ML16036A382

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2015-11-PROPOSED Outline Comments
ML16036A382
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/13/2015
From: Vincent Gaddy
Operations Branch IV
To:
References
Download: ML16036A382 (7)


Text

PROPOSED OUTLINE COMMENTS Rev 2 Facility: Wolf Creek NOC First Exam Date: November 13, 2015 Written Exam Outline (Aug 8, 2015)

Comment Resolution SRO: For original T1/G2, W/E15 Changed rejection methodology and Containment Flooding, KA - 2.1.31, a resampling methodology. Review the new replacement A2 KA was selected. Why rejection list.

1 not select a Generic KA?

Need to review resampling guidance -

see Misc Comments #3.

SRO: For original T2/G2, 033 Spent Changed rejection methodology and Fuel Pool Cooling, KA - 2.4.3, a resampling methodology. Review the new replacement KA in system 035 Steam rejection list.

Generator was selected. Why not reselect a KA from SFP?

2 Need to review resampling guidance -

see Misc Comments #3.

Does Wolf Creek plan to install SFP post-accident instrumentation?

SRO: For original T2/G2, 086 Fire Changed rejection methodology and Protection, KA - A2.04: Does Wolf Creek resampling methodology. Review the new not have an AOP for mitigating a fire or rejection list.

3 damage from a fire? Same concern regarding reselecting a KA from a different system.

SRO: For original T2/G2, 034 Fuel Changed rejection methodology and Handling Equipment, KA - A1.02: The resampling methodology. Review the new justification for replacing the KA is based rejection list.

on Wolf Creek not having an individual 4

Tech Spec for refuel canal water level, but the A1 KA statement isnt limited to Tech Specs. Revise justification or retain original KA.

SRO: The Record of Rejected KAs and Changed rejection methodology and Sample plan K/A rejections document resampling methodology. Review the new says Tier 3 KA G2.1.15 was rejected and rejection list.

5 replaced with G2.1.32. However, Rev 0 of the Written Exam Outline has G2.1.32 as a Tier 3 KA so its unclear what this rejection is for. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Written Exam Outline (Aug 8, 2015)

RO: For original T1/G2, 036 Fuel Changed rejection methodology and Handling Accident, KA - AK1.03: The resampling methodology. Review the new justification document states there are rejection list.

34 categories but not all 34 are WEST so the number of applicable categories is

22. Also, the resampling would not include categories that have already 6

been sampled so the number of categories would be 16. But even so, the resampling should start with same-system, same KA category first.

Need to review resampling guidance -

see Misc Comments #3.

RO: For original KA: 008 Component Changed rejection methodology and Cooling Water, KA - A2.05: If a valve in resampling methodology. Review the new the HX bypass line is air operated and rejection list.

fails closed on loss of air, the lack of low 7 temp alarms seems to be ideal for a question.

Need to review rejection for acceptability.

RO - all remaining 8 rejection Changed rejection methodology and 8 justifications need to be reviewed with resampling methodology. Review the new Chief Examiner for acceptability. rejection list. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Administrative JPM Outline (Aug 8, 2015)

Comment Resolution Identify RO JPMs as A1-A4 and SRO Complete 1

JPMs as A5-A9. Put on form.

(RO/SRO) Put title of JPM on 301-1 form Complete 2

(like the Sim JPMs have) in Topic block.

Ensure LOD for A4 is appropriate for a This discusses dose limits during emergency 3

licensed op applicant. conditions and is LOD appropriate.

KA for A4 is same as Tier 3 KA on RO No overlap one discusses normal the other 4

written exam - ensure no overlap. discusses emergency dose rates.

A1 and A5 (SGTL) descriptions are There is 4 of the 5 SRO admins that are SRO verbatim. A5 should have some only so no change.

5 additional action(s) based on license level for operational validity.

For A6 - is it the intent for the applicant Added step to return to step 9 and continue to determine required actions based on boration.

6 determination? If not, add to JPM as additional action.

For A9 - is this JPM identified as Time The JPM will be changed to a time critical but Critical? If so, ensure steps in JPM with no errors it will be a straight PAR change support examiner documenting start/stop with no built in errors.

7 times. How will applicant obtain the corrected EDCP? Does having to get this affect it being classified a Time Critical JPM? OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Control Room / In-Plant System JPM Outline (Aug 8, 2015)

Comment Resolution Identify simulator JPMs as S1-S8 and Complete the in-plant JPMs as P1-P3. (Note - Any 1

JPMs performed in the Control Room would be designated C.

