ML16036A382
| ML16036A382 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| Issue date: | 11/13/2015 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | |
| References | |
| Download: ML16036A382 (7) | |
Text
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Facility:
Wolf Creek NOC First Exam Date:
November 13, 2015 Written Exam Outline (Aug 8, 2015)
Comment Resolution 1
SRO: For original T1/G2, W/E15 Containment Flooding, KA - 2.1.31, a replacement A2 KA was selected. Why not select a Generic KA?
Need to review resampling guidance -
see Misc Comments #3.
Changed rejection methodology and resampling methodology. Review the new rejection list.
2 SRO: For original T2/G2, 033 Spent Fuel Pool Cooling, KA - 2.4.3, a replacement KA in system 035 Steam Generator was selected. Why not reselect a KA from SFP?
Need to review resampling guidance -
see Misc Comments #3.
Does Wolf Creek plan to install SFP post-accident instrumentation?
Changed rejection methodology and resampling methodology. Review the new rejection list.
3 SRO: For original T2/G2, 086 Fire Protection, KA - A2.04: Does Wolf Creek not have an AOP for mitigating a fire or damage from a fire? Same concern regarding reselecting a KA from a different system.
Changed rejection methodology and resampling methodology. Review the new rejection list.
4 SRO: For original T2/G2, 034 Fuel Handling Equipment, KA - A1.02: The justification for replacing the KA is based on Wolf Creek not having an individual Tech Spec for refuel canal water level, but the A1 KA statement isnt limited to Tech Specs. Revise justification or retain original KA.
Changed rejection methodology and resampling methodology. Review the new rejection list.
5 SRO: The Record of Rejected KAs and Sample plan K/A rejections document says Tier 3 KA G2.1.15 was rejected and 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.
Changed rejection methodology and resampling methodology. Review the new rejection list.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Written Exam Outline (Aug 8, 2015) 6 RO: For original T1/G2, 036 Fuel Handling Accident, KA - AK1.03: The justification document states there are 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 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.
Changed rejection methodology and resampling methodology. Review the new rejection list.
7 RO: For original KA: 008 Component Cooling Water, KA - A2.05: If a valve in the HX bypass line is air operated and fails closed on loss of air, the lack of low temp alarms seems to be ideal for a question.
Need to review rejection for acceptability.
Changed rejection methodology and resampling methodology. Review the new rejection list.
8 RO - all remaining 8 rejection justifications need to be reviewed with Chief Examiner for acceptability.
Changed rejection methodology and resampling methodology. Review the new rejection list.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Administrative JPM Outline (Aug 8, 2015)
Comment Resolution 1 Identify RO JPMs as A1-A4 and SRO JPMs as A5-A9. Put on form.
Complete 2 (RO/SRO) Put title of JPM on 301-1 form (like the Sim JPMs have) in Topic block.
Complete 3 Ensure LOD for A4 is appropriate for a licensed op applicant.
This discusses dose limits during emergency conditions and is LOD appropriate.
4 KA for A4 is same as Tier 3 KA on RO written exam - ensure no overlap.
No overlap one discusses normal the other discusses emergency dose rates.
5 A1 and A5 (SGTL) descriptions are verbatim. A5 should have some additional action(s) based on license level for operational validity.
There is 4 of the 5 SRO admins that are SRO only so no change.
6 For A6 - is it the intent for the applicant to determine required actions based on determination? If not, add to JPM as additional action.
Added step to return to step 9 and continue boration.
7 For A9 - is this JPM identified as Time Critical? If so, ensure steps in JPM support examiner documenting start/stop times. How will applicant obtain the corrected EDCP? Does having to get this affect it being classified a Time Critical JPM?
The JPM will be changed to a time critical but with no errors it will be a straight PAR change with no built in errors.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Control Room / In-Plant System JPM Outline (Aug 8, 2015)
Comment Resolution 1
Identify simulator JPMs as S1-S8 and the in-plant JPMs as P1-P3. (Note - Any JPMs performed in the Control Room would be designated C.
Complete 2
It is noted that none of these JPMs are Direct from bank and none have been used on Previous two NRC exams.
N/A 3
Instead of the SRO-Is not doing S8 (SBO diesels), have them not do S5 (PRM). In addition to it being a significantly more important system, it 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.)
