ML12339A154

Limerick Generating Station - Facility Comments on Draft NRC-Developed Exam (Operating) (Folder 2)

ML12339A154
Person / Time
Site:	Limerick
Issue date:	11/15/2012
From:	Caruso J G Operations Branch I
To:	Wasong A J Exelon Generation Co
Jackson D E
Shared Package
ML120230224	List: IR 05000352/2012301 ML120270009 ML12276A134 ML12279A055 ML12325A281 ML12325A303 ML12325A327 ML12325A335 ML12325A347 ML12332A082 ML12339A154 ML12339A158 ML12339A166 ML12339A170 ML12339A183
References
TAC U01858
Download: ML12339A154 (14)

Text

Admin JPM Changes: JPM A-1.1, Evaluation of Overtime Hours to Determine Availability A-1.1, Evaluation of Overtime Hours to Determine Availability

• A-1.2, Review Drywell Floor Drain Sump/Equipment Drain Tank Logs and Determine Compliance with TS 3.4.3.2 A-1.2, Review Drywell Floor Drain Sump/Equipment Drain Tank Logs and Determine Compliance with TS 3.4.3.2 A-2, Review and Verify Blocking Required per

• 101 "Clearance and Tagging" A-2, Review and Verify Blocking Required per 101 "Clearance and Tagging" A-3, Review and Approve Inventory Release from . Equipment Drain Sample Tank to Cooling Tower Blowdown Line A-4, Emergency Plan Communications A-4, Emergency Plan Communications RO SRO RO SRO RO SRO SRO RO Changes Revised initiating cue per pre-validation comments, and changed Wed (10/3) to day off based on RO comment, to reset 9 day clock and eliminate confusion.

Revised the initiating cue, to provide more clarification on the task, per prevalidation SRO comments.

Added second critical task for identification of math error, edited ST and editorial changes to cue/task standard, and edited ST and editorial changes to cue/task standard.

Added second critical task for identification of math error, edited ST and editorial changes to cue/task standard, and edited ST and editorial changes to cue/task standard.

Removed Critical Element designation from the INFO tags associated with the two Handswitch blocking points listed in the Exam Key, and Revised what information is required for each blocking point Removed Critical Element designation from the INFO tags associated with the two Handswitch blocking points listed in the Exam Key and the Cue Sheet, and Adjusted parameters required and descriptions of isolation points, removed references to tag types Based on pre-validation comments, signed off sections 4.2.10 (S62.1.E) and 4.4 570-0) as completed, and Based on validation comments, added task conditions 7 and 8. Revised the 'Task Condition" and "Initiating Cue" information in the Cue Sheet, added an Evaluator Cue to Element 6, added information to several "Evaluator Notes" which support performance of the JPM either inside or outside of the Simulator. . Revised JPM requiring the applicant to recognize

• that the "Brief Non-Technical Description" label in Block 4.b (Page 1) of the ENF is missing, and for Element 2 require the applicant to recognize and take the appropriate action for failure of Berks County to respond to the initial roll call. Revised JPM to classify an Alert with Escalation to a General Emergency and make Protective Action Recommendations (PAR), and Changed initial classification from Alert to SAE.

CR and In-Plant JPM Changes: JPM Changes A. Start Reactor Changed Malfunction code from VIC106A3 to VIC106A4 in JPM Setup Instruction

1. 3. Revised procedure step reference numbers in Elements 1 through 6. Added an Evaluator Cue to Element #3 to ensure that the applicant remains focused on the task of starting the 1 A Recirc pump. Revised Element #13 to include a second option for tripping RO/SRO the 1A Recirc pump. Added an Evaluator Note to Element #13 indicating that it is acceptable for the applicant to use either of the two methods identified for tripping the 1A Recirc Pump. Added an Evaluator Cue to Element #9 to provide information regarding 1A Recirc pump vibration levels if requested by the applicant.

B. HPCI Manual Start Added a Cue to Element 16 for the Evaluator to prompt the receipt of silenced Annunciator 117 HPCI (E2), if the applicant is unaware of the alarm condition (JPM alarms are silenced due to pairing of JPMs). Added a Note to Element 19 to inform the RO/SRO Evaluator that ARC-MCR-117 (E2) direction to ensure the Aux Oil Pump running may not be performed if the applicant does not refer back to the ARC after tripping HPCI in accordance with S55.2.A. C. Perform Turbine Bypass Changed procedure starting point from last 2 BPV Valve Testing lAW ST-6-001-RO/SRO to first 2 BPV 761-1 o. SOC Restoration Changed task conditions to include TS action statement for 1 C RHR pump per licensee's Recommendations.

