ML100070550

Initial Exam 2009-301 Post Exam Comments

ML100070550
Person / Time
Site:	Catawba
Issue date:	01/07/2010
From:	NRC/RGN-II
To:	Duke Energy Carolinas
References
50-413/09-301, 50-414/09-301
Download: ML100070550 (13)

Text

FAC I LITY NAME: ___

___ -----REPORTNUMBER:

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POST EXAM COMMENTS CONTENTS:

o Post Exam Comments o "As-submitted" post-exam comments from licensee Location of Electronic Files: Not applicable.

FACILITY NAME: ___

____ _ REPORTNUMBER:

_____

____ __ POST EXAM COMMENTS CONTENTS:

o Post Exam Comments o "As-submitted" post-exam comments from licensee Location of Electronic Flies: Not applicable.

" Duke r*, Energy December 29, 2009 Mr. Frank J. Ehrhardt, Senior Operations Examiner U.S. Nuclear Regulatory Commission, Region" Sam Nunn Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, GA 30303

SUBJECT:

Duke Energy Carolinas, LLC Catawba Nuclear Station, Units 1 and 2 Docket Numbers 413 and 50-414 Post Examination Documentation JAMES R. MORRIS Vice President Duke Energy Corporation Catawba Nuclear Station 4800 Concord Road York, SC 29745 803-701-4251 803-701-3221 fax The post examination materials for the Catawba Nuclear Station initial license examination completed on December 22, 2009 submitted in accordance with NUREG , 1 021 ES 501 C.1.a, as listed below, are enclosed.

a. The original examination answer sheets b. A clean copy of the original examination answer sheets c. The master examination

e. The answer keys for the RO and SRO examinations

f. The questions asked by and answers provided to applicants during the written examination

g. The written examination seating chart h. The written exam performance analysis i. Post examination comments and supporting documentation for the operating and written examination portions Form ES-201-3 Examination Security Agreement will be submitted at a later date. www.duke-energy.com a Duke r#Ener 9Y* December 29 , 2009 \2 /09 Mr. Frank J. Ehrhardt , Senior Operations Examiner U.S. Nuclear Regulatory Commission, Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, S.w., Suite 23T85 Atlanta , GA 30303

SUBJECT:

Duke Energy Carolinas , LLC Catawba Nuclear Station , Units 1 and 2 Docket Numbers 413 and 50-414 Post Examination Documentation JAMES R. MORRIS Vice President Duke Energy Corporation Catawba Nuclear Station 4800 Concord Road York, SC 29745 803*701-4251 803-701-3221 fax The post examination materials for the Catawba Nuclear Station inrtiallicense examination completed on December 22, 2009 submitted in accordance with NUREG 1021 ES 501 C.1.a , as listed below , are enclosed. a. The original examination answer sheets b. A clean copy of the original e x amination answer sheets c. The master examination

e. The answer keys for the RO and SRO examinations

f. The questions asked by and an s wers provided to applicants during the written examination

g. The written examination seating chart h. The written exam performance analysis i. Post examination comments and supporting documentation for the operating and written examination portions Form ES-201-3 Examination Security Agreement will be submitted at a later date. \\oWW, duke-enerBy.com U. S. Nuclear Regulatory Commission Regional Administrator, Region II Post Examination Documentation December 29,2009 Page 2 If you have any questions or need additional information, please contact Steve Tripi, Initial Training Supervisor at (803) 701-3770 or Alan Orton, Operations Training Manager at (803) 701-3977.