Complete 4
Did all S3-S8 validate at < 15 minutes?
Will have significant effect on schedule if
> 15 mins.
Times will vary somewhat but overall they should average out at ~15 minutes.
5 For S4, identify the Safety Function as 4S instead of 4.
Complete 6 For P2, identify the Safety Function as 4P instead of 4.
Complete 7
N/A Replaced original P1 with a different JPM. It was discovered that the original required a large amount of evaluator interaction which would remove some of the decision making from the student.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Simulator Scenario Outline Comments (Aug 8, 2015)
Scenario 1 Comment Resolution 1 Why is Setup IC for A MDAFW pump listed as an event?
Deleted 2
For CT - Start Train A CCW pump: are the CCP/SI pumps the most limiting safety significant component on loss of CCW? (i.e., is 30 minutes the most limiting time) Also, need to better define the task to capture success criteria.
Corrected 3
For CT - Start NSAFP before bleed and feed criteria are met: Need to better define the task to capture success criteria. Need to better describe the Justification to capture the critical nature of the task.
Corrected 4
The narrative on page 4 doesnt match the D-1. D-1 Events 1 & 2 arent in narrative, so narrative event numbers arent correct, initial power isnt the same.
Corrected per discussion with Chief and revised complete document.
5 Event 6 is the Major Transient - which is the rod eject. NBO2 fault is Event 7, TDAFP fails to start is Event 8.
Corrected per discussion with Chief and revised complete document.
6 In Target Quantitative Attributes table -
Need to verify #1, 2, 4, and 5. #1, Malfunctions after EOP entry, is 2, not 3.
- 2, Abnormal events, is 3 not 5. #4, 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)
Corrected per discussion with Chief and revised complete document.
Scenario 2 1 Initial Conditions - establish a power band instead of just 0.7%
Changed to 1-2%
2 For all CTs: Need to better define the tasks to capture success criteria.
Corrected 3 In Target Quantitative Attributes table -
Need to verify all numbers Corrected per discussion with Chief and revised complete document.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 4 Swap Events 4 &5 to alternate events between ATC and BOP Corrected Scenario 3 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Swap Events 2 & 3 to alternate events between ATC and BOP Corrected Verify TRM was provided as reference This is provided in the Control Room (SIM)
Scenario 4 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Event 2 - what procedure is used to take manual control?
Corrected Scenario 5 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Event numbers in narrative are mis-numbered since increase in power is not identified as Event 1 Corrected Event 2 - what procedure is used?
Added procedure to description Need to discuss breakout of events after earthquake to separate events from precursors.
Corrected
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 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.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Facility:
Wolf Creek NOC First Exam Date:
November 13, 2015 Written Exam Outline (Aug 8, 2015)
Comment Resolution 1
SRO: For original T1/G2, W/E15 Containment Flooding, KA - 2.1.31, a replacement A2 KA was selected. Why not select a Generic KA?
Need to review resampling guidance -
see Misc Comments #3.
Changed rejection methodology and resampling methodology. Review the new rejection list.
2 SRO: For original T2/G2, 033 Spent Fuel Pool Cooling, KA - 2.4.3, a replacement KA in system 035 Steam Generator was selected. Why not reselect a KA from SFP?
Need to review resampling guidance -
see Misc Comments #3.
Does Wolf Creek plan to install SFP post-accident instrumentation?
Changed rejection methodology and resampling methodology. Review the new rejection list.
3 SRO: For original T2/G2, 086 Fire Protection, KA - A2.04: Does Wolf Creek not have an AOP for mitigating a fire or damage from a fire? Same concern regarding reselecting a KA from a different system.
Changed rejection methodology and resampling methodology. Review the new rejection list.
4 SRO: For original T2/G2, 034 Fuel Handling Equipment, KA - A1.02: The justification for replacing the KA is based on Wolf Creek not having an individual Tech Spec for refuel canal water level, but the A1 KA statement isnt limited to Tech Specs. Revise justification or retain original KA.
Changed rejection methodology and resampling methodology. Review the new rejection list.
5 SRO: The Record of Rejected KAs and Sample plan K/A rejections document says Tier 3 KA G2.1.15 was rejected and 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.