Added Evaluator Cue for Element 3 to Prompt RO Applicant to enter ON-121, if needed, as this is an SRO decision making step. Added cooldown criteria to initiating cue based on Licensee's comments.

Based on pre-validation comments added 1 B RHR pump aligned to LPCI per S51.1A. Removed some tasks as critical tasks RO/SRO post pre-validation due to task involving verifying open or closed position.

Added element 2 and 4 as critical task. Applicant should be able to demonstrate/understand that loss of SOC has occurred based on malfunction.

Added an additional Evaluator Cue to Element 1 to address any questions posed by the applicant regarding the label designation associated with the controller for valve HV-C-51-103A. ! I E. Synchronize and Load Revised JPM by (1) directing the applicant to load Diesel Generator to 1000 RO/SRO the diesel to 1000 KW instead of 2000 KW, changing trigger initiation time from 45 to seconds after reaching 1000 K\N, (3) adding Evaluator Cue to Element 12 to facilitate the use time compression when raising generator load at rate of 350 K\N/min, (4) denoting Steps 9 and 10 Critical Steps, (5) enhancing the Evaluator Notes Elements 14 and 15, to address the fact that applicant may not take the action to place generator breaker and/or the diesel control switch in the "PULL TO LOCK" when shutting down the F. Scram Channel A1 and A2 Changed malfunction failure method-to Functional Test C71-S3A-PB "A 1 manual pushbutton" AND RO/SRO S3C-PB "A2 manual pushbutton" to "Fail-as-is" when "A2" Arming Collar is placed in "ARMED G. Restore RECW, Dispositioned applicant's Pre-Validation comments.

and Instrument Revised JPM by (1) deleting Element 1, (2) deleting Elements 2 and 3, and incorporating associated information into the "Task Conditions," (3) Renumbering the Elements accordingly, (4) adding an Evaluator Note to Element 5 (previously Element RO 8 in Revision 1) to provide information indicating ONLY that restart of the tripped Drywell Chiller will be accomplished in accordance with S87.1.A App. 1, "Startup of StandbylTripped Drywell Chiller Hardcard," (5) adding new Elements 5.a through 5.f and denoting them as Critical Steps, and (6) correcting editorial errors. H. Standby Gas Treatment Dispositioned applicant's Pre-Validation Manual Startup with Charcoal Revised JPM by (1) specifying the 'A' Filter Train Enclosure Hi Temp be placed in service, (2) adding JPM Instruction

1. 5 to ramp TI-76-010A indication to 250 of over a two minute period from the time Annunciator 002 VENT (G5) alarms, (3) adding an Evaluator Note to Element 5 to indicate that the applicant may log Exhaust Fan Run Time when starting the 'A' Fan, (4) adding a Cue to Element 6 for the Evaluator to prompt the receipt of silenced AnnunGiator 002 VENT (G5), if the applicant is unaware of the alarm condition (JPM alarms are silenced due to pairing of JPMs), and (5) correcting an editorial error. Added Evaluator Note and Cue to Element 12 for expected Annunciator 002 VENT (G1) alarm related to SGTS filter isolation and i SGTS fan trip. I. Maximize CRD Flow Revised to reflect new procedure revision and . Shutdown During RO/SRO add to task conditions, and changed evaluator Conditionscue for element 7 based on validation.

I i I J. Alignment of Equipment for Dispositioned Licensee's 4/6/12 comments.

! Manual Operation of LPCI Originally written as a new Alternate Path JPM. RO/SRO Alternate Path deleted at the request of the applicant to reduce the total number of \ Alternate Path JPMs from 7 to 6. K. Venting Primary Revised JPM to vent primary containment using Containment Using the 24" Suppression Pool Purge Supply line instead of Suppression Pool ILRT line to shorten the JPM. Based on Purge Supply validation walkdown, added initial task conditions include that nitrogen bottles have been obtained for RO/SRO use, and removed the task for applicant to close all steam flooding dampers on panel 1 OC234 on 253' elevation.

Added evaluator cue/feedback for step \4.6.11.

