ML023460256

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NRC C Omments on Initial Examination Submittal Written Examination Worksheet, Es - 401 - 9 and Review of Operating Test for the Kewaunee Initial Examination - August / September 2002
ML023460256
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 10/11/2002
From: Bielby M
NRC/RGN-III/DRS/OLB
To:
Nuclear Management Co
References
50-308/02-301
Download: ML023460256 (14)


Text

NRC COMMENTS ON INITIAL EXAMINATION SUBMITTAL WRITTEN EXAMINATION WORKSHEET, ES-401-9 AND REVIEW OF OPERATING TEST FOR THE KEWAUNEE INITIAL EXAMINATION - AUG/SEP 2002

9 FORM ES-40i-7.

ExlaOn MOD.D mNRC 1t297 INPO Bank) d c I

room evacuation. If manual steam dump H 2 U controller following NEW. NRC: DisCgatong control t & t indicate use of manual steam dump B and D.

,B H 2 controler unavailable outside control room can eliminate room, will change B or dump outside control LICENSEE: No manual steam D to make it a creditable disaactor.

sesntence structure of others.

U BANK. NRC: Change disitractor 'C' to match 4B F--

In '0' find a way to rephrase term lost.'

that B.- could also be correct, LICENSE: Agree to changes, also Identified Will rewrite dlstractors.

FW 12 isolation valve would also be affected.

S BANK. NRC:Knowledgeoftrpsandinterlocksisfundamental.normal lineup, control of Pzr H 3 LICENSEE: Have to know long term effects, 5B change, what happened when faulted.

Instructions of the following concepts.]

B for additional Information regarding each (Refer to Section D of ES-401 and Appendix cognItive level.

question as either (F)undamental or (H)igher

1. Enter the level of knowledge (LOK) of each are acceptable).

rating scale (questions Inthe 2 - 4 range question using a I -5 (easy - difficult)

2. Enter the level of difficulty (LOD) of each aprrit ck5.-* box Ifa1sconhito flow is ldentltled: answer (e.g., unclear Intent, more In-formatio is needed, or too much needless Information).
3. Check the Teth mle - Uret focuues elicit the correct etc).
3. C ar sten or distractors contain cues i.e., clues, specific determiners, phrasing, length, The of unrelated true/false statements.
  • The answer choices area collection contradicted by stem).
  • More than one dlstractoir isIs(are) niot credible. make unstated assumptions that are not one or more distractorI partially correct (e.g., ifthe applicant can Check the a mobbox If a content error Is Identified: for has written, a valid rI(JA but, astest not operatioalI modeis(i.e.,

content) it Is not reIred to be known from memoy).

4.

Is not linked to the job requirements Q.e. the question the cosed

  • T qu~esto ec percent wtth question In gallons).

level of accuracy or Inconsistent units (e.g., panel meter in The question r n dsunrealisc compared to the job requirements.

The question requires reverse logic or applIcon SRO-mny (K/A and license levl mismatches are unacceptable).

that are sampled for conformance with the approved K/A and those that are designated

5. Check questios In need of (E)dltorlal enhancement, or (S)atIsfactory?

judgment, is the question as written (U)nacceptable (requiring repair or replacement),

6. Based on the reviewer's attributes are = met.

Atamrinimum, eRan~an U1rati (e. ,how the Ar ndB rhmetric 7.

I

S SXNV, (NItC 6197 PQ S NEW.

S BANK (NRC 12197 Wng RO to Identify a procedure transition S NEW. NRC--')QuWWisas is Fnot vlhich is an f 5Ro function. W 2)to recognize procedure transition Points Questlon LICENSEE* ROs are trairw normally performs that function. plans and 186-51M

).,MxWh an STA leaming obotves (parameters ,

NRC- Licensee Provided appropriate to ZýýOrt S NEW.

S BANK (NRC &" PT S NEW.

S MOD. (NRC 9198 IN, PO tractor's appear to be parameter signals thus stands out All of the dio porot vAthin the system, E BANK NRC.. answer is acom vvtweas the ViBRI stge INPOaveraged

)e. (NRC power are, by a cornPOnent because,of its differen( a nd avg as a component (Summer) to balance LICENSEE- The,,a,4g (circuit), ;,j %%iil list B or D distralctors.

S NEW. I NRC. E).stands Out because it is a generic statement, distmdOs U BANK ecific components.

are actions applied to 9 , 0 to apply to comport",eI'ý n.

LICENSEE'.Wit rewrite S NEW.

S NEW.

S NEW.

-page4 of 10

Explanation NEW. 1102 PB)

BANK (NRC BANK BANK RO to Identify a procedure transition NEW. NRC: Question is asidng which Is an SRO function. s rctdr e i LICENSEE: ROs are trained to recognizeperforms efally that function. ofa (parameWNRCa isoan STAee no Is Licensee provided averonithe Warning objectives and lesson NRC:

to suppor K/A"-'

about availability Of steam BANK- NRC: include statement in stem tables. (NRC2196 CC )

BANK (NRC12100 KEW)

S NEW. NRC: Capitalize "ony in distractor.

