ML22131A213
| ML22131A213 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/24/2022 |
| From: | Chuck Zoia NRC/RGN-III/DRS/OLB |
| To: | Energy Harbor Corp, FirstEnergy Nuclear Operating Co |
| Zoia C | |
| Shared Package | |
| ML20140A262 | List: |
| References | |
| L-22-061 | |
| Download: ML22131A213 (4) | |
Text
D-B 2022 Exam 150-Day Outline Review Comments Administrative Topics Outlines (Forms ES-301-1)
RO A 1.1 - RPS Daily Heat Balance Check per DB-NE-03230
- 1. The K/A description was from NUREG-1122, Revision 3, whereas the written exam outline was from NUREG-1122, Revision 2, Supplement 1. Per OL Feedback 401.56; a licensee may request a written examination outline verbally or in writing prior to September 25, 2020, and the associated examination will be prepared using Revision 2, Supplement 1 of the respective K/A catalog Revised ES-301-1 RO A 1.1 to match NUREG-1122, Revision 2, Supplement 1.
2.1.25 (3.9)
Ability to interpret reference materials, such as graphs, curves, tables, etc.
- 2. The 2020 exam had an SRO-only JPM called Review DB-NE-03230, RPS Daily Heat Balance Check, which may be too similar to not be designated (P)revious 2 exams.
As discussed, this JPM will be designated as (P).
- 3. Changed K/A based on questions to 2.1.25, Ability to interpret reference materials, such as graphs, curves, tables, etc. - ACCEPTABLE, but the Importance is wrong!
Verified RO Importance rating for 2.1.25 is 3.9 in NUREG-1122, Revision 2, Supplement 1, which is listed on revised Form ES-301-1.
RO A 1.2 - Perform a Boric Acid Batch Calculation
- 1. The 2021 exam had an SRO-only JPM called Perform review of a Boric Acid Batch Calculation, which may be too similar to not be designated (P)revious 2 exams.
- 2. NOTE: Review RCS batch addition calculation was also performed on the audit.
JPM RO A 1.2 changed to JPM261M 2.1.18 Ability to make accurate, clear, and concise logs, records, status boards, and reports.
(CFR: 41.10 / 45.12 / 45.13)
IMPORTANCE RO 3.6 SRO 3.8 SRO A 1.1 - Review Misc Inst Daily Checks DB-OP-03007
- 1. Changed the K/A wording to NUREG-1122, Revision 2, Supplement 1 based on early feedback - ACCEPTABLE.
SRO A.3 - Review a Calculated Shutdown Value
- 1. Changed the K/A wording to NUREG-1122, Revision 2, Supplement 1 wording based on early feedback - ACCEPTABLE.
SRO A.4 - Review a Calculated Shutdown Value
- 1. Changed the K/A wording to NUREG-1122, Revision 2, Supplement 1 wording based on early feedback - ACCEPTABLE.
D-B 2022 Exam 150-Day Outline Review Comments System and In-Plant JPM Outlines (Forms ES-301-2)
S7
- Failed NI, DB-OP-02505 Step 4.1.9
- 1. Question: Is E or EN applicable?
A: It is not EN. This JPM will be performed in the RPS Cabinets.
A: Upon further review, it will be designated as E since the activity is directed by an Abnormal Procedure.
S8
- Start CTMT purge IAW DB-OP-06503, Section 3.3
- 1. Question: Is E or L applicable?
A: No, it is performed at 100% power to support post maintenance testing.
Scenario Outlines (Forms ES-D-1)
GENERAL - Critical Task (CT) information initially provided for all scenario outlines was insufficient to properly gauge their adequacy. Critical Tasks were listed as pre-defined CT numbers and titles, and a more detailed description and timing within the scenario was required and was requested from the licensee. This detail was provided and is further discussed below.
GENERAL - Information was requested (and was provided) to support whether the Scenarios are new or significantly modified in accordance with Section D.5 of ES-301 as required by ES-301-4.
Scenario No. 1 (SC1 Summary and CTs)
- 1. The initially submitted outline was significantly revised based on feedback requesting more CT detail. It was then verified that all updated outlines received on 09/21/2021, containing the requested CT detail, replaced the more basic outlines received earlier.