Sincerely, V F T I6r ;::r(JJY1eJ James R. Morris xc: without attachments Malcolm T. Widmann, Chief U. S. Nuclear Regulatory Commission, Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, S. W., Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 G. A. Hutto, III Senior NRC Resident -Catawba CN01NC U. S. Nuclear Regulatory Commission Regional Administrator, Region II Post Examination Documentation December 29. 2009 Page 2 If you have any questions or need information, please contact Steve Tripi, Initial Training Supervisor at (803) 701-3770 or Alan Orton , Operations Training Manager at (803) 701-3977. Sincerely, V FT .,i\r ..:f'()J'Itj "l1oo-!s J a mes R. Morris xc: without attachments Malcolm T. Widmann, Chief U. S. Nuclear Regulatory Commission, Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street , S. W., Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission Document Control Desk Washington , D.C. 20555-0001 G. A. Hutto , III Senior NRC Resident -Catawba CN01NC Regional Administrator, Region II Post Examination Documentation December 29, 2009 Page 3 bxc: without attachments R.D.Hart ELL CN01RC EC050 bxc: cover letter with correspondence review documentation only Date File CN-940.00 CN01RC CN04DM Regional Administrator , Region II Post Examination Documentation December 29 , 2009 Page 3 bxc: without attachments R.D.Hart ELL CN01RC EC050 bxc: cover lett er wijh correspondence review documentation only Date File CN-940.00 CN01RC CN04DM Time Q# Student Posing Question Answer provided Provided to: Question 1117 7 Chad Kidd Can I get a confirmation there is a correct Yes, there is a correct answer. Individual answer for #7? Given SPP-1 is in AL T ACTION, All 'c' htrs are ON causeing pressure [increase]

Answers: A. All htrs ON -No, B/U Htrs Blocked on Alt action B. PORV -No, PORVs blocked on Alt Action C. S[pray blocked (auto), no, 'c' htrs + spray are only thing controlled in auto using Press Master in manual. D. Spray + PORV -No, spray not blocked 1214 7 Jason Moore Am I to assume the Alt Action is from the Enough information is available to Individual PZR Pressure control? answer the question.

0748 7 Jason Moore Is that supposed to be a S/G PORV Question is correct as written. Individual opened momentarily in stem ofquestion?

0817 7 Thomas Strouse Is the Alternate action on SPP-1 or SPP-There is enough information available to Individual

2. answer the question.

0826 12 Keith Anderko Do all 5 operations have to be because of No additional information provided.

Individual 1 ERPA de-energizing or can they be a separate required manual action?

• 13 Keith Anderko Does question two ask Part 2 Question should read as follows: ALL Allow 1 ECS to supply 1 EDC with 1 ECS students still aligned from 1 EMXJ? OR Allow 1 ECS "Does OP/1/A163501008 in room to be powered from 1 EMXJ? (125VDC/120VAC Vital Instrument and Control Power System) allow alignment of the alternate supply to 1 ECS to supply power to 1 EDC based on current Unit 1 conditions?

---

Time Q# Student Posing Questi o n Answer provided Provid e d to: Question 1117 7 Chad K i dd C a n I get a confirmation there is a correct Y e s , there is a correct answer. Individual answer for #7? Given SPP-1 is in AL T ACTION , All 'C' htrs are ON causeing pre s sur e [i ncreas e) Answers: A. All htr s ON -No , B I U Htrs Blo c ked on Alt a c tion B. PORV -No , PORVs blocked on Ait Acti o n C. S(pray blocked (auto), no, 'C' htrs + spra y are only th i ng controlled in auto u s ing Press Master in manual. D. Spray + POR V -No, spray not blocked 1214 7 Jason Moore Am I to assume the Alt Action i s from th e Enough information is a v ailable to Individual PZR Pre s sure control? ans w er th e Question. 0748 7 Ja s on Mo o re I s that suppo s ed to be a S I G PORV Question is c orrect as written. Indi v idual opened momentarily in stem of question?

0817 7 Thoma s Strou s e Is th e Alternate action on SPP-1 or SPP-There is enough information available to Indi v idual 2. answer th e Questi o n. 0826 12 Keith Anderko Do aU 5 operations ha v e to be because of No additional information provided. Indi v idual 1 ERPA or can th ey be a separate required manual action?

• 13 Keith And e rko Does question two as k Part 2 Que s tion sh o uld read as follo ws: ALL Allow 1 ECS to supply 1 EDC w ith 1 ECS student s still aligned from 1 EM X J? OR Allow 1ECS "Does OPI11N6350 1 008 in room to be po w ered from 1 EM X J? (125VDC 1 120 V AC V ital In s trument and Control Po w er System) allow alignment of the alternate supply t o 1 ECS to s uppl y power to 1 EDC based on current Unit 1 condition s?

0954 38 Thomas Strouse T he answers are confusing when In each answer the word "other" is ALL i analyzing the question.

