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

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 Licensee changed A1 to KA 2.1.19 and RO admin JPM is in section ES-301, page will calculate Sub-cooling margin using

10. It states to: QDPS CET inputs.

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. OBDI 202 - IOLE Process Rev 3

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.

1 (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.

For A2 - Your A2 was used on the third Licensee changed A2 to have RO calculate exam back (2017) and its just not very RCS time to boil following loss of all RHR likely that the same KA was hit and during mid-loop.

therefore the same JPM used for this exam.

2 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 For A3 -okay as long as the tags are Licensee will submit with draft submittal.

different or strategy is different (counted 3

as modified- please send the parent JPM in draft exam submittal)

For A4 - Both A4 and A8 JPMS on RP Licensee developed a new JPM.

topics are exactly the same as the 2018 exam. Too predictable.

4 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.

For A5 - Same as A1 with applied TS Licensee changed A5 to KA 2.1.19 and SRO 5 for CETs that are OOS. will calculate Sub-cooling margin using QDPS CET inputs and Apply TS.

For A6 -Same as A2 (TTB) with Licensee working on this to pair with A2 with containment closure requirement for TS.

6 SRO (ie give them a short TTB and hatch closure is required determination for SRO)

For A7 okay. Be sure to send the parent 7

JPM to review for modified JPM.

For A8 Determine emergency entry for Licensee will develop JPM for this topic.

8 high dose and who authorizes it OBDI 202 - IOLE Process Rev 3

A9- okay. Be sure to send the parent 9

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 For S4- Need to change this one due to Licensee used a similar JPM to the predictability (it was on the 2017 exam). suggested one on the 2019 exam and may I would recommend a QPTR JPM. I use it for the audit.

think you have one in your bank for this that is alt path. Another alternative is Licensee will develop another JPM.

4 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.

For S5- This was used on 2018 exam Licensee will change to Normal Path and if we change it to be the normal 5

path JPM then it would be different than the last exam. SF5 For S6- this JPM was also on the 2017 6 exam but with 2/3 changed (S4 and S7) it is acceptable to keep it. SF4S.

For S7- you have a bank JPM on RCB Licensee will change to Containment purge Supp purge that is alt path that I would Rad Monitors. They normally use this in SF7 7 like to try to use in its place. SF8 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 - Licensee main comments here is that they

1. The NUREG requires that lost another SROI from class. Now at 19 scenarios are varied over core total. (6 RO, 10 SROI, 3 SROU) life and core power. We need to have one scenario at mid-level However, this will allow us to reduce down to power (approx. 50%) since we 5 total scenarios instead of 6. We will not use have six scenarios. Also, none of scenario #2 which will take care of one of the the scenarios have a designated biggest concerns and that was with having time in core life on the D-1 form. similar CTs on scenario #2 and #3.

The low power is most operationally valid at BOL, while It will also allow us to use some of the events the 100% power scenarios from scenario #2 on other scenarios to fill in should have at least one at MOL the gaps where we had concerns about and at least one at EOL to meet having enough events per scenario for each the NUREG. The mid-power is RO.

probably best at BOL.

2. You need to have a balanced set On all scenarios, CT numbers will be put on of beans for each scenario-so at the first page of the D-1.

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. Licensee will put an inadvertent start into one

5. We need to have an inadvertent of the scenarios.

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- 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.

Scenario 1 comments

1. We might need another bean for Licensee comments that AFD adjustment the ATC position to have a may not work because they typically adjust balanced scenario (we have 2 for AFD at only 1/2 step at a time.

BOP and 1 ATC now). Also the ATC bean is a normal and this Suggest a malfunction with a perturbation in one doesnt give much insight on CCW flow and have one RCP CCW Thermal ATC performance on several Barrier isolation valve go closed. Will check grading competencies such as at validation ad provide comments then if it alarm response, diagnosis, works.

manual control, etc. A better bean would be adjust ASI-then get a rod control fault that could be reset.

1 2. The second bean to add for the ATC could be something like putting a different orifice in Licensee suggested have two orifices in service for letdown. This is a service and we close one. We typically do more challenging normal. not close and open orifices at the same time

3. Put CT-13 and CT-46 on first even though there is a section in the page of D-1 procedure to do it. Sounds reasonable.

4. To make CT-13 more challenging should have to trip EHC pumps to trip the turbine. This can be added for EHC.

5. On CT-46-how long does it take to get to 1200F on CETs? If it takes a long time (greater than Licensee stated that we maybe use orange 30 or so minutes, then this CT is path to make it bounded properly. Will check not bounded properly). during validation and adjust as needed.

Scenario 2 comments Licensee removed Scenario #2 due to class

1. Put CT-10 and CT-17 on first shrinkage.

page of D-1

2. We might need another bean for the BOP position to have a balanced scenario (we have 2 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.

3 Scenario 3 comments OBDI 202 - IOLE Process Rev 3

1. To change the condensate pump Licensee making changes and will see how trip event to a different event for well it works during validation.

