ML14247A194

2014 Byron Nuclear Station Initial License Examination Operating Test Comments

ML14247A194
Person / Time
Site:	Byron
Issue date:	06/13/2014
From:	Walton R NRC/RGN-III/DRS/OLB
To:
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Download: ML14247A194 (10)

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response RO Operating Test JPM RO A1 1. Procedure and REMA form will be provided to Will ask what references are required.

Calculate a applicant when asked since applicant may ask Reactivity Change for Curve Book instead!

2. Step 4 - Initiating cue specifies UNIT 1, but Changed JPM Standard for Step 4 from Unit 2 to Unit Standard Specifies UNIT 2. 1 JPM RO A2 1. Need to identify a Task Standard for JPM. Task Standard added.

Identify Leak 2. What is the basis for rejecting alternate isolation Procedure has applicant tag closest isolation points.

Isolation Points points (e.g., 1CS018A and 1CS021A)?

from M&E prints 3. Revise Initiating Cue to eliminate SM Cue in Cue to either be eliminated or not provided by step 4. examiner.

JPM RO A3 1. Explain how this task relates to K/A 2.3.13 K/A is applicable for high radiation in WGDT.

Respond to GDT 2. How does a high activity level in a Gas Decay Task is applicable to RO duties.

High Activity Tank impact performance of Licensed Duties of the RO?

3. What is the knowledge/ability being tested? Following procedure, and performing calculations.

4. There are no verifiable actions for critical steps Procedure adherence is being exercised.

4 and 5.

5. Identify Task Standard Task standard to be added.

JPM RO A4 1. Replace JPM; Neither the selected K/A nor Task This JPM implements Emergency Plan for a fire.

Respond to Turbine is related to the Emergency Plan or its Bldg Fire Alarm Implementing Procedures (ES 301 D.3.a; page 11 of 27)

2. Explain how task relates to K/A 2.4.25 Will change K/A to 2.4.27.

3. Appears related to K/A 2.4.27

4. Note before step 4 states that Steps 4, 5, and 6 Examiners expect the applicants to follow sequence may be performed in any order but BAP1100-10 provided in BAP 1100-10.

specifies order.

5. Cue in Step 7 needs more specifics or preferably Agreed, but detail needed may not be available this an intermediate step requiring RO to request early in the event.

additional information (from BAP 1100-10:

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response Obtain as much specific information on the injuries and fire condition as possible to provide the offsite assistance when contacting them.

6. Critical Step #9 is an error likely situation if Agreed. May have to prompt applicant what applicant does not refer back to BAR after equipment is affected.

entering BAP 1100-10.

7. Identify Task Standard. Task standard to be added.

JPM SRO A1 1. On page 5 of 8 step 1 CUE, there is no data This JPM was too complicated to administer as is.

Review of Offsite package labeled W on bottom left of cover This JPM was modified for the applicant to review Power Availability sheet. 1BOSR 8.1.1-1 and identify that an acceptance criteria Surv. 2. On page 5 of 8, step 2 shouldnt the standard be was not met.

checking busses 6 and 13 energized??? The standard says busses 7 and 13.

3. On page 6 of 8, step 8 the standard says Determine acceptance criteria NOT met at step G shouldnt this be step 10.

JPM SRO A2 1. Need to explain why NSO 4 is qualified Per OP-AA-105-101, must complete an annual Evaluate License because the annual operating test requirement operating test by the end of the Calendar Year!

Holder Status doesnt look like it is met. ANNUAL is defined OP-AA-105-101 and NSO 4 doesnt met the annual operating test requirement. The date need to be changed from April 4 to May 4 if you want him to be eligible.

JPM SRO A3 1. Identify the Task Standard Task Standard to be identified.

Initiate a LCOAR 2. Should be listed in ES 301-1 as (M)odified; This LCOAR is different than the Admin JPM Same JPM used in 2012 but this one modified administered in 2012.

by changing SSC with different applicable TS LCO JPM SRO A4 1. Is this JPM going to be done in simulator or This JPM was modified to be performed in the Accessing CNMT classroom??? Would probably be better in simulator. Placard will be missing and must be at Power simulator. Can he find the placards and can he located. Must locate MIDS tag out.