• (of the equivalent to "remaining".

students still remaining channels that input P-11) in room Ch 1, 2, 3 input P-11 Ch 2 failed that leaves Ch 1 & 3 that input P-11 How many of these 2 must be <P-11 to block ECCS PZR Press 2 must be <P-11 to meet the 2/3 logic required 2 of the 2 remaining must be below P-11 answers the question 2 of the other 2? OTHER? 0828 40 Bobby Smith Part 2 -is this asking for TS limits based Question provides correct information.

Individual on current mode, or based on all modes No additional Information is required.

i of applicability?

0855 40 Ray Transou Current status states 1 B LCVU just There is enough information to answer Individual tripped then OAC indications are as the question.

above stated. It shows 1 B LCVU still running. Is OAC status reflecting actual plant status or has it not updated due to LCVU tripping?

1313 42 Thomas Strouse Is 1NI-184 and/or 1NI-185 open? The 1st No further information is necessary.

Individual bullet says auto and manu swap to CLR failed if 184 and 185 are both closed then NS cannot be in service but @ >10 psig procedurally we try to place NS (1 train) in service. @4.9% FWST <<5%) all pump taking suct from FWST must be secured if NS was still on FWST it would be off. 1159 51 Kieth Anderko 2. Does the conditions above, require Answer based on available information.

Individual knowing if the fuel racks will continue to stick? --------0954 38 Thom as S trous e The answers are confusing when In each a n swer th e wo rd " other" is A LL the question .... (of the e qui valen t to "remaini n g", students s till remaining cha nnel s that input P-11 ) in room Ch 1, 2, 3 inputP-11 Ch 2 f a il ed that leaves Ch 1 & 3 that inpu t P-11 Ho w many of these 2 mu st be <P-11 t o block ECC S PZR Pr ess 2 must be <P-11 to mee t th e 213 l ogic required 2 of th e 2 remaining must be below P-11 answers the question 2 o f th e other 2? OTHER? 0828 40 Bo bby Smith Part 2 -is th is asking for TS limits based Questio n provides correct information. In div i dua l o n c urr ent mode, o r based on a ll m odes N o addit i o nal Inform a tion is requ ired. of applicability?

0855 40 Ra y Transou C urren t stat us states 1 B L eVU just There is e n oug h information t o answe r Indi vidua l tripped then OAe indication s are as the question.

above stated. It shows 1 B LCVU still running. Is OAe status reflecting actual plant sta tu s or has it n ot updated due to LCVU tri pping? 1 313 42 Thom as S tr o u se Is 1NI-184 and/or 1NI-185 open? Th e 1st No further inf ormatio n is n ecessary. Individual bullet says a uto and manu swap to CL R f ai l ed i f 1 84 and 185 a r e both closed then NS ca nnot be in serv i ce but @ > 1 0 psig procedurally we try to place NS (1 t r a in) in service. @4.9% FWS T <<5%) a ll pump taking suet from FWST mu s t be secured if N S was s till on FWST it wo ul d be off. 1159 51 K i e th Anderko 2. D oes th e co nditions above, r equi r e Answer based on ava il able i nf ormation.

I n divi du al k n owi n g if the fuel racks w ill cont inu e to stick?

--1133 58 David Shaver Should answer A be SPL-2 instead of No further information is necessary.

Individual SPL-1? OR Should answer C be SPL-1 instead of SPL-2? 0748 77 Ben Thombs Is inservice testing the same as a There is enough information to answer Individual "retest"?

the question.

0820 83 David Shaver Is question 2 asking if the procedure Question is correct as written. No Individual requires stopping core alts, or the additional information is required.

conditions require halting core alts? 1048 87 Will Fowler Question #2 asks what procedure will be There is sufficient information to answer Individual implemented NEXT. When is next? the question.

After the Rx trip/trip of NCPs or after NC leak/SI? 1344 89 Ben Thombs Stem of question states: Part 1 should read as follows: ALL "12/15/091800 IAE completed the 1A students still D/G battery surveillance

... " " Based on the conditions at 1500: in room What is the latest time that this First part of question asks: surveillance could have been completed "1. What is the latest time that this before the LCO for Technical surveillance can be completed before the Specification

3.8.4 would

not have been LCO not met... met?" Clarification request: When discovered inoperable at 12/15/09 1800, the LaC is not met. Are you asking ithe question based on the first time in the question and not considering the discovered inoperable battery?

