ML22354A250
| ML22354A250 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/14/2022 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Entergy Operations |
| References | |
| Download: ML22354A250 (1) | |
Text
Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE COMMENTS Facility:
RBS First Exam Date:
12/5/22 Written Exam Outline Comment Resolution 1 NRC Auto-Generated N/A 2 Replacement K/As Acceptable N/A Administrative JPM Outline Comment Resolution 1 Label all Admin JPMs A1, A2, etc.
Made the correction as requested.
2 Include verbiage and importance rating of K/A referenced.
Made the correction as requested.
3 A3 - Specify the pump being tagged out.
Made the correction as requested.
4 A5 - Be more specific about what is meant by predictor case Made the correction as requested.
5 In section 3 of instructions, include the actual quantitative value in red parentheses, e.g. [2]
Made the correction as requested.
Control Room / In-Plant System JPM Outline Comment Resolution 1
Label each JPM simply S1, P1, etc. For quick reference, document S1.
Alternating CRD Pumps for example.
Dont need RJPM-OPS-S1 Made the correction as requested.
2 Include K/A and importance rating, if pulled from K/A catalog, or site-specific task list. You can include this in the narrative section at end of document, which I like.
Made the correction as requested.
3 P1 - Be more specific about what is being performed than just Enclosure 5 Made the correction as requested.
4 S-1: This doesnt appear to be an alternate path is it really a malfunction if D/P is slightly low out of band and needs to be adjusted upwards? Appears to be a standard part of evolution.
Lets discuss. The Drive D/P being out of spec and requiring adjustment is abnormal since it rarely occurs during a CRD pump rotation.
OBDI 202 - IOLE Process Rev 3 5
I would like every JPM to include the following boilerplate statement at the end of the task standard: The applicants actions did not degrade the condition of the plant beyond that introduced by the JPM as developed.
We will incorporate in task standards.
Simulator Scenario Outline Comments Scenario 1 Comment Resolution 2
Make the first section of the guide portrait layout, not landscape. [all scenarios]. See past submittals.
Made the correction as requested.
3 Make the Event Description table a quick reference phrase: Degraded CCP pump, standby fails to auto-start.
Feedwater Pump low suction pressure. The narrative is good, but paste all that into a paragraph style narrative at the end of the outline. [all scenarios]
Made the correction as requested.
GENERIC: If any major transients are repeated from past 2 NRC exams, provide a statement how it substantively differs in nature or response, per NUREG 1021 guidance.
N/A 4
Event 3 low RFP suction pressure =
downpower: credit this as a Component Malfunction vice Reactivity, since the initiating event is a malfunction.
Made the correction as requested.
5 CRS should get credit for all the events the board operators do. [Generic]
Made the correction as requested.
6 Event 7 - credit this as a Component malfunction vice Major. There is no advantage to crediting more than one event as a Major, it only lowers the I/C bean count artificially.
Made the correction as requested.
7 CT-2: The bounding criteria of 15 minutes to EMX DEPRESSURIZE seems excessively permissive. I would expect that a criteria based on not exceeding MSCWL, -187 or -200, would be more appropriate. Lets discuss.
Bounded the ED critical task on not exceeding MSCWL -187 inches.
8 CT-1: The bounding criteria of 5 minutes to manually scram when level drops to level 3 seems excessively permissive.
A criteria based on not exceeding a parameter would be preferable, such as Bounded the Scram critical task to not allowing level to reach Level 2.
OBDI 202 - IOLE Process Rev 3 Level 2 (-43) or Level 1 (-143). Lets discuss.
Scenario 2 Comment Resolution 1
Event 6 /CT-1: Is this an ATWS, and is that what is being credited as a Major?
If ATWS, at what point should the crew recognize that the reactor failed to SCRAM?. If the plant would automatically protect itself absent of operator action (turbine trip to reactor scram), it wouldnt be a Critical Task.
We do not normally require the crew to anticipate an automatic protective action as a performance standard.
Both RPS and ARI will be inhibited at the beginning of the scenario. All automatic scram functions will not work.
2 Procedurally, at what condenser vacuum level is the crew first directed to SCRAM?
I would split the Loss of all Feedwater and the HPCS failure to start into 2 separate events.
Made the correction as requested.
4 Event 2 - credit as a C vice R since the downpower is in response to a component malfunction.
Made the correction as requested.
Scenario 3 Comment Resolution 1
Event 1, credit as C vice R.
Made the correction as requested.
2 Events 8 and 10 - do not list the CTs as separate events. They are required responses to events, not events themselves.
Made the correction as requested.
3 CT-2: this CT is usually bounded as prior to a third area exceeding Max Safe level, not bounded by time. The way this malfunction is crafted, within what timeframe will a 3rd area exceed Max Safe without operator action?
Made the correction as requested. The third area will be RHR C room.
Scenario 4 Comment Resolution 1
ATC does not have enough creditable events - 1 Reactivity and 1 Component malfunction only, all within the first 5 minutes of the scenario. Need to add Added another ATC Component malfunction before the Major.
OBDI 202 - IOLE Process Rev 3 an I/C malfunction for the ATC before the Major.
CT-1: I would not credit this as a pre-identified CT, since the crew would be expected to prevent a reactor scram as part of their normal response to the malfunction. Additionally, under Rev 12 guidance, if the crew failed to control RPV pressure and an automatic RPS actuation occurred, it would not be graded as a Critical Performance Deficiency, it would be graded as a Significant Performance Deficiency (2-point deduction vice 3). So, if the grading cannot result in a CPD, then it cannot be credited as a Critical Task.
Changed CT-1 to restoring power to the DIV 1 bus within 15 minutes of LOP.
2 CT-2: Why use MZIRWL vice MSCWL?
Lets discuss.
Used MSCWL as my bounding criteria instead of MZIRWL 3
If the Major Event is a SBO, then there should be a CT associated with mitigating the transient. Is there a success path to restore power to at least one safety bus? The CT would be based on that.
Changed CT-1 to restoring power to the DIV 1 bus within 15 minutes of LOP.
4 5
GENERIC Scenario Comments Comment Resolution 1
The following applicants are at risk :
RO1, RO9, RO3, RO7: Bare minimum number of I/C/RX/N events, no margin.
So if another applicant steals a bean, they have to run the spare.
We will evaluate adding another I/C to ensure margin.
2 Form 3.4-1, Crew B, who is filling out the CRS and ATC position? You can have a surrogate for CRS, but one of the 2 ROs will need to fill out the ATC position.
The third day will have the two instants with a surrogate CRS and the two ROs from Crew A with a surrogate CRS. See rotation on next page.
3 Form 3.4-1, Crew C, why are RO5 and RO6 assigned to perform Scenario 3 when they dont need it, and theres no CRS assigned?
3.4-1 Crew C was corrected. We will only run the third scenario twice and RO5 and RO6 will be done with first two scenarios.
4 Ensure that the SRO-Is all have at least 2 I/C events on the boards, and 1 RX manipulation OR a 3rd I/C on the boards.
They do, just something to keep an eye on.
Done.