ML103440541
| ML103440541 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/15/2010 |
| From: | Church C Tennessee Valley Authority |
| To: | Baldwin R Division of Reactor Safety II |
| References | |
| Download: ML103440541 (23) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 November 15, 2010 ES-501 Mr. Richard S. Baldwin U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue, NE, Suitel200 Atlanta, Georgia 30303-1257 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328
Subject:
Reactor Operator and Senior Reactor Operator Initial Examinations -
05000327/2010302 and 0500032812010302
Reference:
NRC letter to TVA, Reactor Operator and Senior Reactor Operator Initial Examinations 05000327/2010302 and 05000328/2010302, dated October 6, 2010 In accordance with Examination Standard (ES) 501, Initial Post-Examination Activities, of NUREG 1021, Operator Licensing Examination Standards for Power Reactors, substantive comments related to the examination were provided in the referenced letter.
The purpose of this letter is to provide supplemental information to the substantive comments submitted in the referenced letter. The enclosure provides the supplemental information as discussed with Craig Kontz of your staff on November 5, 2010.
There are no commitments contained in this submittal. Should you require additional information regarding this matter, please contact Michael Buckner at (423) 843-4208 or contact Beth A. Wetzel at (423) 8437170.
Pnnte O, recycled paper
U.S. Nuclear Regulatory Commission Page 2 November 15, 2010 Sincerely, Christopher R. Church Site Vice-President Sequoyah Nuclear Plant
Enclosure:
Reactor Operator and Senior Reactor Operator Initial Examinations Supplemental Substantive Comments (ES-402)
BAW:NRT:SKD Enclosure
ENCLOSURE SEQUOYAH NUCLEAR PLANT UNITS I AND 2 Reactor Operator and Senior Reactor Operator Initial Examinations Supplemental Substantive Comments (ES-402)
The following provides supplemental information to the NRC post examination questions.
NRC Question I Simulator Job Performance Measure (JPM) G Need new evaluation criteria and basis for evaluating the applicants use of Abnormal Operating Procedure (AOP) M.04 Appendix E with centrifugal charging pump (CCP) and volume control tank (VCT) for establishing make-up. The issues of capacity (flow rate and overall available volume) need to be addressed as an alternative for residual heat removal (RHR) from the refueling water storage tank (RWST).
TVA Response I This JPM was developed as an alternate path JPM such that when the candidates determined that the Appendix A criteria for establishing flow from the RWST through the CCPs in Step 1 could not be established, the candidate would then move on to Step 2 and establish makeup flow from the RWST through an alternate path using the RHR pumps. After reviewing the step sequence and the use of check boxes as each step is performed, it would be reasonable and logical that a candidate would go back to Step 5 of the AOP after not being able to open the suction valves from the RWST to the CCPs and conclude that the next step should be the guidance in Step 5 response not obtained (RNO) column that directs the candidate to perform Appendix E of AOP-M.04. This is not the direction given to the candidate in the JPM initiating cues, (which was to establish makeup to the refueling cavity from the RWST as soon as possible) however; the direction to perform Appendix E does have a logical flow path.
Although making up to the refueling cavity using a CCP taking suction from the VCT does reduce the rate of makeup to that of VCT makeup flow (120 gpm given the plant conditions for the JPM) vs potential makeup from injection by using a CCP taking suction from the RWST
( 400 gpm ) or RHR pumps (3000 gpm ), the rate of makeup flow was not a critical task of the JPM. Since the candidates did not know what the leak rate was, they would not know if Appendix A or Appendix E flow path was adequate until after determining if refueling cavity level was recovering or not. Determining a change in refueling cavity level to indicate how effective the makeup is in recovering level was not part of the JPM, only establishing makeup flow.
The site would evaluate the candidate as satisfactory if they assumed that makeup flow from the RWST could not be established when the CCP suction valves would not open using Appendix A and then applied the Step 5 RNO column direction of implementing Appendix E.
A revised copy of JPM G, with the alternate method of makeup to the refueling cavity using Appendix E is attached.
