ML112901411

2011-06-Draft Outline Comments

ML112901411
Person / Time
Site:	Comanche Peak
Issue date:	06/06/2011
From:	NRC Region 4
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References
50-445/11-06
Download: ML112901411 (5)

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Attachment 6 OBDI 202 - ILE Process DRAFT OUTLINE COMMENTS Facility:

CPNPP First Exam Date:

6/6/2011 Written Exam Outline (4/4/2011)

Comment Resolution 1 Tier 2/Group 2 (Pages 11 and 12) are labeled as Record of Rejected K/As Happened during conversion to Adobe document will provide updated copy.

2 SRO/RO Exam: Tier 1/Group 2 - 25 applicable topics and used a 24 sided dice. How would topic 25 ever be selected?

Incorrectly listed 24 sided vice 30 sided dice.

Corrected in Written Outline Development Rev. 1. See Question #61 as it is Topic #25.

3 RO Exam: Tier 3/Category 4: used numbers 1-41 when there are 43 Cat 4 K/As?

50 total in Category 4 with 7 deleted or moved + 2.4.38 & 2.4.44 are both < 2.5 for RO as they are SRO specific = 41 topics 4

Pages 8 of 9 and 9 of 9 - explain how number of topics was obtained for RO and SRO (T3/Cat 1)

Category 1 has 45 topics with 7 deleted or moved + 2.1.35 is < 2.5 for RO = 37 topics.

For the SRO exam there are 38 topics with one caveat, Note 9 of Form ES-401-2 requires that they be linked to 10 CFR 55.43 so the 100 sided dice is used and if the K/A does NOT meet 55.43, then re-roll.

Corrected numbering in Written Outline Development Rev. 1.

5 Have all K/As with IR less than 2.5 been reviewed to determine none have a IR equal to or greater than 2.5 at CPNPP?

It has been done but was not documented. A new exam group has formed and we will be documenting this activity through the use of VISION software.

6 Does 100 sided dice have a raised lip that would impact random process?

No. The inner 1/2s are separated but the outer 1/2 is smooth. OEAAT will provide for your examination.

7 SRO Exam: Tier 3/Category 1: why use 1-39 (vice 1-38)?

Corrected numbering in Written Outline Development Rev. 1.

8 Record of Rejected K/As:

a. RO: T2/G1 - 063 K4.01. What is avoid ES-401-6 sampling criteria issue?

Selection of this K/A could potentially have impacted Item #4 of Form ES-401-6 since there is only one method employed at CPNPP and it was used on a previous exam.

KA used in previous two exams.

b. RO: T1/G1 - 015 G2.2.3. Does Operations agree no procedural or operational diffs between units?

SRO confirmed no operational or procedural differences for RCPs.

c. RO: 7 reselects for skyscraper balance - explain.

Used to balance selection of questions to meet NUREG-1021 skyscraper requirements of 2 Questions per Tier.

Examples are as follows:

Q#6 - Rev. a of the Outline only had 1 good

OBDI 202 - ILE Process A1 K/A (Q #26 was also initially selected as A1.02 but the K/A was not CPNPP specific and A1.01 was < 2.5), therefore Q#26 was reselected to K2.08 (K2 only had 1 selection in Rev. a) and Q#6 was reselected to A1 for skyscraper balance. Q#33 was then reselected to A1 to meet the minimum requirement Q#27 was originally a K4 which already had 6 selections so it was shifted to a Generic. Q#53 was changed from AA1 to AA2 in response to Q#52 changing from AA2 to AA1. Q#34 was changed because K6 only had 1 question at the final K/A count. Q#40 was changed since it was covered by Q#63 and Generic K/A 2.1.27 was previously eliminated at Q#54.

Administrative JPM Outline (4/4/2011)

Comment Resolution 1 Add RA1-RA4 and SA1-SA5 to Admin Topics Outline forms.

Add under category title.

2 Provide copy of original JPM for all those identified as Modified with the DRAFT exam submittal.

Will be in exam submittal.

3 RA2 - Task Summary states from the Remote Shutdown Panel Is this correct?

This is when those curves are used.

Applicants dont have to be at the Remote Shutdown Panel to perform this task.

4 RA4 - add additional task to make more discriminatory (like impact of EAD alarm setpoint).

Will add second section to address administrative requirements.

5 SA1, SA3 and SA4 - Are these intended to be perform or review? What is operationally valid at CPNPP?

We intend for the SRO applicants to perform the tasks because they need to be able perform the tasks to adequately review them later. Also at first error the item being reviewed would be returned to performer.

Control Room / In-Plant System JPM Outline (4/4/2011)

Comment Resolution 1

Provide copy of original JPM for all those identified as Modified with the DRAFT exam submittal.

Will be in exam submittal.

OBDI 202 - ILE Process 2 S-3: How does this qualify as an Engineered Safety Feature (EN)?

Not EN will remove (EN) from outline. High PRA significance but not EN.

3 4.0 submittal puts KA and IR on the form (like the Admins form).