LICENSEE: Agreed.

NEW.

NEW. nofthe of the effect of a loss or malfunctio',

NEW. NRC" K/A is *Kowledge

" . Ths question I "opne have on the ArFW following (pumps) wil Blowdown S/G not AFW components.SGbodn about impact on Kwl a.....arabl qusint-etK LICENSEE: Could not writ -.-- '

change to KJA K4.

,= BANK. {NRC 1/M2 PS) 3 BANK. {NRC 112/00 KEW)

S NEW.

Page 5 of 10

1. 2. 3. Psychometric Flaws 4. Job Content Flaws 5. Other 6. 7.

Q# LOK LOD (F/H) (1-5) FcStem Cues TIF Cred. Partial Job- Minutia #V Back- Q= SRO U/E/S Explanation

.1 Focus DistD. Link j units jward K/A9 Ony 65B FH 3 E BANK NRC: LOK listed is F, I believe it requires analysis. Applicant could assume that CS was just actuated then reach a different conclusion.

LICENSEE: Will add "large break LOCA" to stem which would indicate that CS has been running for some time.

NRC: Agree 66B FH 2 / / U BANK NRC: Is thls materal that an operatorls expected to know from memory? Not RO responsibility. Question doesnt meet KA for "predicting Impact.

LICENSEE: Provided objective and lesson plans. Operations agreed. Will rewrite question to Include "prediction."

NRC: If "predict..." incorporated, would make question H.

67B H 2 S BANK NRC: (NRC 12/7 Kew) 68B H 3 S BANK 0B H 3 E NEW. NRC: Correct answer "C" stands out, add "...and test should be terminated." to "C" to balance distractors.

LICENSEE: Agreed.

70B H 3 E NEW. NRC: See question page for change to stem.

LICENSEE: Agreed.

71B H 3 S BANK 72R 4F 2 / U BANK NRC: LOK listed Is H, I belleve it is fundamental memory based on knowledge of interlocks. Question #75 supplies answer to Q #72.

LICENSEE: Will write new question.

73B H 2 S BANK 74B F 3 S BANK NRC: Operation of the toggle switch goes beyond the K/A and requires Implementing/recall of Abnormal procedure subsequent steps from memory.

LICENSEE: Provided objective and Lesson Plan reference.

75B F 2 , S NEW. NRC: Question #75 supplies answer to Q #72 LICENSEE: Q#72 will be replaced.

Page 7 of 10

1. 2. 3. Psychometric Flaws 4. Job Content Flaws 5. Other 6. 7.

Q# LOK LOD (F/H) (1-5) Stem Cues T/F Cred. Partial Job- Minutia #ttBack- Q= SRO U/E/S Explanation 76B F 3 Focus _ Dist. Link = units ward K/A Only S MOD.

77B FH 3 / U NEW. NRC: Question LOK listed Is F, I believe it requires analysis.

Selected KIA is an A2, which has two parts: 1) predict Impacts and 2) use procedures to mitigate etc. Question does not predict Impact.

LICENSEE: Will rewrite.

78R H 3 S MOD.

79R F 2 S BANK 80B H 2 S BANK (NRC 5/01 Kew) 81R H 3 V,' U NEW. NRC: Make answers consistent, A&B are diagnosis of problem; C&D are actions to take.

LICENSEE: Agreed.

82B F 3 S NEW.

83R H 3 S NEW.

84B F 3 S BANK 85B F 3 S NEW.

86B F 3 S NEW.

87B H 3 S NEW.

88B F 2 / U NEW. NRC: Stem is not required to answer question, replace/rewrite.

LICENSEE: Rewrite choices and stem so that it Isn't T/F.

89R F 2 S BANK (NRC 1/02, PB) 90B H 3 S NEW.

91B H 3 S MOD.

92R F 3 E NEW.

Page 8 of 10

1. 2. 3. Psychometric Flaws 4. Job Content Flaws 5. Other 6. 7.

Q# LOK LOD (F/H) (1-5) Focus Stem ICues IT/F ICred.

Dist. Link Minutia units Partial Job- ward V1 Back- IQ= ISRO IKA Only UEI Explanvation

,9Br' F 2 S NEW.

tR F 2 S NEW.

95B F 2 S MOD. (NRC 1/02 PB) 11B F 2 S NEW.

SH 2 S BANK 98B F 3 S BANK (NRC 102 PB) 99B F 3 S NEW.

IOOB H 3 S NEW.

49 H 2 S NEW.

2S H 3 S MOD. (NRC 2/02 Kew)

H 3 S NEW.

45 H 2 S NEW.

5S F 2 S NEW.

6S F 2 S NEW.

S H 3 S NEW.

8S F 3 S MOD. (NRC 1/02 PB)

SrS F 2 S BANK (NRC 1/02 PB) 10S F 3 S MOD. (NRC 10/97 Bw)

Sr, H 3 S NEW.

12S F 2 S NEW.

13S H 3 S NEW.

Page 9 of 10

1. 2. 3. Psychometric Flaws 4. Job Content Flaws 5. Other 6. 7.