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response hang the tags on the MIDs.

2. Identify a Task Standard. Task Standard to be identified.

3. JPM is NOT time critical. Containment Entry Agreed. Must complete in <2 hours.

Checklist provided to the applicant must be filled out up to the WEC Supervisor Section

4. Who is responsible for filling out Work Group Ops is responsible for this job. Upper section of BAP Lead section and should portions of the section 1450 T-2 sheet will be completed by RP prior to being be filled out prior to WEC approval? presented to SRO for review.

5. Step 5, Once applicant identifies need for 1BOL Agreed.

PC-1, provide completed package, rather than giving a verbal cue.(combine steps 5 and 6)

JPM SRO A5 1. Identify Task Standard Task Standard to be identified.

Classify and 2. Place initiating cue after the Plant Conditions Agreed.

Complete a NARS 3. There are two time critical actions here Agreed.

Form

• Classify within 15 minutes of acknowledging Cue

• Notify; Start time begins upon completion The applicant will be allowed 12 minutes to complete of Classification and ends 12-13 minutes the NARS form.

later (TBD such that there is time remaining to make call)

4. Preferably completed in MCR or Simulator Location to be determined by schedule.

5. Change cue to say and fill out NARS form if it is No, they must be cued to perform this action since required. We dont want to tell them to fill it out completion of the form is critical to the JPM.

because then we tell them that a classification is to be made. Let them determine that.

JPM Sim01 1. Identify Task Standard Task standard to be identified.

Letdown Orifice 2. What is the intent of Note 1 in Step 1? If applicant brings in the alarms in the NOTE, the Operation Procedure is a Continuous Use procedure so applicant will get a comment. Standard is to operate procedure must be obtained and referred to prior the system without bringing in these alarms!

to performing the assigned task.

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response

3. Step 3 is identified as critical. It appears that Yes, controller to MANUAL is Critical.

only placing the controller in MANUAL should be the critical element since controller is to be adjusted in Step 5.

4. Initiating Cue does not specify which orifice to Yes, to get from 75 gpm to 120 gpm letdown flow, place in service but Step 5 standard specifies applicant must manipulate A orifice. The other A. Is "A the only available choice? orifice is incorrect.

5. Shouldnt the Standard for Step 5 specify a This is finesse of the operator. Operator should not maximum flow rate (reference Limitation E.1 of bring in any alarms in NOTE 1!

BOP CV-9) as well as minimum and maximum pressures?

6. Initiating Cue is to place system in AUTO, Yes, but it may take a while for the system to settle.

therefore Step 8 should also be critical. May not complete the last step.

7. This JPM may duplicate scenario. Both the JPM and a scenario event operate the Letdown system, but both events are different!

JPM Sim02 1. Identify Task Standard Task Standard to be identified.

Raise SI Acc 2. Move 1st Initiating Cue to the Third initial Agreed.

Pressure condition

3. Delete Initiating Cue #3. Verbal Cue is already May keep Cue #3 as is since Cue #3 is more than just provided in Step 1 the valve operated in the JPM.

4. Is Cue in Step 3 necessary? If control is located Delete Cue in Step 3.

on 1PM06J, then operator should be able to actually perform/verify.

5. Step 8

• Does 1SI8880 need to be closed before If operator exceeds 647 psig, then initial cue not met, exceeding 647 psig to be considered SAT? ..restore SI Accumulator pressure to within TS Need a contingency if 1SI8880 is not closed limits.

before accumulator pressure increases above limit (647 psig) (e.g., decreases pressure IAW applicable procedure).

• Would shutting 0NT078 instead of 1SI8880 be Yes, but it does not clear the TS condition!

a successful alternate path? Why or Why Not?

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response

6. Shouldnt determination of whether or not to Either way, examiner should ask this of examinee to Exit 1BOL-5.1 be evaluated as a step or sub- determine knowledge of Tech Specs.

step?