NRC Question 2 Administrative JPM A.1 .A Overtime Restrictions TVA Standard Programs and Processes (SPP) 1.5, Section 3.2.1 .A.5, requires At least a 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break in any 9 calendar day period.
- a. How is this requirement applied / implemented at the station?
- b. How should this requirement have been applied I evaluated for the schedule given in the JPM?
TVA Response 2(a)
The actual application at the station is by using a Personnel Qualification and Scheduling software program in the Shift Operations Management System (eSOMS). This program has the criteria identified in NPG-SPP-03.21, Fatigue Management and Work Hour Limits. This is the official program used to track worker hours (actual and projected) to ensure the site is complying with the requirements of Title 10 Code of Federal Regulations (CFR) Part 26, Fitness for Duty Programs.
The application of Section 3.2.1 .A.5 of At least a 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break in any 9 calendar day period is actually a 216-hour period. The computer program evaluates the 34-hour break based on the start of work following a break of at least 34 continuous hours. Therefore, the computer program would evaluate the 216 hours0.0025 days <br />0.06 hours <br />3.571429e-4 weeks <br />8.2188e-5 months <br /> since the end of the last break of at least 34 continuous hours for another break of at least 34 continuous hours in length.
TVA Response 2(b)
Normally any hours scheduled to be worked (or planned to be worked) are processed using eSOMS to determine if any of the established criteria from Section 3.2.1 would be violated.
The JPM as administered had the candidates do a manual calculation of a work schedule based on the hours presented. During development and validation it was determined that two critical tasks (work hour violations) were present. It was not identified that a violation of Item 3.2.1 .A.5 (a 34 hr break in any 9 calendar day period) had been committed. The work hours given in the JPM were processed through the eSOMS software and the computer program did identify the two predetermined work hour violations, (one on May 30, 2010, for a violation of greater than 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period and one on June 4, 2010, for a violation of greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period); however, it did not identify a violation of Item 3.2.1.A.5.
The procedure requires evaluating any 9 calendar days and it would appear that a violation of the 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break in any 9 day requirement may occur on June 7, 2010. However, because of evaluating the 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break in 9-day period at the end of the workday or start of the next work day, not during a non-workday, there is a greater than 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break for the work hours listed in the JPM. If a candidate determined that a potential violation did occur for this instance it would be a conservative call and would actually need to be verified through the use of the official tracking tool (eSOMS). This would not constitute a failure by the candidate, only an item which would need further evaluation.
JPM Sim G Page 1 of 18 Rev. 1 SEQUOYAH NUCLEAR PLANT September2010 NRC Exam SIM G (RO\SRO) nitiate Makeup to the Refueling Cavity (rev. 1)
JPM Sm G Page 2 of 18 Rev. 1 ROISRO JOB PERFORMANCE MEASURE Task: Initiate Makeup to the Refueling Cavity Task#: 3210110401 (RO)
Task Standard: Makeup to the refueling cavity via the RHR Pumps is initiated per AOP-M.04.(preferred method)
Makeup to the refueling cavity via the COPs and VCT is initiated per AOP-M.04. (alternate)
Time Critical Task: YES: NO: X KJA ReferencelRatings: 036AA2.02 (3.4/4.1) 004A4.08 (3.8/3.4) 036AK3.03 (3.7/4.1)
Method of Testing:
Simulated Performance: Actual Performance: X Evaluation Method:
Simulator X n-Plant Classroom Main Control Room Mock-up Performer:
Trainee Name Evaluator: /
Name I Signature DATE Performance Rating: SAT: UNSAT:
VaHdation Time: 15 minutes Total Time:
Performance Time: Start Time: Finish Time:
COMMENTS
JPM Sim G Page 3 of 18 Rev. 1 SPECIAL INSTRUCTIONS TO EVALUATOR:
- 1. Critical steps are identified in step SAT/UNSAT column by bold print Critical Step.
- 2. Any UNSAT requires comments
- 3. Initialize the simulator to IC-i 14 and complete the following setup.
- 4. Override # AN:OVRDN_584 to ON, to bring in alarm for SPENT FUEL PIT LEVEL.