2012 Limerick Initial License Exam Scenario Comments Overall Comments:

Most scenarios are well above the minimum number of required malfunctions, especially 1,2 and 4 Scenarios 2 and 4 have twice the number of required Tech Specs All scenarios have OT-104 entry Potential overlap issues with Audit Scenarios listed below. These are brought to the Lead Examiner's attention to determine if the station needs to address these potential conflicts.

Audit Scenario #1 also contains a drifting rod, similar to NRC Scenario #1 Audit Scenario #2 has inadvertent RCIC start, NRC Scenario #5 has inadvertent HPCI s tart. (Audit scenario is a low power scenario, NRC scenario is 1 00% )

Scenario #1 Comments Total Malfunctions (our count) ATC -7 NRC: Count is 5 plus reactivity, which is not a malfunction.

Drifting rod removed and ATC gets credit for 2,5,6,8 plus 1 for reactivity plus the major BOP -4 NRC: Count is 4. BOP gets credit for 3, 5, 9 plus the major Tech Specs -4 NRC: Count is 3 due to removal of drifting rod. TS calls in 2, 5, 6 General comments: Too many malfunctions for ATC position -7 malfunctions when only 3 are required.

More than twice the minimum. NRC: Agree, removed rod drift to reduce ATC malfunction count and eliminate overlap with Cert Bare minimum for the BOP position. Unlikely that SRO would reference T.S. prior to directing scram on spurious SLC injection. (Event 6) NRC: Agree will ask as follow-up question as necessary depending on performance on other two TS calls Event 5 (Trip of 201-012) is multiple Tech Specs. NRC: Agree, will add reference to this fact Limerick does not withdraw control rods to raise Reactor Power to 100%. This is done with Recirc flow. We suggest starting with Reactor Power at 95% with 2 peripheral control rods inserted that would normally be withdrawn.

The turnover would identify the inserted rods being inserted for HCU maintenance.

The crew would be directed to restore the 2 control rods to position 48 and then restore Reactor Power to 100% with Recirc. The RBM failure (Event #2) would occur during withdraw of the 2 nd control rod. NRC: Agree. changed 0-1 to reflect this change Use MR00161, Control Rod Drift Unconditional vs MR0016A and MR0016B for rod drift. NRC: Agree Use MCR604A for 1A CRO Pump Trip. NRC: Agree 201-012 Trip, 101-012 and 012 DIG Breaker fail to close -Correct action for this event could be either to close the 101-012 OR close the 012 DIG Output Breaker. Note: To close either breaker manually requires placing the appropriate Synch Switch in ON. Additionally, with 012 DIG running and 012 Bus energized, there will be no ESW Pump running for Diesel cooling. Crew must take action to manually start '0' ESW Pump if they don't immediately restore 012 power. NRC: Agree. While the applicants will most likely close the 012, the EDG breaker remains an option. Will script in actions to alternatively restore the bus using the EDG breaker. ROCS can not be reset, following trip of 201-012, until 012 Bus is re-energized NRC: Actions to reset already scripted; actions to restore bus will be scripted into scenario guide After 012 is re-energized, crew must reposition Off Gas valve, CV-69-156 to Condenser Drain and re-open SJAE Air Valves (could be another malfunction for BOP?) NRC: Offgas valve is already scripted on page 24. There is no reference to SJAE air valves in E-012, is this a required response based upon annunciator?

If this is caused by the loss/restoration of 012, it is all part of the same malfunction. OT-104 step to scram plant on SLC injection should be 3.8. not 3.7 NRC: Accept, will change due to new rev There should be a communication from floor personnel that T -221 can't be performed due to panel door being stuck. banana jack receptacle broke. etc. This will allow for the crew to recognize that MSIVs will close on RPV Level 1 and determine that T-251. Injection with HPCI during ATWS. will be required for RPV Level control. If T-221 has been reported as being completed, the crew has every reason to believe that the MSIV's should remain open. Additionally.

this places the SRO in a difficult decision if he or she believes they do not have adequate injection to maintain and restore RPV Level> -186" which will require a Slowdown during an ATWS per T-117. NRC: Accept, will script in communication that panel door cannot be opened.