Q# LOK LOD (FIH) (1-5) Stem Cues TIF Cred. Partial Job- Minutia #/ 1 Back Q= 1SRO UiE/S Explanation Focus Dist. Link units ward WKAI Only 14S H 2 S NEW.

-1ý6S F 2 S NEW.

16S H 2 S NEW.

S4 F 2 S NEW.

18S H 2 S NEW.

9* H 3 S NEW.

20S H 3 S BANK 21S H 2 S NEW.

22S F 2 S NEW.

23S H 3 S NEW.

24S H 3 S NEW.

S H 2 S NEW.

Higher Fundamental New Bank Modified RO 14+42=56 11+33=44 54 9+28--37 3+10=13 SRO 17+42=-59 8+33=41 58 1+28=29 3+10=13 Page 10 of 10

Kewaunee Station Operating Exam Comments Suggest using colored (ie, yellow...) paper for the JPMs and white for the applicant procedures/handouts ...

JPMs: NUREG 1021, ES-301, D.3.b, states that for each system selected for evaluation, select one task from the applicable KA catalog or site task list for which a JPM exists or can be developed.

Administrative JPMs:

JPM A. 1.a Perform Pre-critical Checklist:

NRC: No comments.

JPM A. 1.b Perform Manual Estimated Critical Position Calculation:

NRC: No comments.

JPM A.2:

NRC: No comments.

JPM A.3 (SRO) Emergency RWP Approval:

NRC: No comments.

JPM A.3 (RO) Perform Radiation Monitor Functional Test:

NRC:

1) Replace JPM. The JPM was not a Administrative JPM topic Category A.3 task, but rather a B.1 task, "Control Room Systems."

LICENSEE:

1) Facility will look at replace/rewrite.

JPM A.4 (SRO) Classify An Event per the Emergency Plan:

NRC:

1) Item 4 on the Event Notice form was identified as critical, but does not appear to be.

LICENSEE:

1) Agree, not critical.

JPM A.4 (RO) Manually Start the CRPA Recirculation System:

NRC:

(1) Replace JPM. The JPM was not a Administrative JPM topic Category A.4 task, but rather a B. 1 task, "Control Room Systems."

LICENSEE:

1) Facility will look at replace/rewrite.

System JPMs:

JPM B.1.a Perform Actions to Stop a CRW:

NRC:

1) Both B.1.a and B.1.g require applicants to recognize an abnormal condition and trip the reactor. The alternate path resolution is too similar, need to change one of the JPM end points. Suggest modifying B.l.a as follows: Have the farthest rod stop once rod control switch placed in Manual, diagnose the problem, and restore the rod configuration. In addition, the SROs could assess the TS LCO for misaligned rods.
2) Step 5 is not critical.

Page 1 of 3

LICENSEE:

1) Look at rewrite.

JPM B.1.b With a Fire in a Dedicated Zone-Restore RCS Inventory Using the Sl System:

NRC:

1) JPM Step 5 should be critical.
2) JPM Step 7 should be critical.

LICENSEE:

1) Look at rewrite.

JPM B.1.c Start a Reactor Coolant Pump:

NRC: No comments.

JPM B.1.d Secure Containment Spray Pumps:

NRC:

1) Do applicants perform this evolution during the scenarios?

LICENSEE:

1) Not scheduled to perform.

JPM B.1 .e Shift Bus 5 from TAT to RAT:

NRC:

1) Combine JPM Steps 6 and 7 into one critical step.

LICENSEE:

1) Will do.

JPM B.1.f Place an Excore NI Channel OOS:

NRC:

1) JPM Step 7 is not critical.

LICENSEE:

1) Will look at.

JPM B.1.g Shift CCW Pumps:

NRC:

1) JPM Step 1 is critical.

In-Plant JPMs:

JPM B.2.a Perform Actions for CR Evacuation-Establish LD from DSDP:

NRC: No comments.

JPM B.2.b Locally Operate the SG PORV:

NRC:

1) No alternate path identified. Need to rewrite/replace with alternate path.

LICENSEE:

1) Incorrect JPM was sent, will submit correct JPM during validation week.

JPM B.2.c Locally Operate the DG:

NRC:

1) JPM Step 10 is not critical.
2) JPM Step 11 is not critical.

LICENSEE:

1) Will look at.
2) Will look at.

Page 2 of 3

Scenarios 1. 2. & 3):

Scenario 1:

NRC:

1) Event 4, RCS leak, will accept as C failure providing we can get adequate evaluation of applicant (ie, diagnose leak, determine leak size, take action address leak such as increase charging... If we can't get adequate evaluation, we will not count as a C.
2) The reactor trip occurs after the leak becomes larger, and should be part of the M.

LICENSEE:

1) Will rewrite event, such that RCS leak is an event, but the increased leak size with reactor trip is part of the major transient.

Scenario 2:

NRC:

1) Event 4 will only count as a C for the RO if he performs substantive actions to diagnose the location of the leak and determine the size of the leak; otherwise, it will count as part of the M.

LICENSEE:

1) Understand.

Scenario 3: No comments.

Page 3 of 3