ML25350A180

From kanterella
Jump to navigation Jump to search
301; Post Exam Comments
ML25350A180
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 12/16/2025
From:
South Carolina Electric & Gas Co
To:
NRC/RGN-II
References
Download: ML25350A180 (0)


Text

2025 NRC JPM A1-a SRO:

During the performance of the A 1-a JPM for SR Os, one candidate performed the JPM differently than how it was validated. This lead to a new way to complete the JPM correctly.

While performing the calculation to increase RWST level, a candidate used the Tech Spec minimum value of 453,800 gallons to calculate the amount of gallons that must be added to get back to the Tech Spec minimum value. During validation and mostly during the JPM, candidates used the curve book to determine what volume would be at 92%

(462,683.75 gallons if calculated or 465,000 if reading the graph), since this is considered the Tech Spec minimum level based on Main Control Board indications. The difference between the two volumes is to ensure that the percent level accounts for indication inaccuracies.

They found the level at 64% (321,866.88 gallons), which was the given RWST level in the turnover document. They took the Tech Spec minimum value of 453,800 gallons and subtracted that from the current volume of 321,866.88 gallons. This gave them a total of 131,933.12 gallons to add to the RWST. They then divided 131,933.12 gallons by 80 gal/min since this is the total makeup flow and got 1649.16 minutes. Next they divided 1649.16 minutes by 60 min/hr which gave them 27.48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This led to the incorrect amount of hours being calculated for the add. However, they did get the Tech Spec portion correct in saying they must shut down to HOT STANDBY.

Because of the flow totalizers, we can account for the specific amount of water and acid being added to the RWST and therefore can accurately say we have a minimum of 453,800 gallons in the RWST. Therefore, we'd like to change the Task Standard times from 29.16 - 29.35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> to 27.48 - 29.35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />.

We ask that the task standard be changed in the following manner:

Calculates the time required to raise RWST level to a minimum of 453,800 gallons or 92% between 27.48 - 29.35 hrs.

Determines the crew must shutdown to HOT STANDBY.

Respectfully, 4~

Jeff Manross Shift Manager

2025 NRC JPM e:

JPM e required candidates to manually initiate Reactor Building Spray and close several Phase-B isolation valves. During the performance of this JPM, several candidates failed to close MVG-9606.

Upon further review, MVG-9605 and MVG-9606 are in series and only one of these two valves are required to be closed to ensure the required Phase-B Containment Isolation has occurred. MVG-9605 is inside the Reactor Building and MVG-9606 is outside the Reactor Building. See picture on next page from drawing 302-612, Component Cooling Water System.

We would like to change the Task standard so that it reads the following:

Candidate performs the following:

Closes the following Phase-B Isolation valves from the MCB:

MVG-9600, TO THERM BARR ISOL.

MVG-9605, FROM RB LOAD ISOL (IRB) AND/OR MVG-9606, FROM RB LOAD ISOL (ORB).

MVG-9568, TO RB LOAD.

Establishes at least one train of RB Spray with flow > 2500 gpm as indicated on Fl-7368 or Fl7378, SPR PP A(B) DISCH FLOW GPM.

Secures Reactor Coolant Pumps.

Respectfully, Jeff Manross Shift Manager

l W

Ul w

Q..

6" (f)

X R0h-14 9609-CC XPS CC SEE NOTE 4 ROL-2 9633-CC E-6

- 611 cc X

RN -25 9625-CC A-6

- 6 11

<1

J TC ESF ~-1-1 L

~

C SC CIV

\\ROg-3 9570- CC

~.....--

RNn-30 XVG'~60G-CC1\\

TC r., ~

2505X

-~TC R0h-14 9604-CC nnL 1

2025 NRC JPM A3 (SRO):

This JPM required candidates to use the indications given and determine that an ALERT was required to be declared. Based on this, the candidate was required to determine which notification was required in accordance with NL-122, REGULATORY NOTIFICATION AND REPORTING. The candidate was also required to determine the highest level of plant management at VC Summer that must be notified by the Shift Manager.

One candidate utilized OAP-100.4 based on his experience of performing certain actions during Emergency Response Organization (ERO) drills. This was not utilized during validations nor was it thought of when creating this JPM. The candidate said that the Global Notification list was required to be sent out which notified all senior level management positions, as seen on the following page. Attachment II, step 3.d. states "the STA, SM, and OMOC shall determine, based on issue/event, if the Global Page List or the Local Management Page List will be used to communicate that issue/event".

Then on Page 4 of Attachment II, there is a list of "notification criteria" and Item 4 on that list is "Activation of the Emergency Plan". This has all of the senior site level management that must be notified.

We ask that the task standard be changed in the following manner:

Candidate determines:

1-1 Determines that either the Operations Manager or the Operations Manager on Call (OMOC) must be apprised.

OR Determines the site personnel on the V.C. Summer Global Page List or the V.C.

Summer Local Management page list on Attachment II of OAP-100.4.

Respectfully, 4~

Jeff Manross Shift Manager

ST A Notifications OAP-100.4 ATTACHMENT II PAGE 1 OF 4 REVISION 4 This attachment conveys the expectations and responsibilities of the STA concerning notifications to Management and the NRC, and to establish consistency in those notifications.