- 5. Override ZAOL168320, ZAOL168321, ZAOL168335A, ZA0L168339A at 50 to simulate PZR at refueling level.
- 6. Override ZAOPI6866A, ZAOP16869, ZA0P16862 at 35 to simulate refuel flood up pressure.
- 7. Override AN:OVRDN_1695 to OFF to keep midloop high level alarm from alarming.
- 8. Override (FCV-62-135 & 136, CCP Suction from VCT, CLOSED. (ZLOHS62I35A_Green f:ON, ZLOHS62I36A_Green f:ON, ZDIHS62I35A f:O (close), ZDIHS62I36A f:0 (close)
- 9. Insure operator performs the following required actions for SELF-CHECKING;
- a. Identifies the correct unit, train, component, etc.
- b. Reviews the intended action and expected response.
- c. Compares the actual response to the expected response.
- 10. Add Caution Order tag to FCV-63-i per 0-GO-13 App. 0. (jumpers placed to remove seal in)
Tools/EquipmentlProcedures Needed:
AOP-M.04, Section 2.0, 2.1, and Appendix A & B
REFERENCES:
- 1. AOP-M.04, Sect 2.1 & Appendix A Refueling Malfunctions Rev No. 9
- 2. AOP-M.04, Sect 2.1 & Appendix E Refueling Malfunctions Rev No. 9 Task Number Task Title Cont TRN 3210110401 (RO) Initiate Makeup to the Refueling Cavity
JPM Sim G Page 4 of 18 Rev. 1 READ TO OPERATOR DIRECTIONS TO TRAINEE:
I will explain the initial conditions, and state the task to be performed. I will provide initiating cues and reports on other actions when directed by you.
All steps shall be performed for this task. When you complete the task successfully, the objective for this job performance measure will be satisfied. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.
INITIAL CONDITIONS:
- 1. Unit I is in mode 6 performing refueling operations. Approximately 1/2 of the core has been off-loaded at this time.
- 2. There is one fuel assembly in transit to the spent fuel pit from the core. It is presentiy in the upender cart in transient to the spent fuel pit.
- 3. The refueling SRO in the reactor building has just informed you that there is an obvious drop in reactor cavity level.
- 4. A dedicated operator that has been assigned to monitor vessel level instruments, informs you that there is a decreasing trend in Reactor cavity level indicators.
INITIATING CUES:
I. The refueling SRO reports a confirmed reactor cavity seal failure is occurring.
- 2. Alarm on panel 1-M-6D (D3) SPENT FUEL PIT LEVEL HIGH-LOW has just actuated.
- 4. The US directs you to perform AOP-M.04, Refueling Malfunctions (single performer method).
JPM Sim G Page 5 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SAT/U NSAT NOTE: If operator responds using AR-M6-D window D-3. AUO is dispatched to the SEP to investigate the alarm. Operator determines that AOP-M.04 is the appropriate procedure.
SAT STEP 1: Obtain the appropriate procedure.
UNSAT Start Time STANDARD: Operator obtains a copy of AOP-M.04.
COMMENTS:
STEP 2: 1. EVALUATE the following Tech Specs for applicability: SAT
- 3.9.8.2, RHR Low Water Level UNSAT
- 3.9.10, R Vessel Water Level
- 3.9.11, Refueling Operations Spent Fuel Pit Water Level Cue: The US will evaluate the Tech Specs for applicability STANDARD: Operator notifies US of the need to evaluate these three Tech Spec items.
COMMENTS:
STEP 3: 2. EVALUATE EPiP-i, Emergency Plan initiating SAT Conditions Matrix.
UNSAT Cue: The SM will evaluate the Emergency Plan STANDARD: Operator notifies US/SM of the need to evaluate the Emergency Plan.
CO M ME NT.S:
JPM Sim G Page 6 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SAT/U NSAT STEP 4: 3. Diagnose conditions to determine appropriate section, of SAT AOP-M.04, to perform.
UNSAT STANDARD: Based on plant indications and initial conditions, determines that section 2.1 must be performed and proceeds to page 4.