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)

Scenario 4 comments These comments were resolved however Became the spare as scenario 3 after they were removed since it was the spare validation. 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) 4 Scenario 5 comments Licensee will add that the RWST level should

1. CT-36 needs bounding criteria not go to 0% while any pumps taking suction 5 for the second part (ie re- from the RWST are running.

establish ECCS injection before

???) OBDI 202 - IOLE Process Rev 3

2. We might need another bean for Licensee will see about take out TS Only on the ATC position to have a ESF DG Starting Air and add CCP sheared balanced scenario (we have 2 shaft as recommended. Check when BOP and 1 ATC now). validating it.

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 Licensee will add the EHC leak on the pump EHC (not enough to trip, and be started.

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, Licensee suggested the following:

so 4 at full power, 1 at Mode 2, Scenario 1 - 100%

and one at 75%, which is just Scenario 2 - 95%

around the power level where a Scenario 3 - 75%

second feed pump is needed). Scenario 4 - Mode 2 One of these we need to change Scenario 5 - 50%

power to 50% or 60% if possible Scenario 6 - 100%

without messing up the scenario and will ensure BOL, MOL and EOL are elements. We can discuss this used.

when you get the comments.

Scenario 6 comments Licensee: This has been standard wording

1. CT-16 bounding does not make for this CT, however, a few years ago it was sense to me. Trip RCPs before 5 minutes.

orange path on core cooling when RCPs are stopped??

6 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 Done.

the description. Just an optics issue to match the NUREG.

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)

CCW pump 1A trips and Adjust ASI-rod control fault- PZR level inst LT-0465 fails W/D control rods to raise transfer bus or leak that oil sight glassbroken on CS 1B fails to auto start (RO, RO (TS?) high power to 1-3% causes EHC loss pump 1B TS)

Possibly containment buiding chiller or cooler CRDM vent fan 12A?

fails, requiers start of SG 1A PORV press xmtr Shaft Shear of running CCP-Swap Letdown orifices-RO PR NI-44 fails high Trouble-change fan and is it standby-pushes PT-7411 fails high RO (TS) not the same event containment cooling closer for CT-XXX (BOP)

SG 1A Main Steam Rad Loss of load-GV #1 fails DRPI indication for rod H6 One droppped control rod D-Mon RT-8046 failure-SRO Condensate pump #11 trips PZR PT-0457 fails low closed fails (both channels) 12 only TS Main Gen stator cooling DT SG 1D Controlling NR level PZR Porv PCV-655A SG 1C MFRV stuck in SGFPT #13 trips with alarm due to high DT channel fails low. LT-0549 comes open and sticks RCP vibration current position (recognized SGFPT #14 failure to start-across statot bars-requires (TS) partially open (TS) when dropped rod occurs) downpower to 80%

fast load reduction SG 1B faulted and SG 1A FW line break Ejected Control rod H8-LPHD Pump #11 trips ruptured. Faulted on MS RCP trips-ATWT-Major 1 LBLOCA - major inside containment-major LOCA-Major line in IVC-Major MS deaerator suuply valve Main Gen O/P BKR trips- Failure of train B essential CIS Phase A fails to MS-PV-7174 partially Loss of ESF power to E1C PZR SBLOCA - major 2 Rx trip chillers to start actuate opens on rx trip Seal return isol vvls MOV-Main turbine fails to auto SG 1a FWIV FV-7141 fails E1C LC breaker for E1C2 Auto swap to cold leg recirc Train B of CIS has stuck 0077 and MOV-0079 fail to trip -major to auto close on rx trip fails to auto close fails open valve ED-MO-7800 auto close Group 1 steam dumps fail ED-MOV-0064 has to be Inadvertent FWI to open manually closed Loss of Heat Sink-Major 2 CT-13 manually trip CT-10 manually close turbine by tripping EHC CT-1 manually trip rx by block valve for partially CT-17 isolate a faulted CT-2 manually actuate at CT-16 trip RCPS before pumps before orange opening breakers 1K1 stuck open PORV 655A SG before transition to least one train of SI orange path on core path either on and 1L1 for Rod MG set such that a manual or EO-E020 (Faulted SG before transition past step cooling when all RCPs subcriticality or integrity power prior to automatic Rx trip does procedure)?? 4 of E0 stopped-????

CSF or before transition completing step 1 of E0 not occur to EO-EC21 CT-36 manually align SI for cold leg recirc prior CT-46 Initiate Feed and CT-34 begin RCS to RWST level reaching CT-11 Manually close ED-CT-??? Reduce SG PORV Bleed so that HHSI injects CT-17 isolate a faulted cooldown to preclude a 6% "RWST empty" alarm MOV-0064 when phase A setpoints to between 990 prior to CET reaching SG before transitioning transition to EO-EC32 (32,500 gal) or stop CIS doesn't complete and 1000 psig within 45 1200F or red path on out of EO-E20 (SGTR with sat recovery pumps taking suction prior to completion of minutes of SBLOCA core cooling desired) from RWST then realign Addendum 5 of E0 and reestablish ECCS flow CT-xx for rising temp in containment from fw break-use collers or CS spray?

overlap key yellow is overlap prev. 2 blue is overlap 3rd exam orange is reactivity-which pink is similar event but exams back doesn't count for overlap 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 OBDI 202 - IOLE Process Rev 3