ML090290235

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Retake Exam - Draft - Outlines (Folder 2)
ML090290235
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 10/02/2008
From:
Calvert Cliffs
To:
Operations Branch I
HANSELLS
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TAC U01779
Download: ML090290235 (22)
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Text

ES-401 PWR Examination Outline Form ES-4014 ]

Facility: Calvert Cliffs Date of Exam: December 08,2008 I

I II Total RO K/A Category Points K

K K

K K

K A

A A

A G

1 2

3 4

5 6

1 2

3 4

Total Tier Group Categories Note:

1.
2.
3.
4.
5.
6.

7.'

8.
9.

and SRO Ensure that at least two topics from every applicable WA category are sampled within each tier of the RO only outlines (Le., except for one category in Tier 3 of the SRO-only outline. the "Tier Totals" in each WA category shall no be less than two).

The point total for each group and tier in the proposed outline must match that specified in the table.

The final point tota for each group and tier may deviate by f l from that specified in the table based on NRC revisions. The final KO exam must total 75 points and the SRO-only exam must total 25 points.

Systems/evolutions within each group are identified on the associated outline; systems or evolutions that do not apply at the facility should be deleted and justified; operationally important, site-specific systemslevolutions that are not included on the outline should be added. Refer to Section D.l.b of ES-401 for guidance regarding the elimination of inappropriate K/A statements.

Select topics from as many systems and evolutions as possible; sample every system or evolution in the group before selecting a second topic for any system or evolution.

Absent a plant-specific priority, only those WAS having an importance rating (IR) of 2.5 or higher shall be selected.

the RO and SRO ratings for the RO and SRO-only portions, respectively.

Select SRO topics for Tiers 1 and 2 from the shaded systems and K/A categories The generic (G) WAS in Tiers 1 and 2 shall be selected from Section 2 of the WA Catalog, but the topics must be relevant to the applicable evolution or system. Refer to Section D.1.b of ES-401 for the applicable WAS.

On the following pages, enter the WA numbers, a brief description of each topic, the topics' importance ratings (IRs) for the applicable license level, and the point totals (#)for each system and category. Enter the group and tier totals for each category in the table above; if fuel handling equtpment is sampled in other than Category A2 or G* on the SRO-only exam, enter it on the left side of Column A2 for Tier 2, Group 2 (Note # I does not apply). Use duplicate pages for RO and SRO-only exams.

For Tier 3, select topics from Section 2 of the KI'A catalog, and enter the WA numbers, descriptions, IRs, and point totals (#) on Form ES-401-3. Limit SRO selections to WAS that are linked to 10 CFR 55.43.

Use

X K

K A

A G

KIA Topic(s) 2 3

1 2

EK2.03 - Reactor trip status panel X

AK1.02 - Change in leak rate with change in pressure EI(3.26 - Maintenance of RCS subcooling 2.2.44 -Ability to interpret control room indications to verify the status and operation of a system, and understand how operator actions and directives affect plant and system conditions.

AK2.07 - RCP seals X

X X

EK3.3 ~ Manipulation of controls required to obtain desired operating results during abnormal and emergency situations.

EK3.02 - Actions contained in EOP for loss of offsite and onsite power AA2.73 - PZR heater onloff AA 1.06 - Manual control of components for which automatic control is lost AA2.01 - That a loss of dc power has occurred; verification that substitute power sources have come on line X

X X

000077 Generator Voltage and Electric Grid Disturbances / 6 KIA Category Totals:

3 3

3 3

3 3

Group Point Total:

Form ES-401-;!_ll -

11 ES-401 PWR Examination Outline

.bnorrnal Plant Evolutions - Tier l/Group 1-Reactor Operator I

l l

I I

ES-401 Emergency and I

I-ElAPE # / Name / Safety Function K

1 000007 (CE/E02) Reactor Trip -

Stabilization - Recovery / 1 000008 Pressurizer Vapor Space Accident I 3 x

1 000009 Small Break LOCA I 3 00001 1 Large Break LOCA I 3 5:

3 2 000015/17 RCP Malfunctions / 4 I

000022 Loss of Rx Coolant Makeup / 2 000025 Loss of RHR System / 4 000026 Loss of Component Cooling

==I-Water / 8 I I I

I AA1.03 - PZR level trend AK.1.01 - Loss of RHRS during all modes of 1

1 1

I I opcration 2.2.40 - Ability to apply technical I

l l

1 x 1 Specifications for a system.