Scenario #2 Comments Total Malfunctions (our count) Revised ATC count now 3 based on NRC Revised BOP count now 3 based on NRC Tech Specs -Revised TS count now 3 based on NRC General Comments: No substantive action for BOP in event #2 Agree; will remove "C-BOP" reference in "Event Type" column for Event Will also change ATC to BOP for Event 7, and delete ATC from Event 5 (no substantive action for ATC in Event 5). 6 events for ATC -excessive, twice the required Revised ATC count now 3 based on NRC 4 Tech Spec calls -excessive, twice the required amount Revised TS count now 3 as indicated below (Note that following Event numbers reflect the new designations based on deletion Event Evaluated Event 1 (Recirc Flow Unit Failure; Refers to TS 3.3.1 and 3.3.6 -No Active LeOs) Event 3 (Single Loop; TS 3.4.1.1.a.1, 3.4.1.1.a.2, 3.4.1.2.b, 3.2.1,3.2.3,3.2.4:

NOTE that all SLO Tech Spec actions are identified in OT-112) Event 4 (Loss of 125/250 VOC Safeguard Bus 1B0105; TS 3.5.1, 3.B.1, 3.B.2, 3.B.3, TS 3.0.3 relative to TS 3.5.1 and 3.B.2) d. Event 4 is a malfunction within a malfunction (stuck rod) and should be considered 2 malfunctions.

NRC will delete the Stuck Rod malfunction from Event 4, making it a single malfunction Total malfunctions (9) and abnormal events (5) are out of range high Total Malfunction count now '7 based on NRC changes. Abnormal event count now 4 based on NRC changes NOTE: Will combined Events Band 9 into one event, since recovery of RCIC below -129" will not prevent level from reaching TAF and the requirement to perform Emergency Blowdown (i.e., Malfunctions After EOP Entry reduced from 2 to 1). No clear indication for Recirc Flow Unit Failure (event #1) to lead crew to bypass APRM per the ARC. Alarm comes in but it isn't clear from the display which APRM should be bypassed.

Even when the APRM is bypassed, the rod block won't clear so there's no feedback that the action has corrected or mitigated the problem. (Recommend deleting this malfunction)

ARC-MCR-10B, REACTOR, Window E-3, "APRM/RBM FLOW REF OFF NORMAL," directs crew to perform APRM bypass. Will assess and make determination regarding Recirc Flow Unit Failure at pre-validation.

Reactor pressure oscillation on EHC Reg. failure is subtle (1013 pSig -1022 psig). No alarms come in -may take a crew a few minutes to recognize.

Will have to see how it validates.

Additionally, crew wouldn't be expected to swap regulators at this power. With pressure regulator INOP, must reduce power to <25%. (Recommend deleting this malfunction)

NRC will delete the EHC Regulator failure malfunction Can't mimmick Recirc Motor Bearing Temps. If desired to insert a reason to trip ASD, could trip ASD Cooling Pumps with a failure of ASD to auto No indication of Recirc Pump Motor Bearing temperature in the MCR CRT display, recorder, etc)? Why unable to mimic the temperature? alarm exists for this condition.

Does procedural guidance exist for a Recirc Pump on a trip of the associated ASD Cooling Pumps guidance that could be incorporated into the scenario (08/02/12)

Revised the malfunction to incorporate LGS recommendations. LOCAILOOP very challenging with only 1 4 KV Bus available.

E-10/20, Loss of Offsite Power is not included in assessment.

Crew should attempt to cross-tie buses per Att. 1 of E-1 0/20 to energize an RHR Pump and ESW Pump. This is a 45 min -1 hour process. Very busy for a 3 person crew. LOOP/LOCA not overly challenging in that Crew primary focus should be on Adequate Core Coverage only. Cross-ties are a follow-up action that will not be evaluated during the scenario.

Event scripted so that RPV level can be restored with "C" RHR following Emergency Blowdown, provided the "C" EDG is manually started (Critical Task). Primary Containment not a focus of this event.

Scenario #3 Comments Total Malfunctions (our count) A TC -3 (2 malfunctions, and 1 Tech Specs -General comments: Insufficient events for ATC position (2). SRO-I candidates must have 2 malfunctions and 1 major in the A TC position.

If credit is given for event #7 to perform scram actions, that would solve. NRC: Credit will be given to ATC for scram actions in Event #7. Event #10 on ES-D1 Form is not a separate event but part of Event #8. NRC: Agree, Event # 8 and 10 will be combined on ES-D1. 5 events prior to major is excessive.