7. At step 8 of the JPM why isnt closing 0NT078 Either valve is acceptable. The intent is the student also a correct action for completing the critical must recognize that pressure rise to accumulator must step??? Add Close either 1SI8880 or 0NT078 be halted.

to stop pressure increase JPM Sim03 1. Identify Task Standard Task Standard to be identified.

Synchronize DG to 2. What is the trigger for the Governor Adjust ESF Bus Switch failure?

3. Is it appropriate to leave the engine running Can operate in this condition for several hours unloaded? provided cooling water pump is running.

4. What if the applicant trips the engine per Not wrong, may ask applicant why this action was Precaution D.2? taken!

5. At step 3 with Auto Re-close Circuit Arm Selector Switch NOT in SURV TEST will EDG be OPERABLE??? If it is INOP during surv if NOT in SURV TEST this should be a critical step. Bkr may not auto reclose when it needs to.

(Technical Question)

JPM Sim04 1. Identify the Task Standard Task Standard will be generated.

Turbine Driven 2. Move Initiating Cue #2 to Initial Conditions Optional.

FWP Swap 3. Step 2 should include action to verify that This will take a long time to occur and might not Turning Gear Disengages and De-energizes. happen before JPM is ended.

4. Step 7 standard should include verification that Redundant to Trip. May ask applicant follow up Turbine is tripped (e.g., HP and LP stop valves question as to what a tripped turbine looks like.

closed and speed decreasing.

5. A better alternate path might be to fail the local Optional, but not incorporated.

and remote trip push-buttons (require closure of HP and LP stop valves, reduce speed manually, and/or isolate steam supply).

6. Initial condition 4 pumps should be pump Will make pump singular.

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response

7. Step 6 why is the U-2 assist NSO reporting Cue provided if applicant asks for information from 1PM12J vibration readings??? This should only U2 Assist NSO.

be giving if the applicant asks the U-2 assist NSO to look at them. The AR should give alarm setpoint and where to look at vibration readings.

The same can be said for the EO report, it should An open bullet for contacting the EO is optional. A only be given if asked for following the hi cue is provided in case applicant does this action.

vibration alarm.

JPM Sim05 1. This JPM is not a PRIMARY system JPM as This JPM was replaced.

Transfer from FW indicated by safety function of 301-2 Bypass to FW Reg 2. Cue needs to be better or JPM needs to allow Valve any feed reg to be manipulated. I recommend change cue to specify swap 1FW510 and then 1FW520.

JPM Sim06 1. Identify Task Standard Task Standard to be added.

SX Flooding 2. Simulator Setup needs to include verification Noted.

Requiring RCFC that SX Train A and associated RCFCs are in Isolation service

3. Move Initiating Cue #1 to Initial Conditions Optional.

4. Are applicants expected to complete pump/train Applicants would be expected to obtain a procedure to swaps without reference to any other system perform this function.

operating procedures?

5. Is the applicant expected to restart the Train B Per the procedure, the applicant would be expected to RCFCs? return the non-leaking previously isolated train to service.

6. We shouldnt be overriding CNMT chiller Extraneous alarms are overridden so as not to distract alarms the operator should expect them and not the applicant (and the other applicants being tested) in be distracted by them. the simulator.

JPM Sim07 1. Identify Task Standard Task Standard to be added.

Containment 2. Recommend changing alarm spike to an OP Changed fault to high radiation condition.

Release Failure or Upscale Failure rather than spike. (Continuously in)

This will eliminate confusion with whether spike 6 of 10

NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response is a valid alarm or if alarm is present when applicant checks indication.

3. At step 7 I dont think the Unit Sup should direct The alarm is very quiet. If needed, the examiner the applicant to the RM-11 alarm. The applicant should prompt the applicant that the radiation alarm is is expected to respond to one of his panels its your alarm.

his responsibility.

4. A good follow-up question would be which Applicants will get enough challenges in Tech Specs LCOs are you as a result of this failure??? between admin JPMs and scenarios.

JPM Sim08 1. Identify Task Standard Task standard to be added.

Start H2 2. Given the limited number of manipulations and Agreed.

Monitoring the time compression cue, the estimated System completion time seems excessive.