I 000029 ATWS / 1 1

1 1

I EA 1.OS - Reactor trip switch pushbutton 000038 Steam Gen. Tube Rupture / 3 I

I 1

I I

I EKI.01 - Use of steam tables

~

~~

~

000040 (CE/E05) Steam Line Rupture -

Excessive Heat Transfer I 4 2.4.45 - Ability to prioritize and interpret the significance of each annunciator or alarm. L-000054 (CEIEO6) Loss of Main Feedwater / 4 000055 Station Blackout / 6 000056 Loss of Off-site Power / 6 000057 Loss of Vital AC Inst. Bus / 6 000058 Loss of DC Power / 6

~

000065 Loss of Instrument Air I 8 2.9 I AA2.01 - Cause and effect of low-pressure insirumeiit air alarm X I I I 1

1 AK2.06 - Reactor power 3.9 1 r

CE/A16 Excess RCS Leakage / 2 CE/EO9 Functional Recovery KIA Category Point Totals:

features AKI 2 - Normal, abnoiinal and associated with (Excess RCS Leakage)

EA I 1 - Components, and functions of control and safety systems, including X

instrumentation, signals, interlocks, 4 2 failure modes, and automatic and manual features x

emergency operating procedures 3 0 I

2 1

2 2

I Group Point Total:

9

Form ES-401-idI -

1 ES-401 PWR Examination Outline X

X K

K 1

2 X

X I

PWR Exa Form ES-401-2 utline ES-401 System # / Name Reactor Operator G

K/A Topic(s) 003 Reactor Coolant Pump I

K6.14 -Starting Requirements +-

2. I.3 1 - Ability to locate control rooin switches, controls, and indications, and to determine that they correctly reflect the desired plant lineuu.

X

't 003 Reactor Coolant Pump K5.14 - Reduction process of gas concentration in RCS: vent-accumulated non-condensable gases froin PZR bubble space, depressurized during cooldown or by alternately heating and cooling (spray) within allowed pressure band (drive more gas out of solution)

K5.02 - Need for adequate subcool ing A3.04 - Cooling water systems K2.02 - Valve operators for accumulators K3.0 1 - Containment K2.02 - CCW pump, including emergency backup 2.4. I - Knowledge of EOP entry X

condition and immediate action steps.

004 Chemical and Volume Control 005 Residual Heat Removal 006 Emergency Core Cooling 006 Emergency Core Cooling 007 Pressurizer RelieWQuench Tank 008 Component Cooling Water 008 Component Cooling Water 3 0 4 6 3 1 3 3 3 7 2 8 2 9 4 2 3 6 010 Pressurizer Pressure Control 01 2 Reactor Protection A 1.06 - RCS heatup and cooldown 013 Engineered Safety Features Actuation K1.18 - Premature reset of ESF actuation K4.04 - Cooling of control rod drive motors K3.01 - Containment equipment sub.ject to damage by high or low temperature, humidity, and pressure K1.0 1 - ECCS 022 Containment Cooling 022 Containment Cooling 026 Containment Spray 2.2.37 - Ability to determine operability and/or availability of safety re I ated equipment.

026 Containment Spray

ES-401 PWR Examination Outline onsequences o

II

=il ES-40 1 PWR Examination Outline Plant Systems - Tier 2/Group 2 - Reactor K

K K

K K

K A

A A

A G

1 2

3 4

5 6

1 2

3 4

System # / Name 001 Control Rod Drive X

027 Containment Iodine Removal 033 Spent Fuel Pool Cooling X

X 035 Steam Generator X

04 1 Steam Dump/Turbine X

Bypass Control 055 Condenser Air Removal X

056 Condensate 068 Liquid Radwaste X

071 Waste Gas Disposal X

086 Fire Protection X

X WA Category Point Totals:

1 0

1 1

1 1

1 1

1 1

1 11 ES-401 PWR Examination Outline Form ES-401-kdl -

Form ES-40 1-2 Operator WA Topic(s)