Will add to summary narrative section of ES-301-2.

Simulator Scenario Outline Comments (4/4/2011)

Comment Resolution 1 Helpful to add Target Quantitative Attributes table at bottom of all D-1s.

Will add to bottom of D-1.

2 All CTs must be objectively defined such that a pass/fail grade can be assigned.

Add by when each CT must be accomplished to get credit.

Will revise D-1 to include termination criteria for CTs.

3 Scenario 1:

a. ESD outside containment run on last 2 NRC exams. Replace transient or make it ESD inside containment.

2009 Scenario 1 - SGTR Scenario 2 - Loss of All AC 2010 Scenario 1 - Loss of Heat Sink Scenario 2 - SGTR Scenario 3 - SBLOCA Spare - ESD 2010 Retest Scenario 1 - LBLOCA Scenario 2 - ESD ORC but unisolable ESD is only common event in scenario to LC18 retest scenario 2.

b. Only 3 events prior to Major - add another one.

Event 2 is very time consuming and adding another event could extend scenario length.

Recommend making decision following on-site validation.

c. Events 5 and 6 appear to be the same thing (Event 6 is operator response to Event 5)

RO will try to manually actuate SI but switch is failed.

BOP will manually actuate SI from CB-02.

d. Events 7-9 are good, however no malfunction credit would be given (see Appendix D)

Actions taken in events 7 & 8 are considered to provide insight into competence. Event 9 will be deleted.

Frequently, important evaluative benefit is gained in terms of safety significance by having key components or instruments fail after entering the EOPs. This process compels the operators to respond immediately to a safety-related situation by taking alternative actions to mitigate the event. This process also allows for a better evaluation of the operators overall knowledge of plant procedures and systems because the event must be incorporated into the mitigation strategy for the remainder of the scenario. Conversely, instrument and component failures that are initiated after the major transient sometimes require little action and may provide little insight into the operators competence. (NUREG-1021, pg 417)

OBDI 202 - ILE Process

e. Event 9: Scenario Summary states failing to start Containment Spray Pump complicates scenario - how so if ESD is outside containment?

Will delete Event 9 as it is not needed.

4 Scenario 2:

a. Scenario summary states no scheduled activities but Event 1 is a Normal evolution. Will it not be included in turnover?

Deleted with no scheduled activities from the Scenario guide. Will be included in turnover.

b. Scenario summary states first event if failure of VCT level transmitter. This is Event 2. Also, does the transmitter fail HI or LOW?

Changed to read The next event is a low failure...

c. Event 4 - With trip of CCP, does the B/U pump fail to auto start?

No auto start associated with CCP.

d. Event 5 - list the Rapid Downpower on the D-1 in addition to the SGTL since it is actually what is giving the event credit.

Added to ES-D-1.

e. Event 7 - What is the trip signal that does not work? This is an ATWT event?

Scenario summary states an uncontrolled loss of PZR level will require a manual Reactor trip Is this complete?

Not an ATWT only classified as an ATWT if the reactor cannot be tripped from the Control Room.

PZR level and pressure decreases uncontrollably due to the SGTR will be added to D-1 summary.

f. Termination of scenario is RCS cooldown initiated, not completed.

Changed completed to initiated.

5 Scenario 3:

a. Does 3 to 8% power require a Mode change? If so, how will this be handled during the scenario?

Yes but all MODE 1 requirements have been met and signed off on the Integrated Plant Operations procedure in use. This is covered in the turnover sheet.

b. Are Events 5 and 6 the same? (Event 6 is a non-successful operator action that is a direct result of Event 5).

Below 48% there is no automatic reactor trip from RCP trip. Will add ABN-101 to summary General Outline Comments (4/4/2011) 1 What plant-specific priorities (including PRA and IPE insights) are covered in the appropriate exam sections?

S-3, S-4, S-6, P-1, & P-3.

Scenario #1, Events 2, 4, 7 Scenario #2, Events 6 Scenario #3, Events 6, 7 Include PRA document referenced during exam development.

2 Any recent OE included (plant specific or other)?

Loss of Protection Bus (Scenario 1) - CPNPP CCP trip (Scenario 2) - STP ATWT (Scenario 3) - Salem

OBDI 202 - ILE Process SGTR (Scenario 2) - Palo Verde & others Non-SFGD bus transfer (S7) - CPNPP Steam Dump Ops (S5) - CPNPP issue from Requal program Written exam:

Q2 demin saturation - CPNPP and others Q8 blackout - CPNPP and others Q10 LTOP actuation - CPNPP Q20 DG operability - CPNPP and others Q24 DG synchronization - CPNPP and others Q25 Rad Mon actuation block - CPNPP Q34 CET operability - CPNPP Q46 ATWT - Salem and others Q56 Grid Instability - NE Blackout Q65 Emergency exposure - Fukushima Q69 Tagging - CPNPP and others Q90 Loss of protection bus - CPNPP and others Q98 CNTMT PAL - CPNPP