• Time this was given was not documented, however, based on returned sheets, it was after Bobby Smith completed his exam. All other student were still taking their exam. 1133 58 David Shaver Should answer A be SPL*2 instead of No further information is necessary. Individual SPL-1? OR Should ans w er C be SPL-1 instead of SPL-2? 0748 77 Ben Thombs Is inservice testing the same as a There is enou g h information to answer Individual

" retest"? the Question. 0820 83 Da v id Shaver Is question 2 asking if the procedure Question is correct as written. No Individual requires stopping core alts , or the additional information

s required. conditions require haltino core a l ts? 1048 87 Will Fowler Que s tion #2 asks what p rocedure will be There i s sufficient info r mation to an s wer Individual implemented NEXT. When is ne x t? the question. After the Rx trip/trip of NCPs or after NC lea kl SI? 1344 89 Ben Thombs Stem of quest i on states

Part 1 should read as follo w s: ALL "121151091800 IAE completed the 1A s tudents s till D I G battery sUiveillance

... " .. Based on the conditions at 1500: in room What is the latest time that this First part of question asks: surveillan c e c ould have been completed

" 1. What is the lalest time that this before the LCO for Technical s urveillance can be completed before the Specification 3.8.4 w ould not ha v e b e e n LCO not met... met?" Clarification r equest: When disco v ered inoperable at 12115/09 1800, the LOC is not met. Are you asking ithe question based on th e first time in the question and not c onsidering the discovered inoperab l e battery? + Time this was given was not documented, ho w ever , based on returned sheets, it was after Bobby Smith completed his e x am. All other s tudent were still takina their exam.

TRANSOU USRO EXAM SMITH PROCTOR #2___ RO BLANKENSHIP I [ MOORE [ [ STROUSE UNDERWOOD RO USRO RO USRO THOMBS ISRO U] L-' ____ ----' ISRO RO FOWLER USRO KIDD ANDERKO __ ---' '-----___ ----' L-' ____ ---' FRONT EXAM PROCTOR #1 TRANSOU USRO [ EXAM PROCTOR #2 BLANKENSHIP

[ MOORE RO USRO FANTA I SHAVER [ USRO ISRO SMITH RO I STROUSE RO TURNER I RO UNDERWOOD USRO THOMBS ISRO ,-__ __ ,, __ FRONT EXAM PROCTOR #1 Catawba Nuclear Station 2009 Senior Operator Exam and 2008 Senior Operator Retake Exam (12/22/09)

Post Examination Comments The following comment is submitted for review regarding question number 84 of the written examination administered at Catawba Nuclear Station on December 22, 2009. Question # 84: Unit 1 was at 3% power performing a startup. Given the following:

Initial conditions

• Intermediate Range channel N-35 failed low

• The crew removed N-35 from service per the applicable abnormal procedure Current conditions

• IAE returned the channel to service and reported that the SUR circuitry for N-35 had to be disabled as part of the channel repair

• Engineering has evaluated the repair and determined that all other functions will operate as designed with the SUR circuitry disabled.

1. When the crew removed N-35 from service per the abnormal procedure, which fuses (if any) were removed? 2. For the conditions above, is N-35 operable?

A. 1. The control power fuses 2. No S. 1. The control power fuses 2. Yes C. 1. No fuses were removed 2. No D. 1. No fuses were removed 2. Yes Original Answer Key: 0

References:

1) AP/16 (Malfunction of Nuclear Instrumentation), 2) T. S. 3.3.1 and bases 3) ENS (Excore Nuclear Instrumentation) lesson plan Page 11 Catawba Nuclear Station 2009 Senior Operator E xam and 2008 Se nior Operator Retake E xam (12122109)

Post E xamination Comments The following comment is submitted for review regarding question number 84 of the written examination administered at Catawba Nuclear Station on December 22, 2009. Question # 84: U nit 1 was at 3% power performing a sta rtup. Given the following: I nitial conditions

• Intermediate Range channel N-35 fai l ed low

• The crew removed N-35 from service per the applicable abnormal procedure Current con dit io n s

• IAE returned the channel to service and report ed that the SUR circuitry fo r N-35 had to be disabled as part of the channel repair

• Eng i neering ha s evaluated the rep ai r and determined that all other functions will operate as deSigned w ith the SUR circuitry disabled. 1. When the crew removed N-35 from service per the abnormal procedure, which fuses (if any) were removed? 2. F o r the condi tions above, is N-35 operable?