IK A2 07 - Effect of reactor trip on primary and secondary parameters and 4 1 systems A4 02 - Remote operation and handling of iodine filters AI 01 - Spent fuel pool water level 2 7 3 2 2 3 K6 01 - MSlVs K5 07 - Reactivity Effects KI 06 - PRM system 2 4 6 - Knowledge of EOP A3 02 - Automatic isolation K3 04 - Ventilation system K4 02 - Maintenance of fire 2 0 mitigation strategies 3 '7 header pressure 3 0 Group Point Total:

10

Form ES-401-4 ES-401 PWR Examination Outline E/APE # I Name / Safety Function 000015/17 RCP Malfunctions / 4 000027 Pressurizer Pressure Control System Malfunction / 3 000040 Steam Line Rupture -

Excessive Heat Transfer / 4 000054 Loss of Main Feedwater / 4 000062 Loss of Nuclear Svc Water / 4 CEIE02 Reactor Trip - Stabilization -

Recovery / 1 K/A Category Totals:

0 0

K K

K A

A G

K/A Topic(s)

IR 2.1.I 9 - Ability to use plant computers to evaluate system or component status.

A.42.10 - PZR heater energized/de-energized 2.4.23 - Knowledge of the bases for itnpletnentation during emergency operations.

AA2.01 - Occurrence of reactor and/or turbine 3 5 AA2.01 - Location of a leak in the SWS 2.4.41 - Knowledge of the emergency action level thresholds and classifications.

4 6 0

0 3

3 GroupPointTotal:

6 1

2 3

1 2

3 8 X

X condition 3 6 prioritizing emergency procedure 4 4 X

trip 4 4 x

I

=il 0

11 ES-401 PWR Examination Outline Form ES-401 -:gl 2.4.20 - Knowledge of operational and notes.

X implications of EOP warnings, cautions, 4.3 0

0 2

2 Group Point Total:

4 ES-401 PWR Examination Outline Form ES-401-2 it Evolutions - Tier l/Group 2 - Sr. Reactor Operator KIA Category Point Totals:

Emergency and Abnormal PI K

1 E/APE # / Name / Safety Function 0

000001 Continuous Rod Withdrawal I 1 000003 Dropped Control Rod / 1 I

00005 1 Loss of Condenser Vacuum 000033 Loss of Intermediate Range NI 17 ll K

K A

A G

K/A Topic(s) 2 3

1 2

X AA2.04 - Reactor power and its trend 2.4.1 - Knowledge of EOP entry conditions and immediate action steps.

AA2.0 1 ~ Cause of low vacuum condition

Form ES-401 -;d ES-401 PWR Examination Outline ES-401 System # / Name 005 Residual Heat Removal 0 13 Engineered Safety Features Actuation 06 1 Auxiliary/Emergency Feedwater 073 Process Radiation Monitoring

~

078 Instrument Air KIA Category Point Totals:

K K

1 2

PV ! Exar iation actor Operator K/A 1-opic(s)

A2.02 - Pressure transient protection during cold shutdown 2.1.45 - Ability to identify and interpret diverse indications to validate the response of another indication.

A2.08 - Flow rates expected from various combinations of AF W pump discharge valves 2.4.6 - Knowledge of EOP mitigation strategies.

A2.01 - Air dryer and filter malfunctions Group Point Total:

Form ES-401-2 I 4

I

Form ES-401- -

ES-401 PWR Examination Outline 11 ES-401 11 072 Area Radiation I

WA Category Point Totals:

0 I W li Exaini nati on Out I i 11c Form ES-401-2 3 2 - Sr.

A A

2 3

X X

Leactor 1 A (i 4

X

,erator IUA lopic(s)

A2.04 - Effects on axial flux density of control rod alignment and sequencing, xenon production and decay, and boron vs.

control rod reactivity changes A2. I7 - Malfunction of electrohydraulic control 2.2.37

~ Ability to determine operability and/or availability of safety related equipment.

Group Point Total:

3.8

ES-401 Generic Knowledge & Abilities Outline Form ES-401 1 Topic Knowledge of shift or short-term relief turnover practices.