It is noted that none of these JPMs are N/A 2 Direct from bank and none have been used on Previous two NRC exams.

Instead of the SRO-Is not doing S8 Complete (SBO diesels), have them not do S5 (PRM). In addition to it being a significantly more important system, it 3 increases SRO-Is Alt Paths from 4 to 5 (and it shortens up Thursday afternoon by two hours - and only adds 15 minutes on Saturday since S7/S8 are run concurrently.)

Did all S3-S8 validate at < 15 minutes? Times will vary somewhat but overall they 4 Will have significant effect on schedule if should average out at ~15 minutes.

> 15 mins.

For S4, identify the Safety Function as Complete 5

4S instead of 4.

For P2, identify the Safety Function as Complete 6

4P instead of 4.

N/A Replaced original P1 with a different JPM. It was discovered that the original required a 7 large amount of evaluator interaction which would remove some of the decision making from the student. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Simulator Scenario Outline Comments (Aug 8, 2015)

Scenario 1 Comment Resolution Why is Setup IC for A MDAFW pump Deleted 1

listed as an event?

For CT - Start Train A CCW pump: are Corrected the CCP/SI pumps the most limiting safety significant component on loss of 2

CCW? (i.e., is 30 minutes the most limiting time) Also, need to better define the task to capture success criteria.

For CT - Start NSAFP before bleed and Corrected feed criteria are met: Need to better define the task to capture success 3

criteria. Need to better describe the Justification to capture the critical nature of the task.

The narrative on page 4 doesnt match Corrected per discussion with Chief and the D-1. D-1 Events 1 & 2 arent in revised complete document.

4 narrative, so narrative event numbers arent correct, initial power isnt the same.

Event 6 is the Major Transient - which is Corrected per discussion with Chief and 5 the rod eject. NBO2 fault is Event 7, revised complete document.

TDAFP fails to start is Event 8.

In Target Quantitative Attributes table - Corrected per discussion with Chief and Need to verify #1, 2, 4, and 5. #1, revised complete document.

Malfunctions after EOP entry, is 2, not 3.

  1. 2, Abnormal events, is 3 not 5. #4, 6

Substantive EOPs, is 1 (but E-1, not E-0 and FR=H1), #5, Contingency EOPs is 1 (FR-H1). E-0 is not counted in this table.

(See Append D of NUREG 1021)

Scenario 2 Initial Conditions - establish a power Changed to 1-2%

1 band instead of just 0.7%

For all CTs: Need to better define the Corrected 2

tasks to capture success criteria.

In Target Quantitative Attributes table - Corrected per discussion with Chief and 3

Need to verify all numbers revised complete document. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Swap Events 4 &5 to alternate events Corrected 4

between ATC and BOP Scenario 3 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Swap Events 2 & 3 to alternate events Corrected between ATC and BOP Verify TRM was provided as reference This is provided in the Control Room (SIM)

Scenario 4 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Event 2 - what procedure is used to take Corrected manual control?

Scenario 5 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Event numbers in narrative are mis- Corrected numbered since increase in power is not identified as Event 1 Event 2 - what procedure is used? Added procedure to description Need to discuss breakout of events after Corrected earthquake to separate events from precursors. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Miscellaneous Comments:

1. Starting the schedule at 0700 will be difficult for examiners given travel time to plant.

Lets discuss starting no earlier than 0730. Fixed

2. Its not ideal to conduct Admin JPMs between scenario runs. Lets discuss moving JPMs to afternoon of Tuesday - Friday where we have plenty of time and available examiners. Moved to Tuesday
3. KA resampling guidance: When it is necessary to reselect a randomly selected K/A, the order in which the reselection is done is as follows: corrected
1) the same randomly selected K/A category (K1.01 to K1.04), then
2) within the same system (K1 to K5), then
3) within the same Tier and Group (T2/G2: 201002 RMCS to 201005 RCIS) such that the new system is within the intent of the randomly selected K/A (performs the same function)
4) within the same Tier and Group (T2/G2: 201004 RSCS to 204000 RWCU) such that the new system is randomly selected from those systems not yet selected Note: Under no circumstances is it allowed to reselect across Tiers and Groups, even if the same Safety Function is maintained. It is not within NUREG 1021 guidance to reselect from the Safety Function. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Facility: Wolf Creek NOC First Exam Date: November 13, 2015 Written Exam Outline (Aug 8, 2015)

Comment Resolution SRO: For original T1/G2, W/E15 Changed rejection methodology and Containment Flooding, KA - 2.1.31, a resampling methodology. Review the new replacement A2 KA was selected. Why rejection list.