COMMENTS:
Caution 1: Loss of Spent Fuel Pit or Refueling Cavity level and subsequent loss of shielding may result in extremely high dose rates in Containment and Spent Fuel Pit areas.
Caution 2: If the reactor cavity water level drops to flange elevation with upender in vertical position, the top 0.25 inch of upender will extend above surface of water.
Note: Fuel Handling SRO. personnel required to place fuel in safe location, and Radcon personnel remain (if possible) until required actions are completed.
STEP 5: 2.1.1 ANNOUNCE to all non-essential personnel to evacuate SAT Containment and AB el. 734 Refuel Floor.
UNSAT Cue: The SM would like you to make that announcement.
STAN DARD: Operator makes this announcement.
COMMENTS:
JPM Sim G Page 7 of 18 Rev. 1 Job Performance Checkhst STEP/STANDARD SAT/UNSAT SIEP 6: 2.1.2 ENSURE the following personnel notifled that seal SAT failure has occurred:
UNSAT
- Control Room
- RADCON to monitor refueling area and Aux Bldg as required
- Fuel Handling Supervisor Cue: The SM will ensure all control room personnel and the Fuel Handling SupervIsor are aware of the event and that RADCON begins monitoring CNMT and the Aux Bldg.
STANDARD: Operator ensures these people are notified.
COMMENTS:
Caution: Failure to maintain RWST level greater than 5% may cause CCPs or RHR pumps to lose suction.
STEP 7: 2.1.3 MAINTAIN Refueling Cavity level as necessary: SAT
b.
Cue: US directs makeup from RWST using CCP STANDARD: Operator obtains a copy of Appendix A Section A of AOP-M.04.
COMMENTS:
NOTE:The following are from Appendix A, Filling Refueling Cavity From RWST, Section A of AOP-M.04.
STEP 8: A.1 .a. VERIFY RWST level greater than 8%.
SAT UNSAT STANDARD: Operator verifies RWST level greater than 8% using one or more of the RWST level indicators located on M-6.
COMMENTS:
JPM Sim G Page 8 of 18 Rev. 1 Job Performance Checkhst STEPISTANDARD SAT! UNSAT STEP 9: A.1 .b. ENSURE the foliowing charging vaves OPEN: SAT UNSAT FCV-62-90 STANDARD: Operator verifies FCV-62-90 open by observing 1-HS 90A RED light LIT.
COMMENTS:
STEP 10: A.1 .b. ENSURE the following charging valves OPEN: SAT UNSAT FCV-62-91 STANDARD: Operator verifies FCV-62-91 open by observing 1 -HS 91A RED light LIT COMMENTS:
STEP 1 1: A.1 .b. ENSURE the following charging valves OPEN: SAT UNSAT FCV-62-85 OR FCV-62-86 STANDARD: Operator verifies FCV-62-85 or 86 is open by observing 1-HS-62-85A or 1-HS-62-86A RED light LIT.
COMMENTS:
JPM Sim G Page 9 of 18 Rev. 1 Job Performance Checklist STEPISTANDARD SAT/UNSAT STEP 12 A 1 c OPEN the foUowg valves SAT U N SAT Critical Step STANDARD: Operator pushes HSs (1-HS-62-135A and 1-HS-62-136A)
IN and turns to the OPEN position and determines that neither valve opens Green lights remain LIT for FCVs 135 and 136.
Cue: If required, acknowledge and ask for recommended path to complete task.
This step is critical to attempt a supply to the refueling cavity makeup flowpath and then for the UO to determine the valve failure so the alternate path may be utilized.
flflMMFNTS Evaluator Note: The candidate should recommend using the alternate method of filling Reactor Cavity by performing step 2 of Appendix A, OR the candidate may determine that response was not obtained due to suction valves not opening, flow from RWST is not available and returns to AOP step 5, RNO column.
(if candidate returns to step 5, RNO to perform Appendix E, then go to JPM step 20)
STEP 13: Operator reports to US that neither COP suction from the SAT RWST will open.
UNSAT Cue: After operator reports not being able to open CCP suction valves, report as the US that you will contact Maintenance Shift Supervisor to investigate the cause of the valve failure.