1. Notifications are NOT to interfere with the STA's primary responsibility of maintaining a broad-based overview of the plant during events and/or operational transients; however, the expectation is that notifications will be made within the specified time frame.
2. This attachment provides a listing of criteria/conditions that require GenPager notifications. Additionally, a conference call may be made between the STA, the Shift Manager, and the OMOC (based upon the nature of the event) at the discretion of the STA to determine what additional notifications are needed.
3. The following applies to notifications requiring a GenPager notification:
a. As conditions allow, preferably within one hour, the STA shall make notification by Gen Pager if any of the conditions of the notification criteria exist. Delays in page notification may be appropriate, OMOC should be consulted for GenPager recommendations (e.g., for non-urgent issues, it may be appropriate to delay page until after verbal reports are made to OMOC and Operations Manager).
b. Gen Pager is accessed from the Dominion Energy Nuclear Homepage or from http://genpager.dominionnet.com//
c. The STA, SM, and OMOC shall determine, based on issue/event, if the Global Page List or the Local Management Page List will be used to communicate that issue/event.
d. Manually add the STA, OMOC and the Work Week Coordinator to all GenPager communications.

OAP-100.4 ATTACHMENT II PAGE2OF4 REVISION 4

e. The following is the V.C. Summer Global Page List:

CNO - CHIEF NUCLEAR SVP NUCLEAR VP NUCLEAR OFFICER OPERATIONS AND ENGINEERING & FLEET FLEET PERFORMANCE SUPPORT SITE VICE PRESIDENT DIRECTOR STATION DIRECTOR NUCLEAR SAFETY AND ENGINEERING LICENSING PLANT MANAGER MANAGER NUCLEAR MANAGER NUCLEAR MAINTENANCE OUTAGE AND PLANNING MANAGER NUCLEAR MANAGER EMERGENCY MANAGER NUCLEAR OPERATIONS PREPAREDNESS SITE SERVICES MANAGER LICENSING MANAGER MANAGER NUCLEAR ORGANIZATIONAL PROTECTION SERVICES EFFECTIVENESS MANAGER RADIOLOGICAL MANAGER NUCLEAR MANAGER SUPPLY PROTECTION AND ENGINEERING DESIGN CHAIN CHEMISTRY

& PROGRAMS MANAGER NUCLEAR SITE MANAGER NUCLEAR SUPERINTENDENT SHIFT ENGINEERING TRAINING OPERATIONS OPERATIONAL SUPERINTENDENT MAINTENANCE ADVISOR OPERATIONS SUPPORT

OAP-100.4 ATTACHMENT 11 PAGE 3 OF 4 REVISION 4

f. The following is the V.C. Summer Local Management Page List:

SITE VICE PRESIDENT DIRECTOR STATION DIRECTOR NUCLEAR SAFETY AND ENGINEERING LICENSING PLANT MANAGER MANAGER NUCLEAR MANAGER NUCLEAR MAINTENANCE OUTAGE AND PLANNING MANAGER NUCLEAR MANAGER EMERGENCY MANAGER NUCLEAR OPERATIONS PREPAREDNESS SITE SERVICES MANAGER LICENSING MANAGER MANAGER NUCLEAR ORGANIZATIONAL PROTECTION SERVICES EFFECTIVENESS MANAGER RADIOLOGICAL MANAGER NUCLEAR MANAGER SU PPL Y PROTECTION AND ENGINEERING DESIGN CHAIN CHEMISTRY

& PROGRAMS MANAGER NUCLEAR SITE MANAGER NUCLEAR SUPERINTENDENT SHIFT ENGINEERING TRAINING OPERATIONS OPERATIONAL SUPERINTENDENT MAINTENANCE ADVISOR OPERATIONS SUPPORT

g. Notifications made shall be documented in the Station Narrative Log.
h. Discretion shall be utilized for notifications to the CNO. (e.g., notify these individuals of significant events that have the potential to jeopardize unit operation).

NOTIFICATION CRITERIA

1. Unplanned Reactor Protection System or ESF actuation.
2. Any unplanned plant transient or load reduction.

OAP-100.4 ATTACHMENT II PAGE4OF4 REVISION 4

3. Any issue that may grade as Reactivity Management Significance Level 1 or 2 IAW OP-AP-300.
4. Activation of the Emergency Plan.
5. Unplanned entry into a Technical Specification LCO Action Statement of< 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (requires a Global Page List notification upon entry and update notifications every 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> while the condition exists).
6. Any equipment failures or operational conditions which the ST A or Shift Manager has determined warrant notification to Station Management.
7. Any reportable or potentially reportable occurrence as defined in NL-122.
8. Any emergent/unplanned change in on-line risk to higher than green or shutdown risk assessment from a green/yellow condition to an orange/red condition.
9. Valid entry into an AOP or EOP.
10. Any unusual, unexplained, or unanticipated response of the plant.
11. Unplanned radioactive releases less than reportable limits.
12. Any fires on-site.
13. Transportation of an injured person by station or offsite ambulance.
14. Unplanned mode changes.
15. Technical Specification LCO Action Statements that were unplanned that have been exited.
16. Other notifications as determined by Operations Management.
17. Notify station management for NRC prompt event notifications prior to NRC notification, if practicable.
18. Planned Technical Specification LCO Action Statement entries that exceed 1/2 of the action statement time. (requires a Global Page List notification).