1 not select a Generic KA?

Need to review resampling guidance -

see Misc Comments #3.

SRO: For original T2/G2, 033 Spent Changed rejection methodology and Fuel Pool Cooling, KA - 2.4.3, a resampling methodology. Review the new replacement KA in system 035 Steam rejection list.

Generator was selected. Why not reselect a KA from SFP?

2 Need to review resampling guidance -

see Misc Comments #3.

Does Wolf Creek plan to install SFP post-accident instrumentation?

SRO: For original T2/G2, 086 Fire Changed rejection methodology and Protection, KA - A2.04: Does Wolf Creek resampling methodology. Review the new not have an AOP for mitigating a fire or rejection list.

3 damage from a fire? Same concern regarding reselecting a KA from a different system.

SRO: For original T2/G2, 034 Fuel Changed rejection methodology and Handling Equipment, KA - A1.02: The resampling methodology. Review the new justification for replacing the KA is based rejection list.

on Wolf Creek not having an individual 4

Tech Spec for refuel canal water level, but the A1 KA statement isnt limited to Tech Specs. Revise justification or retain original KA.

SRO: The Record of Rejected KAs and Changed rejection methodology and Sample plan K/A rejections document resampling methodology. Review the new says Tier 3 KA G2.1.15 was rejected and rejection list.

5 replaced with G2.1.32. However, Rev 0 of the Written Exam Outline has G2.1.32 as a Tier 3 KA so its unclear what this rejection is for. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Written Exam Outline (Aug 8, 2015)

RO: For original T1/G2, 036 Fuel Changed rejection methodology and Handling Accident, KA - AK1.03: The resampling methodology. Review the new justification document states there are rejection list.

34 categories but not all 34 are WEST so the number of applicable categories is

22. Also, the resampling would not include categories that have already 6

been sampled so the number of categories would be 16. But even so, the resampling should start with same-system, same KA category first.

Need to review resampling guidance -

see Misc Comments #3.

RO: For original KA: 008 Component Changed rejection methodology and Cooling Water, KA - A2.05: If a valve in resampling methodology. Review the new the HX bypass line is air operated and rejection list.

fails closed on loss of air, the lack of low 7 temp alarms seems to be ideal for a question.

Need to review rejection for acceptability.

RO - all remaining 8 rejection Changed rejection methodology and 8 justifications need to be reviewed with resampling methodology. Review the new Chief Examiner for acceptability. rejection list. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Administrative JPM Outline (Aug 8, 2015)

Comment Resolution Identify RO JPMs as A1-A4 and SRO Complete 1

JPMs as A5-A9. Put on form.

(RO/SRO) Put title of JPM on 301-1 form Complete 2

(like the Sim JPMs have) in Topic block.

Ensure LOD for A4 is appropriate for a This discusses dose limits during emergency 3

licensed op applicant. conditions and is LOD appropriate.

KA for A4 is same as Tier 3 KA on RO No overlap one discusses normal the other 4

written exam - ensure no overlap. discusses emergency dose rates.

A1 and A5 (SGTL) descriptions are There is 4 of the 5 SRO admins that are SRO verbatim. A5 should have some only so no change.

5 additional action(s) based on license level for operational validity.

For A6 - is it the intent for the applicant Added step to return to step 9 and continue to determine required actions based on boration.

6 determination? If not, add to JPM as additional action.

For A9 - is this JPM identified as Time The JPM will be changed to a time critical but Critical? If so, ensure steps in JPM with no errors it will be a straight PAR change support examiner documenting start/stop with no built in errors.

7 times. How will applicant obtain the corrected EDCP? Does having to get this affect it being classified a Time Critical JPM? OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Control Room / In-Plant System JPM Outline (Aug 8, 2015)

Comment Resolution Identify simulator JPMs as S1-S8 and Complete the in-plant JPMs as P1-P3. (Note - Any 1

JPMs performed in the Control Room would be designated C.

It is noted that none of these JPMs are N/A 2 Direct from bank and none have been used on Previous two NRC exams.