Event #5, swapping RECW Pumps is really a normal and Event # 1 is a normal. (Recommend deleting Event #5). NRC: Need to determine if any alarms can be overridden to come in related to RECW pump for operators to investigate ( send field operators), after that, if based on field report, operators take actions to swap pumps. (This would satisfy component failure criteria and would not be normal event) Placing FW Heaters in service is a long evolution (2-3 hours). Recommendation:

Start with Reactor Power at 18% with Turbine Generator ready to synch and make synching the generator the normal event NRC: Agree, will change initial conditions, and Event #1 (Normal) to synch the main generator at 18% power. On RF delta P isolation and 'A' SGTS Fan failing, '8' SGTS Fan will auto start, therefore no crew action is required.

Recommendation:

Fail the isolation to occur on a valid delta P signal and crew would have to manually insert isolation. (This would also require resetting a PCIG isolation if isolation is completed from MCR.) NRC: Need to add malfunction to prevent 'B' SGTS Fan from auto starting, this will require crew to take manual actions to start the 'A' SGTS fan lAW the scenario script. Trip of D114 prior to major is OK, but with Load Center de-energized Drywell and Suppression Pool pressure instruments are downpowered and crew won't be able to determine when/if parameters exceed limits requiring Slowdown. (Recommendation:

pick a different bus or give D114 LC back. e.g. invadvertant Div 1 LOCA. This will trip 0114 but it will auto re-close back in.) NRC: Will assess and determine appropriate recommended actions during validation visit. (08/02112)

NRC: Revised Event 4 to include restoration of 0114 Load Center (Discussed resolution with Lee Stanford on 8/01112). Can't change Recirc Speed at this power -Recirc Pumps are at Min Speed due to Feedwater flow and can't raise or lower. NRC: Lee indicated that this malfunction or (manual override) can be done, where Recirc flow pushbutton speed can be cycled increases (10 rpm) and decreases (30rpm) manually.

Need to confirm with Lee that this can be done or not.

Can't break tailpipe on 'C' SRV, recommend selecting

'N' instead. (Malfunction MAD149E to fail open mechanical, MAD151 F for Downcomer break) NRC: Will change tailpipe break to 'N' SRVand use MAD151F. Scenario #4 Comments Total Malfunctions (our count) Revised ATC count now 4 based on NRC Revised BOP count now 3 based on NRC Tech Specs -Revised TS count now 3 based on NRC General Comments: Too many events -only 3 required per position (ATC/BOP)

Total Malfunction Count now 8 based on NRC changes Abnormal Event count now 6 based on NRC changes Revised ATC count now 3 based on NRC changes Revised BOP count now 3 based on NRC changes (Note that in addition to deleting Event 7, NRC will also delete Event 1 to unload and secure 014) Too many Tech Spec events -6 total. Event #8 has 3 Tech Spec LCO's. This will make for a lengthy scenario if SRO is required to reference Tech Specs for all of these malfunctions.

Recommendation:

delete at least 1 event per position.

This still leaves 4 events/each and 4 Tech Spec events. Revised TS count now 3 as indicated below (Note that following Event numbers reflect the new designations based on deletion of "Normal" Event 1): Evaluated TS: Event 1 (Rx Level Transmitter L T 1 N080C; TS 3.3.1) Event 2 (1A Recirc Pump Motor High Vibration; TS 3.4.1.3) Event 6 (Loss of Safeguard Bus 0134; TS 3.6.5, 3.7.2, 3.8.3) Non-evaluated TS (included in scenario write-up for reference only): Event 3 (RWCU Leak with Auto Isolation Failure; TS 3.3.2, TRM 4.4.4) Event 5 (1A Recirc Pump ASO Controller Failure; TS 3.4.1.3) Events 3, 6 and 7 all require power reductions.

Events 3 and 7 are both marked as 'R', 6 is listed as 'C'. Event 3 to retain 'R' designation Event 6 to retain 'C' designation Event 7 to be deleted Attributes table incorrect:

i. There are 2 or 3 Malfunctions after EOP entry (T-103 entry on Hi Rad, MSIV Failure, SGTS Agree that the '1' specified in the Attributes Table incorrect.

Will change the number from 1 to 2 (i.e., Failure and SGTS (08/02/12)

The SGTS Failure is the only Malfunction after EOP entry. The Hi Rad and MSIV Failures primarily serve as "setup" events for the Major Malfunction.