Ability to make accurate, clear, and concise verbal reports Knowledge of RO duties in the control room during fuel handling, such as responding to alarms from the fuel handling area, communication with the fuel storage facility, system operated from the control room in support of fueling operations, and supporting instrumentation.

Facility: Calvert Cliffs Category RO IR 3.7 3.9 3.9

1.

Conduct of Operations

~~

~~~

~~

3.2 2.3.4 Knowledge of radiation exposure limits under normal or emergency conditions.

2.3.1 1 Ability to control radiation releases.

3.8 Control may arise during normal, abnormal, or emergency 3.7

3.

Radiation 2.3.14 Knowledge of radiation or contamination hazards that conditions or activities.

Ability to approve release permits.

Knowledge of radiation monitoring systems, such as fixed 2.3.6 2.3.1 5 2.1.3 2.1.17 2.1.44 I Subtotal 2.2.1 Ability to perform pre-startup procedures for the facility, including operating those controls associated with plant equipment that could affect reactivity.

2.1.20 3

4.5 1 2.1.40 2.4.5 Knowledge of the organization of the operating procedures network for normal, abnormal, and emergency evolutions.

Knowledge of abnormal condition procedures.

Ability to prioritize and interpret the significance of each 3.7 2.4.1 1 2.4.45 I

Ability to intermet and execute procedure steps.

1 1

annunciator or alarm.

Knowledge of refueling administrative reauirements.

I I

~~

Subtotal 2

2.

Equipment Control 2.2.1 7 Knowledge of the process for managing maintenance activities during power operations, such as risk assessments, work prioritization, and coordination with I

I the transmission system operator.

I I

~~

of the process used to track inoperable alarms.

I I

I S

u b

t oz radiation monitors and alarms, portable survey instruments, personnel monitoring equipment, etc.

I Subtotal I

3 1

4.

Emergency Procedures I Plan I

2.4.3 I Ability to identify post-accident instrumentation.

1 3.7 I 10 Tier 3 Point Total 4.2 1

4.3 I

ES-401 Record of Rejected WAS Form ES-401-4 Tier / Group RO - 1/1 RO - 2/1 RO - 2/2 RO - 2/2 SRO - 1/1 SRO-1/2 SRO - 1/2 SRO - 21'2 Randomly Selected KIA EA 1.02

~~

~~

025 K2.02 A3.01 2.1.43 2.4.26 005 AA2.01 2.4.26 Reason for Rejection Replaced 029, EAI.02 with 029, EA1.08. WA EA1.02 is an inappropriate match for tlie E/APE # selected. CCNPP standard post-trip ac,tions for an ATWS do not include boration from the RWST.

Replaced 025, K3.01 with 022, K3.01. Calvert Cliffs does not have ice condensers.

Replaced K2.02 with K3.04. Calvert Cliffs does not have an Integrated Control System.

Replaced A3.01 with A3.02. Calvert Cliffs Reactor Coolant Waste Evaporators are retired-in-dace Replaced 2.1.43 with 2.1.19. Poor WA match to system Replaced K/A 2.4.26 with K/A 2.4.1. K/A 2.4.26 is an inappropriate match for tlie E/APE # selected. K/A 2.4.26 paire knowledge of faci I ity fire protection with a Dropped Control Rod. K/A 2.4.1 pairs knowledge of EOP entry conditions and immediate action steps with a Dropped Control Rod.

Replaced 005 AA2.01 with 051 AA2.01 due to over sampling 0 1 CEA Malfunctions.

Replaced K/A 2.4.26 with 2.2.37. K/A 2.4.26 is an inapproprial match for the E/APE # selected. K/A 2.4.26 paired knowledge of facility fire protection with Area Radiation Monitoring. WA 2.2.37 pairs the ability to determine operability and/or availabilitv of safety related equipment with Area Radiation Monitoring.

CCNPP LOI-2206 Retake Exam Data Form ES-401-2 1

ES-401 PWR Examination Outline Note:

1.
2.
3.
4.
5.
6.

7.*

8.
9.

Ensure that at least two topics from every applicable K/A category are sampled within each tier of the RO and SRO-only outlines (i.e., except for one category in Tier 3 of the SRO-only outline, the Tier Totals in each K/A category shall not be less than two).

The point total for each group and tier in the proposed outline must match that specified in the table.

The final point total for each group and tier may deviate by *l from that specified in the table based on NRC revisions. The final RO exam must total 75 points and the SRO-only exam must total 25 points.