JPM INP01 1. This JPM should entail obtaining keys and Doors are unlocked! Pictures will be removed, have Local Reset of FW entering panels 1/2PA27J & 1/2PA28J. There is applicant open the cabinet.

Isolation Signal really no need for these pictures the applicants can get the keys open the door and point to the fuses.

2. Identify a Task Standard. Task Standard to be added.

JPM INP02 1. Step 4 how are the lock out relays checked for Lock out relays checked locally on breakers in Local Loading of this step. Need to describe how this will be switchgear room.

DG performed. At bus 141 or by checking MCR alarms??? This shouldnt be a cue.

2. Step 13 how are these fuses checked without Will either provide applicant pictures of inside of opening a Bkr cabinet door??? cabinet or open breaker cabinet door on spare breaker.

3. Can we do this JPM on a spare Bkr in the Good idea, except breaker in training building wont training bldg.??? work with this JPM. Its defective!

4. Why is this alternate path? Initial conditions Breaker wont operate locally manually. Must prime already establish that there was a problem with springs to allow for local operation.

auto closure of the breaker.

5. Identify Task Standard Task Standard to be identified.

6. For step 4, what are the indications that the Tripped relays have a red flag revealed. Non-tripped 7 of 10

NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response relays are not tripped. relays are black.

7. For this task it appears that the engine may be True, a bit of artificiality exists to run this JPM!

running without a cooling water supply. If this is the case, then the task should be considered time critical, or the initial conditions modified such that the engine is not running and the associated steps to restart incorporated.

8. Step 9 should be critical; ensures that DG Presently evaluated as non-critical as there is no Output breaker will be closed on a dead bus. power on the bus during a black out.

JPM INP03 1. Need a copy of the procedure to provide the Agreed. Two procedures will be provided. One for Local Operation of applicant. Unit 1 and one for Unit 2. Examiner decides where to PZR PORV Block run JPM.

Valve 2. Step 1 should not contain a cue to breaker Agreed. Locations provided for examiner, not locations. The applicants need to know where to applicant!

find this equipment.

3. What electrical safety equipment is required to Agreed.

remove fuses 46 & 47??? It needs to be listed here for the examiner.

4. Identify a Task Standard. A Task Standard will be identified.

5. Move Initiating Cues 1 and 2 to Initial Agreed.

Conditions

6. Step 1 -- Remove reference to contacting Open bullet is optional. Examiners will not cue WEC/MCR. applicant as to where the electrical cabinet is.

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response Scenarios Scenario 1 a) Event 5 the first action the RO should take prior to placing RODS to MANUAL is verify the turbine is not ramping excessively / running back! Add to RO actions.

Scenario 2 a) Why do we have the failure of the feedwater isolation signal in d) See attachment B, Step 11. Needs better this scenario??? More challenging to operator if feedwater identification!

isolation signal occurs automatically at time of Rx Trip. Not taken credit as a bean.

b) Following the 1A CV pump trip, letdown has to be restored.

Letdown is manipulated in one of the JPMs.

c) Event 3 is very similar to a JPM as well. In plant vs CR actions!

d) Why arent the actions to manually isolate feedwater spelled out better in the body of the scenario??? If the operator needs to take an action in accordance with an EOP it should be identified for the examiner.

Scenario 3 a) Event 5 is the same event as scenario 1 event 6. There may be a) Need to evaluate differences between different outcomes but this is preconditioning the operators to these two events.\

be able to respond better the second time. b) May be a good followup question after b) Event 3 why isnt there an action for the crew to initiate a filter scenario. Have them add this step!

change/replacement??? I would not expect a crew to move on c) Dependent upon ramp rate.

without getting the seal injection filter replaced in short order, that is on their shift or the next. I would bag the next shift unless it was the very end of the shift.

c) Event 7 why isnt there a step to dispatch NLOs to look for the source of condenser air inleakage??? I would expect this to be a normal expected response for the operators.

Scenario 4 a) I like this scenario. Is it going to be the spare??? You should use it.

b) No substantive comments.

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NRC Exam Submittal Comments for Fermi 2013 Initial Exam Examiner Comment Facility Action/Response 10 of 10