. CT-36 needs bounding criteria for the second part (ie re-establish ECCS injection before

???)

Licensee will add that the RWST level should not go to 0% while any pumps taking suction from the RWST are running.

OBDI 202 - IOLE Process Rev 3

2. We might need another bean for the ATC position to have a balanced scenario (we have 2 BOP and 1 ATC now).

3. Event 1 might be better if we drop or transfer a bus that has EHC on it and requires starting another pump or restarting the previously running after the transfer or have a small leak in EHC (not enough to trip, and be isolated) to be more dynamic than a normal (see general comments section above on normal events).

4. Recommend placing text ATWT on the line item for event 4 with the description. Just an optics issue to match the NUREG.

5. Put CT-2 and CT-36 on first page of D-1

6. Scenario 3, 5 or 6 should be around 50% power to meet NUREG for variations in power across the scenarios (we have 6, so 4 at full power, 1 at Mode 2, and one at 75%, which is just around the power level where a second feed pump is needed).

One of these we need to change power to 50% or 60% if possible without messing up the scenario elements. We can discuss this when you get the comments.

Licensee will see about take out TS Only on ESF DG Starting Air and add CCP sheared shaft as recommended. Check when validating it.

Licensee will add the EHC leak on the pump started.

Licensee suggested the following:

Scenario 1 - 100%

Scenario 2 - 95%

Scenario 3 - 75%

Scenario 4 - Mode 2 Scenario 5 - 50%

Scenario 6 - 100%

and will ensure BOL, MOL and EOL are used.

6 Scenario 6 comments

1. CT-16 bounding does not make sense to me. Trip RCPs before orange path on core cooling when RCPs are stopped??

2. Put CT-16 and CT-11 on first page of D-1

3. Recommend placing text LOCA on the line item for event 5 with the description. Just an optics issue to match the NUREG.

Licensee: This has been standard wording for this CT, however, a few years ago it was 5 minutes.

Done.

See suggested event and scenario changes on next page.

OBDI 202 - IOLE Process Rev 3

OBDI 202 - IOLE Process Rev 3 100%

95%

75%

Mode 2 100%

100%

Scenario 1 (2020)

Scenario 2 (2020)

Scenario 3 (2020)

Scenario 4 (2020)

Scenario 5 (2020)

Scenario 6 (2020)

Adjust ASI-rod control fault-RO (TS?)

CCW pump 1A trips and 1B fails to auto start (RO, TS)

PZR level inst LT-0465 fails high W/D control rods to raise power to 1-3%

transfer bus or leak that causes EHC loss oil sight glassbroken on CS pump 1B Swap Letdown orifices-RO Possibly containment buiding chiller or cooler fails, requiers start of standby-pushes containment cooling closer for CT-XXX (BOP)

SG 1A PORV press xmtr PT-7411 fails high PR NI-44 fails high Shaft Shear of running CCP-RO (TS)

CRDM vent fan 12A?

Trouble-change fan and is it not the same event SG 1A Main Steam Rad Mon RT-8046 failure-SRO only TS Loss of load-GV #1 fails closed Condensate pump #11 trips DRPI indication for rod H6 fails (both channels)

One droppped control rod D-12 PZR PT-0457 fails low SG 1D Controlling NR level channel fails low. LT-0549 (TS)

PZR Porv PCV-655A comes open and sticks partially open (TS)

Main Gen stator cooling DT alarm due to high DT across statot bars-requires fast load reduction RCP vibration SG 1C MFRV stuck in current position (recognized when dropped rod occurs)

SGFPT #13 trips with SGFPT #14 failure to start-downpower to 80%

LPHD Pump #11 trips SG 1A FW line break inside containment-major SG 1B faulted and ruptured. Faulted on MS line in IVC-Major RCP trips-ATWT-Major 1 LBLOCA - major Ejected Control rod H8-LOCA-Major Main Gen O/P BKR trips-Rx trip MS deaerator suuply valve MS-PV-7174 partially opens on rx trip Loss of ESF power to E1C PZR SBLOCA - major 2 Failure of train B essential chillers to start CIS Phase A fails to actuate Main turbine fails to auto trip -major SG 1a FWIV FV-7141 fails to auto close on rx trip E1C LC breaker for E1C2 fails to auto close Seal return isol vvls MOV-0077 and MOV-0079 fail to auto close Auto swap to cold leg recirc fails Train B of CIS has stuck open valve ED-MO-7800 Inadvertent FWI Group 1 steam dumps fail to open ED-MOV-0064 has to be manually closed Loss of Heat Sink-Major 2 CT-13 manually trip turbine by tripping EHC pumps before orange path either on subcriticality or integrity CSF or before transition to EO-EC21 CT-10 manually close block valve for partially stuck open PORV 655A such that a manual or automatic Rx trip does not occur CT-17 isolate a faulted SG before transition to EO-E020 (Faulted SG procedure)??

CT-1 manually trip rx by opening breakers 1K1 and 1L1 for Rod MG set power prior to completing step 1 of E0 CT-2 manually actuate at least one train of SI before transition past step 4 of E0 CT-16 trip RCPS before orange path on core cooling when all RCPs stopped-????

CT-46 Initiate Feed and Bleed so that HHSI injects prior to CET reaching 1200F or red path on core cooling CT-17 isolate a faulted SG before transitioning out of EO-E20 CT-34 begin RCS cooldown to preclude a transition to EO-EC32 (SGTR with sat recovery desired)

CT-??? Reduce SG PORV setpoints to between 990 and 1000 psig within 45 minutes of SBLOCA CT-36 manually align SI for cold leg recirc prior to RWST level reaching 6% "RWST empty" alarm (32,500 gal) or stop pumps taking suction from RWST then realign and reestablish ECCS flow CT-11 Manually close ED-MOV-0064 when phase A CIS doesn't complete prior to completion of Addendum 5 of E0 CT-xx for rising temp in containment from fw break-use collers or CS spray?

overlap key yellow is overlap prev. 2 exams blue is overlap 3rd exam back orange is reactivity-which doesn't count for overlap pink is similar event but component changed same CT on two different scenarios (Scen 2 and 3 for the 2020 exam) therefore we will need a third CT for these scenarios so there is a minimum of two unique CT's per scenario suggested new or modified events from your submittal