Systems/evolutions within each group are identified on the associated outline; systems or evolutions that do not apply at the facility should be deleted and justified; operationally important, site-specific systems/evolutions that are not included on the outline should be added. Refer to Section D.1.b of ES-401 for guidance regarding the elimination of inappropriate K/A statements.

Select topics from as many systems and evolutions as possible; sample every system or evolution in the group before selecting a second topic for any system or evolution.

Absent a plant-specific priority, only those K/As having an importance rating (IR) of 2.5 or higher shall be selected.

Use the RO and SRO ratings for the RO and SRO-only portions, respectively.

Select SRO topics for Tiers 1 and 2 from the shaded systems and K/A categories.

The generic (G) K/As in Tiers 1 and 2 shall be selected from Section 2 of the K/A Catalog, but the topics must be relevant to the applicable evolution or system. Refer to Section D.1.b of ES-401 for the applicable K/As.

On the following pages, enter the K/A numbers, a brief description of each topic, the topics importance ratings (IRs) for the applicable license level, and the point totals (#) for each system and category. Enter the group and tier totals for each category in the table above; if fuel handling equipment is sampled in other than Category A2 or G* on the SRO-only exam, enter it on the left side of Column A2 for Tier 2, Group 2 (Note #1 does not apply). Use duplicate pages for RO and SRO-only exams.

For Tier 3, select topics from Section 2 of the K/A catalog, and enter the K/A numbers, descriptions, IRs, and point totals (#) on Form ES-401-3. Limit SRO selections to K/As that are linked to 10 CFR 55.43.

CCNPP LOI-2206 Retake Exam Data I AK3.02 I 3 4 I Q24719 1 B

I 1

Tier l/Group 1-Reactor Operator 19 E/APE # / Name / Safety Function 000067 Plant Fire On-site / 8 000068 (BWlA06) Control Room Evac. / 8 000069 Loss of CTMT Integrity / 5 000007 (CE/EO2) Reactor Trip - Stabilization - Recovery / 1 000008 Pressurizer Vapor Space Accident / 3 2.2.42 3.9 450931 B

1 5:

AK2.02 3.7 450930 M

1 45 AA1.03 2.8 450932 N

2 5;

000009 Small Break LOCA / 3 000074 (W/E06&E07) Inad. Core Cooling / 4 CE/A13 - Natural Circ. / 4 CE/A16 Excess RCS Leakage / 2 000011 Large Break LOCA / 3 000015/17 RCP Malfunctions / 4 Id

~

EA2.06 4.0 440348 B

2 AK2.1 3.0 414420 B

2 1t AK1.2 3.0 440701 B

2 1

?>

000022 Loss of Rx Coolant Makeup / 2 CE/E09 Functional Recovery 000025 Loss of RHR System / 4 000026 Loss of Component Cooling Water / 8 11 EA1.l 4.2 425068 B

2 000029 ATWS / 1 000038 Steam Gen. Tube Rupture / 3 000040 (CE/E05) Steam Line Rupture - Excessive Heat Transfer / 4 000054 (CE/E06) Loss of Main Feedwater / 4 000055 Station Blackout / 6 000056 Loss of Off-site Power / 6 000057 Loss of Vital AC Inst. Bus / 6 000058 Loss of DC Power / 6 000065 Loss of Instrument Air / 8 000077 Generator Voltage & Electric Grid Disturbances / 6 K/A Imp Vision I

Topics

~

EK2.03 3.5 420174 B

3 It EK3.26 4.4 426519 B

1 2 -

AK1.02 3.1 450851 N

2 2f 2.2.44 1 :::

1 425313 1 1

AK2.07 438715 AA1.03 3.2 450992 M

2 58 AK1.01 I 3.9 I 420393 I B

I 2 pp15 2;

~~

2.4.45 I 4.1 I 450950 I N I 3

I 51 EK3.3 1 ::: 1 428472 1 i 1 f

1 1;

EK3.02 440704 AA2.73 3.5 418107 3: -

AA1.06 1 ::: 1 Q50852 1 E 1 1

2:

AA2.01 451132 3 ::

AA2.01 2.9 451150 AK2.06 3.9 450730 N

7 Tier l/Group 2-Reactor Operator C

Y Topics E/APE # / Name / Safety Function 000059 Accidental Liquid RadWaste Rel. / 9 I AA2.02 I 2.9 I 450933 I N I 2

I 53 000061 ARM System Alarms / 7 I

I I

I

I CCNPP LOI-2206 Retake Exam Data Tier 2/Group I - Reactor Operator

CCNPP LOI-2206 Retake Exam Data K/A Topics ll Tier 2 / Group 2 - Reactor Operator ll Imp Vision Cognitive Exam

~

ID Level E/APE # / Name 1 Safety Function A2.07 A4.02 001 Control Rod Drive 4.1 451032 N

3 6t 2.8 451130 B

1 4:

027 Containment Iodine Removal A1.O1 K6.01