A. 1. The co n trol po wer fuses 2. No B. 1. The contro l power fuses 2. Yes C. 1. No fuses were removed 2. No D. 1. No fuses were removed 2. Yes Original Answer Key: 0 References

1) AP/16 (Malfunction of Nuclear Instrumentation), 2) T. S. 3.3.1 and bases 3) ENS (Excore Nuclear Instrumentation) lesson ptan Page 11 Comment: Question 84 did not provide all the necessary information to enable the Senior Reactor Operator applicant to make a proper determination of operability in accordance with approved guidelines contained in Nuclear Station Directive (NSD) 203, "Operability/Functionality." Per the "initial conditions" contained in Question 84, when the Intermediate Range channel was removed from service per the abnormal operating procedure, the channel was declared inoperable.

Subsequent information provided in the "current conditions" statement (second bullet) is not consistent with the station's expectations to use the Operability Determination Process contained in NSD 203 to determine operability.

Specifically, the fact that an Operability Determination was/was not conducted is not included in the stem of the question.

Without this information, the applicant could conservatively assume that the Operability Determination was not conducted, and the Structure, System or Component would remain inoperable.

Recommendation:

Based upon the above information, the Senior Reactor Operator applicant cannot make a definitive determination of operability within the expectations contained in the NSD. Therefore, Catawba Nuclear Station recommends that Question 84 be deleted from the SRO-only portion of the written examination.

References:

The applicable portions of NSD 203, "Operability/Functionality" are included.

Page I 2 Comment: Question 84 did not provide all the necessary i nformation to enable the Senior Reactor Operator applicant to make a proper determination of operability in accordance with approved guidelines contained in Nuclear Station Directive (NSD) 203, Per the U initial contained in Question 84 , when the Intermediate Range channel was removed from service per the abnormal operating procedure , the channel was declared inoperable.

Subsequent information provided in the " current statement (second bullet) is not consistent with the station's expectations to use the Operability Determination Process contained in NSD 203 to determine operability. Specifically, the fact that an Operability Determination was/was not conducted is not included in the stem of the question. Without this information, the applicant could conservatively assume that the Operability Determination was not conducted , and the Structure, System or Component would remain inoperable.

Recommendation:

Based upon the above information, the Senior Reactor Operator applicant cannot make a definitive determination of operability within the expectations contained in the NSD. Therefore. Catawba Nuclear Station recommends that Question 84 be deleted from the SRO-only portion of the written examination.

References:

The applicable portions of NSD 203, " Operabilily

/Functionalily" are included. Page I 2 203. OPERABILITY I FUNCTIONALITY 203.1 PURPOSE The purpose of this directive is to provide the departmental policy for performing operability determinations and functionality assessments consistent with Regulatory Issue Summary (RIS) 2005-20 and its associated Nuclear Regulatory Commission (NRC) Inspection Manual Part 9900 Technical Guidance.

In addition, this directive complements the guidance in NSO 208, "Problem Investigation Process (PIP)" for the resolution of degraded and/or nonconforming conditions.

203.2 SCOPE AND APPLICABILITY This procedure applies to degraded/nonconforming conditions and unanalyzed conditions associated with structures, systems, and components (SSCs) that perform specified functions as set forth in the Current Licensing Basis (CLB) for the facility.