STANDARD: Operator determines that step 2 of Appendix A is appropriate action to take or returns to step 5 RNO column for next action.
COMMENTS:
JPM Sim G Page 10 of 18 Rev. 1 Job Performance Checklist STEP/STAN DARD SAT/U NSAT NOTE: The following are from Appendix A. Section A, Step 2 of AOP-MM4.
STEP 14: A.2. IF initiating makeup from RWST using RHR Pump SAT suction, THEN PERFORM the following: UNSAT
- a. VERIFY RWST level greater than 8%.
STANDARD: Operator verifies RWST level greater than 8% using one or more of the RWST level indicators located on M-6.
COMMENTS:
STEP 15: A.2. F initiating makeup from RWST using RHR Pump SAT suction, THEN PERFORM the following: UNSAT
- b. OPEN FCV Critical Step STANDARD: Operator uses HS-63-1A and opens FCV-63-1, Observes Red light ON, Green light OFF.
This step is critical to provide a makeup flowpath from the RWST to the refueling cavity.
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JPM Sim G Page 11 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SAT/UNSAT STEP 16: A.2. F initiating makeup from RWST using RHR Pump SAT suction, THEN PERFORM the following: UNSAT
. cLosE e: the foflow
-. FCV74 RHR Critical Step
- FCV442, RI-IR STANDARD: Operator uses HS-74-1A and CLOSES FCV-74-1, Observes Red light OFF, Green light ON. OR Operator uses HS-74-2A and CLOSES FCV-74-2, Observes Red light OFF, Green Ught ON This step is critical to isolate the normal RHR suction flowpath and to swap over to the RWST suction flowpath.
COMMENTS:
STEP 18: A.2.d VERlFYflowto RCS. SAT UNSAT STANDARD: Operator verifies flow into the RCS by observing flow on 1-Fl-63-91B or 1-Fl-63-92B.
COMMENTS:
JPM Sim G Page 12 of 18 Rev. 1 Job Performance Checklist STEPISTANDARD SAT/UNSAT STEP 19: Inform the US of flow from RWST to RCS/Refueling Cavity. SAT UNSAT STANDARD: Operator informs US and/or SM that flow has been established from RWST to Spent Fuel Pit.
Stop Time Cue: After operator reports that flow has been established, State This completes the JPM.
COMMENTS:
Evaluator Note: If candidate went back to Step 5 RNO start evaluation here STEP2O: 2.1.5.aRNO: SAT IF RWST NOT available, THEN PERFORM the following: UNSAT
- 1) INITIATE makeup using normal charging with CCP suction aligned to VCT USING App. E, Refueling Cavity Makeup Using Normal Charging.
STANDARD: Operator transitions to App E to initiate makeup using normal charging.
CO M ME NTS:
JPM Sim C Page 13 of 18 Rev. 1 Job Performance Checklist STEPISTANDARD SAT/U NSAT NOTE: The following steps are from Appendix E, of AOP-M.04.
STEP 21: App E 1. SAT U N SAT STANDARD: Operator places Manual/Auto toggle switch to Manual on controller 1-HIC-62-81A and then moves toggle to the ri ica
- ep right until valve position indicator is fully CLOSED (indicator needle stops moving to the right)
This is a critical step to stop letting down water from RHR system to conserve RCS i nvento 7.
COMMENTS:
STEP 22: 2. ENSURE FCV-62-83, RHR Letdown CLOSED. SAT UNSAT STANDARD: Operator turns setpoint dial fully clockwise and observes position indicator goes fully to CLOSE (left) position CO v1 ME NTS:
JPM Sim G Page 14 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SAT/UNSAT STEP 23: 3. ENSURE one of the following valves OPEN: SAT UNSAT FCV-62-85, Charging FCV to Loop 1 OR FCV-62-86, Charging FCV to Loop 4 STANDARD: Operator verifies FCV-62-86 is Open by observing switch for FCV-62-86 in the Open position and Red light On.
COMMENTS:
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iuiiuwiiIy VdIVt JFC.I4.