~~

~

033 Spent Fuel Pool Cooling 035 Steam Generator 7;

2.7 451050 N

2 3.2 428225 B

2 21 -

041 Steam DumpDurbine Bypass Control K1.06 2.4.6

~

055 Condenser Air Removal 2:: -

2.6 450830 N

1 3.7 424549 B

1

2.

056 Condensate K3.04 K4.02 068 Liquid Radwaste 071 Waste Gas Disposal 2.7 451051 N

2 7:

3.0 434432 B

1 24.;

086 Fire Protection K5.07 I 3.1 I 428429 I B

I 3

I 23 A3.02 I 3.8 I 451033 I N I 1

I 65

CCNPP LOI-2206 Retake Exam Data ll Tier 2 / Group 2 - Sr. Reactor Operator I

Cognitive 1

K/A Imp Vision Topics ID Type Level E/APE # / Name / Safety Function 015 Nuclear Instrumentation A2.04 3.8 451079 N

3 045 Main Turbine Generator A2.17 2.9 425257 B

2 072 Area Radiation Monitoring 2.2.37 4.6 451073 N

2 II Generic Knowledge & Abilities Conduct of Ops Radiation Control Equipment Control Emergency procedures / Plan

CCNPP LOI-2206 Retake Exam Data Parameter Reactor Operator Test Bank Questions (Maximum of 75%)

Modified Questions 43 (57%)

8 (110/o)

Memory New Questions (Minimum of 10 questions - 8 RO, 2 SRO) 1 24 (32~0) 30 (40%)

Comprehension / Analysis (50 - 60% for RO exam) 45 (60%)

Modified Questions Modified Question # I Original Question #

450993 451016 I

450992 Q50990 420397 414583 1

Q51110 451097 I

450770 428787 450364 420383 1

441651 450890 I

Q5065 1 441 134 442268 419256 1

I 450930 424994 1

~

~

Sr. Reactor Operator Test 8 (32%)

3 (12%)

14 (56%)

7 (28%)

18 (72%)

I Q51150 I

420290 I

CCNPP LOI-2206 Retake Exam Data Key to symbols / abbreviations:

Type:

B = Bank Question 0

M = Modified Question N = New Question Cognitive Level:

1 = Fundamental knowledge or simple memory (stpts, definitions, facts) 0 2 = Comprehension (recognition of system interactions) 3 = Analysis / Synthesis / Application (use of info to predict an event or outcome or to solve a problem)

Calvert Cliffs Retake Exam 75-day Sample plan review comments:

1. The package did not describe the process for creating the sample plan. NUREG-1021 ES 401 page 4 states:

When submitting its examination outline to the NRC, the facility licensee shall describe the process that was used to develop the examination outline (in sufficient detail for the NRC to confirm that it meets the systematic and random selection criteria). Examples of adequate documentation include (1) a statement that the facility licensee used the sampling process described in Attachment I; (2) identification of the industry standard or widely-available commercia/ product that was used; or (3) a description or copy of the facility licensees process document.

Response: The licensee provided a document stating that the sample plan was developed with the latest version of the NRC PWR KIA exam Generator Software, NKEG, Version 1.1 developed by Westinghouse Electric Company, LLC.

2. T2G2 system 041 -there is an X under the K2 column but the KA is K3.04?

Response: Corrected. The K2 selection was made in error. The only WAS under K2 for system 041 were related to ICs which is a B&W system, not a CE system. The decision was made to systematically reselect the K5 category, because this category did not have any selections in Tier 2 Group 2. This would maintain the balance on the sample selection for T2G2. It was also verified that there were still 2 - K2s under the systems tier 2 sample plan. The licensee provided a replacement page for the sample plan that showed these changes. The problematic page was replaced.

3. The distribution of stem categories (KI - A4 + G) has no statistical variation that would be expected if the sample plan had been randomly generated. For example, for Tier 1 Group 1, there are 6 possible stem categories (KI, K2, K3, K4, AI, A2, G) and 18 E/APES that are sampled. The sample plan shows a distribution as follows:

K1 K2 K3 K4 AI A2 G

Total 3

3 3

3 3

3 3

18 This total lack of any statistical variation exits in same time, there is no apparent geometric pattern in the stem category selections that could be evidence of a random process. Unless the licensee has developed a highly sophisticated process of rebalancing the distributions, this is prima fascia evidence of cherry picking the WAS.