A conceptual illustration showing the scope and applicability of this directive is provided as Appendix A.1, "Scope and Applicability. " 203.2.1 OPERABILITY DETERMINATIONS The Operability Determination Process (OOP) is used to assess the operability of SSCs explicitly required to be operable in a Technical Specification (TS) Limiting Condition for Operation (LCO). The scope of SSCs considered within the OOP is as follows: a. SSCs explicitly required to be operable in a TS LCO.1 These SSCs (also referred to as "SSCs described in TSs") may perform required support functions for other SSCs required to be operable by TSs (e.g., emergency diesel generator and service water). b. SSCs that are not explicitly required to be operable in a TS LCO, but that perform necessary and required support functions (as specified by the TS definition of operability) for SSCs that are required to be operable by TSs (Le., Support SSCS).2 203.2.2 FUNCTIONALITY ASSESSMENTS Functionality is an attribute of SSCs that are not required to be operable by TSs. Such SSCs warrant programmatic controls to ensure that SSC availability and reliability are maintained.

SSCs within the scope of functionality are divided into three subsets: a. Support SSCs. SSCs within this subset are considered within the scope of the OOP (Refer to 203.2.1.b)

b. SSCs that are described in the Selected Licensee Commitments (SLC) Manual but do not fall within the scope of the OOP. SSCs within this subset are subject to Formal Functionality Assessments in accordance with Section 203.8. 1 This includes the TSs based on NUREG-1430 (Babcock and Wilcox) and NUREG-1431 (Westinghouse) and the TSs associated with the Independent Spent Fuel Storage Installation (ISFSI). 2 If the ODP is entered due to a condition affecting a Support sse not described in TSs, then the operability determination should be performed on the Supported sse described in TSs. Page I 3 203. OPERABILITY I FUNCTIONALITY 203.1 PURPOSE The purpose of this directive is to pro v ide the departmental policy for performing operability determinations and functionality assessments consistent with Regulatory Issue Summary (RIS) 2005-20 and its associated Nuclear Regulatory Commission (NRC) Inspection Manual Part 9900 Technical Guidance. In addition , this directive complements the guidance in NSD 208 , "Problem In v estigation Process (PIP)" for the resolution of degraded and/or nonconforming conditions. 203.2 SCOPE AND APPLICABILITY This procedure applies to degraded/nonconforming conditions and unanalyzed conditions associated with structures , systems , and components (SSCs) that perform specified functions as set forth in the Current Licensing Basis (CLB) for the faCility. A conceptual illustration showing the scope and applicability of this directive is provided as Appendi x A.1 ,

and Applicability

203.2.1 OPERABILITY DETERMINATIONS The Operability Determination Process (ODP) is used to assess the operability of SSCs explicitly required to be operable in a Technical Specification (TS) Limiting Cond i tion for Operation (LCO). The scope of SSCs considered within the ODP is as follows: a. SSCs explicitly required to be operable in a TS LCO.1 These SSCs (also referred to as described in may perform requ ir ed support functions for other SSCs required to be operable by TSs (e.g., emergency diesel generator and service water). b. SSCs that are not explicitly required to be operable in a TS LCO , but that perform necessary and required support functions (as specified by the TS definition of operability) for SSCs that are required to be operable by TSs (i.e .* Support SSCs)' 203.2.2 FUNCTIONALITY ASSESSMENTS Functionality is an attribute of SSCs that are n ot required to be operab l e by TSs. Such SSCs warrant programmatic controls to ensure that SSC availability and reliability are maintained.

SSCs within the scope of functionality are divided into three subsets: a. Support SSCs. SSCs within this subset are considered within the scope of the OOP (Refer 10 203.2.1.b)

b. SSCs Ihal are described in the Selected Licensee Commitments (SLC) Manual but do not fall within the scope of the OOP. SSCs within this subset are subject to Formal Functionality Assessments in accordance with Section 203.8. I Thi s in c lu des th e T Ss ba se d o n NUREG-1430 (B a bc oc k and Wil c ox) and NUREG-1 4 3 1 (W es tingh ouse) and th e TS s associ at e d with th e Ind epe nd ent S p e nt Fu e l S t o rage In st all a ti o n (I S F S I). 2 If th e ODP is e n te red du e to a c o nd it ion aff ec ting a S uppon sse n ot d esc ri be d in T Ss, th e n the o perabili ty d e t e rmin a t io n s hould b e performed on the S up po rted s s e d esc ribed in T Ss. Page I 3 203.3 DEFINITIONS

c. Functional/Functionality

-Functionality is an attribute of SSCs not required to be operable by TSs. In general, an SSC is functional or has functionality when it is capable of performing its specified function(s) as set forth in the CLB for the facility.