S AT UNSAT FCV-62-90, Charging isolation FCV-62-91, Charging isolation STANDARD: Operator verifies FCV-62-90 and FCV-62-91 are Open by observing switch for each valve in A-Auto position and Red light On, Green light off for each valve.
COMMENTS:
Evaluator Note: The VCT makeup rate will be limited to 120 gpm for normal auto makeup, if charging is increased above this value then VCT makeup will be required.
JPM Sim G Page 15 of 18 Rev. 1 Job Performance CheckHst STEPISTANDARD SATIU NSAT STEP 25: 5. ENSURE VCT makeup initiated as necessary to maintain SAT VCT level above 20%: UNSAT STANDARD: Operator verifies VCT level above 20% and notes the need to monitor level to ensure normal makeup initiates as necessary.
COMMENTS:
STEP 26: 6. ENSURE the following valves OPEN: SAT UNSAT FCV-62-132, CCP Sucton from VCT FCV-62-133, CCP Suction from VCT STANDARD: Operator verifies that FCV-62-132 and FCV-62-133 are OPEN by observing control switches in A-Auto position and Red light ON, Green light Off COMMENTS:
JPM Sim G Page 16 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SAT/UNSAT STEP 27: 7. ENSURE the following valves CLOSED: . SAT UNSAT FCV-62-135, CCP Suction from RWST FCV-62-136, CCP Suction from RWST STANDARD: Operator verifies that FCV-62-135 and FCV-62-136 are CLOSED by observing control switch indications Green light ON, Red light Off.
Evaluator Note: valves are failed closed per the previous JPM malfunction COMMENTS:
STEP 28: 8. ENSURE CCP running. SAT UNSAT STANDARD: Operator verifies that lB-B CCP running by observing control switch in A-Auto position and Red light ON, Green light Off, and normal running amps, discharge pressure, for plant conditions.
COMMENTS:
Evauator Note: If candidate establishes greater than 120 gpm charging flow to the RCS in the next step, normal makeup flow will not be able to maintain VCT level greater than 20%
and they will eventually lose this source of makeup water if VCT level cannot be maintained.
JPM Sim G Page 17 of 18 Rev. 1 Job Performance Checklist STEP/STANDARD SATIUNSAT STEP 29 9 ADJUST FGV-62-89 and FGV62-93 to es SAT UNSAT STANDARD: Operator adjusts charging flow by positioning control dial (turning dial counter clockwise) on 1-HC-82-93A to open ri ica
- ep FCV-62-93 to establish 1 20 gpm flow to the RCS.
This step is critical to ensure that makeup flow is being provided to the RCS to attempt to makeup for inventory loss due to the Reactor Cavity Seal.
COMMENTS:
STEP 30: Inform the US of flow from VCT to RCS!Refueling Cavity. SAT UN SAT STANDARD: Operator informs US and/or SM that flow has been established from VCT to RCS/Refueling Cavity.
Stop Time Cue: After operator reports that flow has been established, State This completes the JPM.
COMMENTS:
End Of JPM
READ TO OPERATOR DIRECTIONS TO TRAINEE:
I will explain the initial conditions, and state the task to be performed. I will provide initiating cues and reports on other actions when directed by you.
All steps shall be performed for this task. When you complete the task successfully, the objective for this job performance measure will be satisfied. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.
INITIAL CONDITIONS:
- 1. Unit I is in mode 6 performing refueling operations. Approximately 1/2 of the core has been off-loaded at this time.
- 2. There is one fuel assembly in transit to the spent fuel pit from the core. It is presently in the upender cart in transient to the spent fuel pit.
- 3. The refueling SRO in the reactor building has just informed you that there is an obvious drop in reactor cavity level.
- 4. A dedicated operator that has been assigned to monitor vessel level instruments, informs you that there is a decreasing trend in Reactor cavity level indicators.
INITIATING CUES:
- 1. The refueling SRO reports a confirmed reactor cavity seal failure is occurring.
- 2. Alarm on panel I -M-6D (D3) SPENT FUEL PIT LEVEL HIGH-LOW has just actuated.
- 4. The US directs you to perform AOP-M.04, Refueling Malfunctions (single performer method).