the other tiedgroup selections. At the Response: The latest version of the sample plan generator that is provided by the PWR Owners Group uses a WA selection methodology that ensures that all WA categories (stem Statements KI-K5, A1-A4 and G) are equally sampled. As a result, the old sample plan patterns of having a greater number of WAS under one category and a fewer number of WAS under other categories is no longer going to occur when the new generator is used. This was verified by looking at other exams that had been generated using this version of the sample plan generator. Two other sample plans (Calvert Cliffs June 2008 and Salem August 2008) showed this same pattern of selections (equal selections of WA categories with no statistical variation).

I i

Calvert Cliffs Retake Exam 75-day Sample plan review comments:

1. The package did not describe the process for creating the sample plan. NUREG-1021 ES 401 page 4 states:

When submitting its examination outline to the NRC, the facility licensee shall describe the process that was used to develop the examination outline (in sufficient detail for the NRC to confirm that it meets the systematic and random selection criteria). Examples of adequate documentation include

( I ) a statement that the facility licensee used the sampling process described in Attachment I; (2) identification of the industry standard or widely-available commercial product that was used; or (3) a description or copy of the facility licensees process document. If Response: The licensee provided a document stating that the sample plan was developed with the latest version of the NRC PWR KIA exam Generator Software, NKEG, Version 1.I developed by Westinghouse Electric Company, LLC.

2. T2G2 system 041 -there is an X under the K2 column but the KA is K3.04?

Response: Corrected. The K2 selection was made in error. The only WAS under K2 for system 041 were related to ICs which is a B&W system, not a CE system. The decision was made to systematically reselect the K5 category, because this category did not have any selections in Tier 2 Group 2. This would maintain the balance on the sample selection for T2G2. It was also verified that there were still 2 - K2s under the systems tier 2 sample plan. The licensee provided a replacement page for the sample plan that showed these changes. The problematic page was replaced.

3. The distribution of stem categories (KI - A4 + G) has no statistical variation that would be expected if the sample plan had been randomly generated. For example, for Tier 1 Group 1, there are 6 possible stem categories (KI, K2, K3, K4, AI, A2, G) and 18 E/APES that are sampled. The sample plan shows a distribution as follows:

K1 K2 K3 K4 AI A2 G

Total 3

3 3

3 3

3 3

18 This total lack of any statistical variation exits in gJ the other tiedgroup selections. At the same time, there is no apparent geometric pattern in the stem category selections that could be evidence of a random process. Unless the licensee has developed a highly sophisticated process of rebalancing the distributions, this is prima fascia evidence of cherry picking the WAS.

Response: The latest version of the sample plan generator that is provided by the PWR Owners Group uses a KIA selection methodology that ensures that all KIA categories (stem Statements KI-K5, A1-A4 and G) are equally sampled. As a result, the old sample plan patterns of having a greater number of WAS under one category and a fewer number of WAS under other categories is no longer going to occur when the new generator is used. This was verified by looking at other exams that had been generated using this version of the sample plan generator. Two other sample plans (Calvert Cliffs June 2008 and Salem August 2008) showed this same pattern of selections (equal selections of WA categories with no statistical variation).

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