Functionality does not apply to specified safety functions, but does apply to the ability of non-TS SSCs to perform other specified functions.

SSCs described in the SLC Manual (but not described in TSs) are functional or have functionality when they are capable of performing those functions considered necessary to meet their associated COMMITMENT(s).

d. Loss of Functional Capability -A physical deterioration of an SSC, such that previous assumptions are no longer valid regarding the SSCs function(s) in support of operability or functionality.

Examples of conditions that can reduce the capability of a system are failures, malfunctions, deficiencies, deviations, defective material, aging, erosion, corrosion, improper operation, and maintenance.

When the capability of an SSC described in TS is degraded to a point where it cannot perform with reasonable assurance or reliability, the SSC should be declared inoperable even if, at the time of the declaration, the SSC could perform its specified safety function.

Page 14 203.3 DEFINITIONS

c. Functional/Functionality

-Functionality is an attribute of SSCs not required to be operable by TSs. In general, an sse is functional or has functionality when it is capable of performing its specified function(s) as set forth in the CLB for the facility. Functionality does not apply to specified safety functions, but does apply to the ability of non-TS SSCs to perform other specified functions.

SSCs described in the SLC Manual (but not described in TSs) are functional or have functionality when they are capable of performing those functions considered necessary to meet their associated COMMITMENT(s).

d. Loss of Functional Capability

-A physical deterioration of an sse, such that previous assumptions are no longer valid regarding the SSCs function(s) in support of operability or functionality.

Examples of conditions that can reduce the capability of a system are failures, malfunctions, deficiencies , deviations, defective material, aging, erosion, corrosion, improper operation, and maintenance. When the capability of an sse described in TS is degraded to a point where it cannot perform with reasonable assurance or reliability, the SSC should be declared inoperable even if , at the time of the declaration, the sse could perform its specified safety function.

Page 14 Explanation of Critical task: Closure of 1 NV*252A and 1 NV*253B during transfer to Cold Leg Recirc during Scenario 3. Event 7 This task is NOT critical per the Westinghouse Owners Group (WOG) Emergency Response Guideline (ERG) Critical Task Documentation if the actions already taken will prevent cavitation of the NV pumps. Per the critical task documentation, from the ERG based critical tasks notebook, the critical task associated with EP/1/A/5000/ES-1.3, Transfer to Cold Leg Recirculation, is: Transfer to cold leg recirculation and establish ECCS recirculation flow. Closure of these valves isolates the FWST from the NV pump suction preventing further depletion of the FWST. The NV pumps, at this point, have already had their suction aligned to the NO pump discharge, which will produce a higher suction head than the FWST. The flow from the NO pumps is prevented from flowing into the FWST by a check valve in the line, with 1 NV252A and 1 NV253B being closed as a backup to the check valve, which is tested per PT/1/Al4200/013H NI/NV Check Valve Test according to the Catawba OM-1 0 Testing Program. EP/1IA15000/ES-1.3 continues on regardless of the position of 1 NV252A and 1 NV253B, and the final check that is made for successful transfer to Cold Leg Recirc is flow from each of the ECCS pumps, which will be present with 1 NV252A and 1 NV253B open or closed. The Critical Task Review Group (CTRG) anticipated that the performance standard, for the critical task of swapping to cold leg recirc, would hinge on the following:

• Establishing ECCS recirc flow at least consistent with minimum safeguards

• Preventing loss of suction to the ECCS pumps The by/when aspect of the performance standard would be, "before the crew is forced to stop all safety i njection when the FSWT empties." This would be before the FWST decreases to the setpoint (Le. 5%) at which the crew is required to stop all ECCS pumps. As long as actions are taken to align the NI and NV pump suctions to the NO pumps' discharge, and action is taken to align the NS pumps to the FWST at 11 % FWST level, no ECCS pumps will be taking suction on the FWST at 5% level. Therefore closing 1 NV-252A and 1 NV-253B during transfer to Cold Leg Recirc is NOT critical.