Operator action to close the MSIVs does not result in a successful isolation of the 'A' MSL. Primary to Secondary Containment Leak simulation (including subsequent Leak Propogation) is dependent upon the failure to isolate (i.e., a "setup" event). The number specified in the Attributes Table is correct and will remain at 1. (Communicated this change to Lee Stanford during the week of July 2, 2012). EOP's entered should be T-101 and T-103 (No EO procedures)

Do not understand comment regarding

"(No EO procedures)." T-101 and T-103 are scripted, as well as 102 on rising MSL and SJAE Discharge radiation levels. Need clarification. Event #5, if voltage regulator fails to Manual, there won't be any action needed to reduce Main Generator Voltage (voltage will be reduced when manual regulator in control since it's at the original setpoint).

Recommendation:

Begin with turnover to maintain MAX VARs due to grid instability and then fail regulator with VARs lowering which will require manual adjusting VARs back up to limit. Note: With auto voltage regulator failing, TSO and Power Team require notification within 15 minutes that voltage regulator is in Manual. Would it be possible to use Malfunction MEG542 (Main Generator Automatic Voltage Regulator Fails High), with an override to prevent the Auto Voltage Regulator from transferring to Manual (intent is for the BOP to manually perform the transfer; ARCs MCR-125 C4 & 01 provide guidance associated with this action), ensuring that the High Volts/Hertz condition will be limited to a value that will not challenge the Generator lockout protective feature. Note that the TSO and Power Team 15 minute notifications have already been scripted into the scenario.

(08/02/12)

Revised the malfunction (now Event #4) to incorporate LGS recommendations. Event #6 -can't mimic ASD Controller failure. (Recommend deleting this malfunction)

NRC understands that a malfunction does not presently exist for the ASD Controller failure. However, initial discussions indicated that the ASD Controller failure could be manually simulated from the booth. This is an important Event in that it leads to the Fuel Failure in Event 9. Unclear as to why the failure cannot be manually simulated.

(08/02/12)

Discussed resolution with Lee Stanford during the week of July 30,2012. Lee indicated that it would be possible to simulate the ASD Controller Failure by incrementally raising Recirc pump speed using the override feature (i.e., multiple overrides of the 10 RPM Raise Pushbutton).

The NRC determined that raising Recirc pump speed incrementally would be an acceptable means of simulating the failure. Pre-Validation to confirm. Event #7 -failing SSE Outlet Valve will lead to a rapid Condenser Vacuum drop. Since actions are required in the field to open back-up valve, it's unlikely crew will be able to prevent Turbine Trip on Low Condenser Vacuum. Recommendation:

Delete this NRC will delete Steam Seal Evaporator Steam Outlet Valve

5. Event #8 LGS Simulator does not model Seismic Panel. OK to trip 0134 but suggest deleting seismic event. NRC understands that the LGS Simulator does not model the Seismic Panel. However, initial discussions indicated that initiation of a Seismic Event could be accomplished by simply providing a verbal cue to the crew (i.e., tremors felt in the MCR, etc.). Unclear as to why the Seismic Event would need to be deleted. This Event makes the scenario credible with respect to the subsequent loss of Safeguard Bus 0134 and the MSL Break in the Outboard MSIV Room.

Scenario #5 Comments Total Malfunctions (our count) Tech Specs -NRC: Generic comments: We count 8 malfunctions, not 7 NRC: Agree, will change 3 malfunctions post-EOP, not 2 NRC: Currently the count is 2. The A RFP steam supply failure and RHR system rupture are the only 2 post-EOP entry events. This may reduce to 1 depending on results of pre-validation of RHR system rupture mentioned below Event #3, there is no RPV Level change on 'B' RFP Controller failure, FWLC works too good. However, with 'B' RFP in Manual, it makes level control very difficult during any further transients and power maneuvers.

NRC: If the 8 RFP controller is driven up fast enough (instantaneous failure or something approximating it) it should have an effect on RPV water level. Water level will recover via FWLC but that does not relieve the operators from taking the controller to manual and restoring balanced flow. During the manual runback, competent operators should be more than able to coordinate the runback with RPV level control considering two RFP are still in auto. (08/02/12)

'8' RFP Controller Failure malfunction deleted. T-101 would be entered following the scram as Feedwater level control will align for post-scram level control and RPV Level will drop below 12.5". NRC: Accept, will script in actions for SRO exiting T-100 and entering 101/T-102 on high drywell pressure Not sure why the RHR HTXR Leak is required post-EOP.

It's possible that RHR may not be needed to raise Reactor Pressure to 235 psig. Recommendation:

There are enough malfunctions/events that this could be deleted. NRC: We will pre-validate this and possibly flag it for deletion depending on pre-validation results