Instead of the SRO-Is not doing S8 Complete (SBO diesels), have them not do S5 (PRM). In addition to it being a significantly more important system, it 3 increases SRO-Is Alt Paths from 4 to 5 (and it shortens up Thursday afternoon by two hours - and only adds 15 minutes on Saturday since S7/S8 are run concurrently.)

Did all S3-S8 validate at < 15 minutes? Times will vary somewhat but overall they 4 Will have significant effect on schedule if should average out at ~15 minutes.

> 15 mins.

For S4, identify the Safety Function as Complete 5

4S instead of 4.

For P2, identify the Safety Function as Complete 6

4P instead of 4.

N/A Replaced original P1 with a different JPM. It was discovered that the original required a 7 large amount of evaluator interaction which would remove some of the decision making from the student. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Simulator Scenario Outline Comments (Aug 8, 2015)

Scenario 1 Comment Resolution Why is Setup IC for A MDAFW pump Deleted 1

listed as an event?

For CT - Start Train A CCW pump: are Corrected the CCP/SI pumps the most limiting safety significant component on loss of 2

CCW? (i.e., is 30 minutes the most limiting time) Also, need to better define the task to capture success criteria.

For CT - Start NSAFP before bleed and Corrected feed criteria are met: Need to better define the task to capture success 3

criteria. Need to better describe the Justification to capture the critical nature of the task.

The narrative on page 4 doesnt match Corrected per discussion with Chief and the D-1. D-1 Events 1 & 2 arent in revised complete document.

4 narrative, so narrative event numbers arent correct, initial power isnt the same.

Event 6 is the Major Transient - which is Corrected per discussion with Chief and 5 the rod eject. NBO2 fault is Event 7, revised complete document.

TDAFP fails to start is Event 8.

In Target Quantitative Attributes table - Corrected per discussion with Chief and Need to verify #1, 2, 4, and 5. #1, revised complete document.

Malfunctions after EOP entry, is 2, not 3.

  1. 2, Abnormal events, is 3 not 5. #4, 6

Substantive EOPs, is 1 (but E-1, not E-0 and FR=H1), #5, Contingency EOPs is 1 (FR-H1). E-0 is not counted in this table.

(See Append D of NUREG 1021)

Scenario 2 Initial Conditions - establish a power Changed to 1-2%

1 band instead of just 0.7%

For all CTs: Need to better define the Corrected 2

tasks to capture success criteria.

In Target Quantitative Attributes table - Corrected per discussion with Chief and 3

Need to verify all numbers revised complete document. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Swap Events 4 &5 to alternate events Corrected 4

between ATC and BOP Scenario 3 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Swap Events 2 & 3 to alternate events Corrected between ATC and BOP Verify TRM was provided as reference This is provided in the Control Room (SIM)

Scenario 4 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Event 2 - what procedure is used to take Corrected manual control?

Scenario 5 For all CTs: Need to better define the Corrected per discussion with Chief and tasks to capture success criteria. revised complete document.

In Target Quantitative Attributes table - Corrected Need to verify all numbers Event numbers in narrative are mis- Corrected numbered since increase in power is not identified as Event 1 Event 2 - what procedure is used? Added procedure to description Need to discuss breakout of events after Corrected earthquake to separate events from precursors. OBDI 202 - IOLE Process Rev 1

PROPOSED OUTLINE COMMENTS Rev 2 Miscellaneous Comments:

1. Starting the schedule at 0700 will be difficult for examiners given travel time to plant.

Lets discuss starting no earlier than 0730. Fixed

2. Its not ideal to conduct Admin JPMs between scenario runs. Lets discuss moving JPMs to afternoon of Tuesday - Friday where we have plenty of time and available examiners. Moved to Tuesday
3. KA resampling guidance: When it is necessary to reselect a randomly selected K/A, the order in which the reselection is done is as follows: corrected
1) the same randomly selected K/A category (K1.01 to K1.04), then
2) within the same system (K1 to K5), then
3) within the same Tier and Group (T2/G2: 201002 RMCS to 201005 RCIS) such that the new system is within the intent of the randomly selected K/A (performs the same function)
4) within the same Tier and Group (T2/G2: 201004 RSCS to 204000 RWCU) such that the new system is randomly selected from those systems not yet selected Note: Under no circumstances is it allowed to reselect across Tiers and Groups, even if the same Safety Function is maintained. It is not within NUREG 1021 guidance to reselect from the Safety Function. OBDI 202 - IOLE Process Rev 1