- 2. CT-3: Isolate Possible RCS Leak Paths: Boundary criteria (time and/or limiting conditions) is needed to determine if the Required Action (Close the Pressurizer Spray Valve and PORV Block Valve) is adequately met.
Currently, the Bounding criteria is that the Pressurizer Spray Valve and PORV Block Valve must be closed prior to a Reactor Trip.
Also, added Technical Basis References to Justification for Critical Tasks.
- 3. CT-17: Isolate Overcooling SG AND CT-B: Protect RCP Seals: Question: Is there any technical bases for the boundary criteria listed (TS, FSAR, etc.)?
A: CT-17: Removed since it also on Scenario 2. SC1 will now have 2 CTs.
A: CT-B: Yes, added Technical Basis References to Justification for Critical Tasks and added further justification in the Safety Significance.
D-B 2022 Exam 150-Day Outline Review Comments Scenario No. 2 (SC2 Summary and CTs)
- 1. For Event 5 - Question: Is de-energizing E2 and F2 to trip the reactor an RNO IA response or part of the SCRAM choreography?
A: It is an RNO IA. The ATC will be required to go to the CTRM back electrical panel to de-energize the CRD System.
Also, see NUREG-1021, Appendix D, Section D for CT-24: Shutdown Reactor-ATWS for Safety Significance and Measurable Performance Standard boundary criteria.
Added further explanation to the Safety Significance.
- 2. CT-17: Isolate overcooling Steam Generators - Question: Is there any technical basis for the boundary criteria listed (TS, FSAR, etc.)?
A: Yes, added Technical Basis References to Justification for Critical Tasks.
Scenario No. 3 (SC3 Summary and CTs)
- 1. Question: Why was CT-10 Establish Feedwater Flow and Feed Steam generators omitted?
A: Based on discussion, it was determined not to be a critical task since the end result of the drill is a loss of all feedwater.
- 2. For CT-1: Trip all Reactor Coolant Pumps please provide the Appendix K analyses.
Additional information will be added to the CT Justification.
- 3. CT-14 Initiate High Pressure Injection Cooling: Question: Is there any technical basis for the boundary criteria listed (TS, FSAR, etc.)?
A: Yes, Areva Tech Document 74-1152414-12, 3.3.B Establish MU/HPI Cooling for Davis Besse. This information will be added to the CT Justification Scenario No. 4 (SC4 Summary and CTs)
- 1. CT-10 Establish FW Flow and Feed SGs: Question: What is the expected timeframe for SG 2 level not being restored prior to reaching the SFRCS Low Level Trip setpoint?
A: Approximately 6 minutes from when the failure is inserted
- 2. CT-32 Bypass Emergency Core Cooling System Actuation: Question: What is the expected timeframe for SFAS RCS Low Pressure actuation with SFAS not blocked?
A: Approximately 1 minute from the time the block permits come in.
D-B 2022 Exam 150-Day Outline Review Comments Scenario No. 5 PROPOSED SPARE (SC5 Summary and CTs)
- 1. Low Power Scenario.
- 2. CT-1 Trip all Reactor Coolant Pumps is repeated, which could be a problem if applicants who were in Scenario No. 3 also needed the spare scenario. Consider rearranging the schedule and which scenario is chosen to be the spare to ensure that this is avoided.
Scenario 5 will be changed so that an additional critical task will be added to ensure at least two CTs will be different.
- 3. Question: Why is CT-2 Initiate High Pressure Injection listed on the D1 Form, but CT-2 (B) Flow Balance HPI Lines is what is in the Scenario Event Summary with its attributes described?
A: Critical Tasks were tied to the Critical Tasks listed in Areva Technical Document 47-1229003-06, EOP Technical Bases Document. This Critical Task did not exactly match CT-2 so it was listed as 2 (B). Critical Task numbers will be removed to eliminate confusion.
- 4. CT-2 (B) Flow Balance HPI Lines: Boundary criteria technical basis (TS, FSAR, etc.) is needed to support the need/timing of the Required Action (HPI valves not throttled within 10 minutes after Subcooling Margin drops below 20 Degrees in either RCS Loop) being adequately met.
Added Technical Basis References to Justification for Critical Tasks.