1 NI1 OOB is also NOT critical to be closed, because it also has a check valve in series that will prevent backflow to FWST and because the NI pumps will also be receiving adequate suction from the NO pumps. This check valve is also tested per PT/1/Al4200/013H NI/NV Check Valve Test according to the Catawba OM-10 Testing Program. The Design Bases Document (DBD) originally referenced and the DBD for 1 NV253B and 1 NV252A are attached with the text highlighted that was originally used to justify closure of these valves as critical.

The DBD uses words like "possibility of ...... Ioss of suction" and " ... may become inoperable" to describe the effect of not closing valves 1 NV252A, 1 NV253B, and 1 NI1 OOB, implying that it is desired to close these valves, but NOT required to ensure cold leg recirc capability.

The critical task document was not originally referenced.

After referencing the critical task document, it was seen that closure of these valves is NOT critical.

Page I 5 Explanation of Critical task: Closure of 1 NV-2S2A and 1 NV*2538 durina tra ns fer to Cold Leg Reclrc during Scenario 3. Event 7 This task is NO T critica l per the Westinghouse Owners Group (WOG) Emergency Re s p onse Guideline (ERG) Critical Ta sk Documentation if the actions a lre ady taken will pre vent cavitation of the NV pumps. Per the crit ic al t a sk documentation, from the ERG based c rit ical tasks notebook, the critical t a s k associated wi th EP ltlAl5000/

ES-1.3, Tr a n s fe r to Cold Leg Recirculation , is: Transfer t o cold leg recirculation and establish ECCS recirculation flow. 'Clos u re of these valves i so l ates the FWS T from the NV pump suction preventing further depletion of the FWST. T he NV pumps, at this point, have al r eady had their suction aligned to the NO pump discharge , which will produce a higher suction head than the FWST. T he flow fro m the NO p um ps is prevented from flowi n g into the FWST by a check valve in the line , with 1 NV252A and 1 N V253B being closed as a backup to the check valve, which is tested per PT/11A14200/013H NIINV Check Valve Te st according to the Catawba OM-1 Q Testing Program. EP/1 1 A15000/ES-1.3 continues o n regardless of the position o f 1 N V252A and 1 NV253 B , and the final check that is made for successful transfer to Cold Leg Recirc i s flow from each of t he ECCS pumps , wh i ch w ill be prese n t with 1 NV252A and 1 NV253B op en or closed. T he Critical Task Review Group (CT R G) ant iCip ated that the performance standard , for the critical task of swapping to cold leg recirc , wou l d hi n ge on the following:

• Establishing ECCS reci r c flow at least cons i stent wi t h minimum safeguards

• Preventing loss of suction to the ECCS pu mps The by/when aspect of t h e performance standard would be ,

the c r ew i s forced to stop a ll safety injection whe n the FSWT empties." This wou l d be before the FWST decreases to the setpolnt (Le. 5%) at w h ich the crew is r equired to stop a ll E CCS pumps. As long as ac t ions a r e taken to align the NI and NV pump suctions to the NO pumps' discharge, and action i s taken to align the N S pumps to t h e FWST at 1 1 % FWST leve l , no E CCS pumps wi ll be taki n g suction on the FWST at 5% leve l. Th ere for e clos i ng 1 NV-252A and 1 NV*253B during transfer to Cold Leg R eci rc is NOT c r itica l. 1N I 10QB is a l so NOT critical to b e closed , because it also has a check va l ve i n series that will p revent backflow to FWST and because the NI pumps will also be rece iving ad equ a t e suction f rom the NO pumps. This check va l ve is als o tested per PT/1/A14200/013 H NIIN V Check Valve Test according t o the Catawba OM*10 T esting Prog ram. T h e De sign Base s D ocument (DBD) originally referenced and the DBD for 1 NV253B and 1 NV252A are attac hed wi th t he text highlighted tha t was o r ig i nally used to justify closu r e of these valves as c rit ical. Th e DBD uses words like of ..... .Ioss o f suct ion n and* ... may become in ope rable" to describe the effect of no t closing va l ves 1 NV252A, 1 N V253 8 , and 1 N1100B , implyin g tha t it is desired to close these valves, but NOT r eq uir ed to ensu r e cold leg r ecirc capabil ity. T he critical task document was not originally referenced.

After referenc i ng the critical task document , it was seen t hat closu r e of t hese valves is N O T c r itical. Page I 5