Changed rejection methodology and resampling methodology. Review the new rejection list.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Written Exam Outline (Aug 8, 2015) 6 RO: For original T1/G2, 036 Fuel Handling Accident, KA - AK1.03: The justification document states there are 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 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.
Changed rejection methodology and resampling methodology. Review the new rejection list.
7 RO: For original KA: 008 Component Cooling Water, KA - A2.05: If a valve in the HX bypass line is air operated and fails closed on loss of air, the lack of low temp alarms seems to be ideal for a question.
Need to review rejection for acceptability.
Changed rejection methodology and resampling methodology. Review the new rejection list.
8 RO - all remaining 8 rejection justifications need to be reviewed with Chief Examiner for acceptability.
Changed rejection methodology and resampling methodology. Review the new rejection list.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Administrative JPM Outline (Aug 8, 2015)
Comment Resolution 1 Identify RO JPMs as A1-A4 and SRO JPMs as A5-A9. Put on form.
Complete 2 (RO/SRO) Put title of JPM on 301-1 form (like the Sim JPMs have) in Topic block.
Complete 3 Ensure LOD for A4 is appropriate for a licensed op applicant.
This discusses dose limits during emergency conditions and is LOD appropriate.
4 KA for A4 is same as Tier 3 KA on RO written exam - ensure no overlap.
No overlap one discusses normal the other discusses emergency dose rates.
5 A1 and A5 (SGTL) descriptions are verbatim. A5 should have some additional action(s) based on license level for operational validity.
There is 4 of the 5 SRO admins that are SRO only so no change.
6 For A6 - is it the intent for the applicant to determine required actions based on determination? If not, add to JPM as additional action.
Added step to return to step 9 and continue boration.
7 For A9 - is this JPM identified as Time Critical? If so, ensure steps in JPM support examiner documenting start/stop times. How will applicant obtain the corrected EDCP? Does having to get this affect it being classified a Time Critical JPM?
The JPM will be changed to a time critical but with no errors it will be a straight PAR change with no built in errors.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Control Room / In-Plant System JPM Outline (Aug 8, 2015)
Comment Resolution 1
Identify simulator JPMs as S1-S8 and the in-plant JPMs as P1-P3. (Note - Any JPMs performed in the Control Room would be designated C.
Complete 2
It is noted that none of these JPMs are Direct from bank and none have been used on Previous two NRC exams.
N/A 3
Instead of the SRO-Is not doing S8 (SBO diesels), have them not do S5 (PRM). In addition to it being a significantly more important system, it 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.)
Complete 4
Did all S3-S8 validate at < 15 minutes?
Will have significant effect on schedule if
> 15 mins.
Times will vary somewhat but overall they should average out at ~15 minutes.
5 For S4, identify the Safety Function as 4S instead of 4.
Complete 6 For P2, identify the Safety Function as 4P instead of 4.
Complete 7
N/A Replaced original P1 with a different JPM. It was discovered that the original required a large amount of evaluator interaction which would remove some of the decision making from the student.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 Simulator Scenario Outline Comments (Aug 8, 2015)
Scenario 1 Comment Resolution 1 Why is Setup IC for A MDAFW pump listed as an event?
Deleted 2
For CT - Start Train A CCW pump: are the CCP/SI pumps the most limiting safety significant component on loss of CCW? (i.e., is 30 minutes the most limiting time) Also, need to better define the task to capture success criteria.
Corrected 3
For CT - Start NSAFP before bleed and feed criteria are met: Need to better define the task to capture success criteria. Need to better describe the Justification to capture the critical nature of the task.
Corrected 4
The narrative on page 4 doesnt match the D-1. D-1 Events 1 & 2 arent in narrative, so narrative event numbers arent correct, initial power isnt the same.
Corrected per discussion with Chief and revised complete document.
5 Event 6 is the Major Transient - which is the rod eject. NBO2 fault is Event 7, TDAFP fails to start is Event 8.
Corrected per discussion with Chief and revised complete document.
6 In Target Quantitative Attributes table -
Need to verify #1, 2, 4, and 5. #1, Malfunctions after EOP entry, is 2, not 3.
- 2, Abnormal events, is 3 not 5. #4, 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)
Corrected per discussion with Chief and revised complete document.
Scenario 2 1 Initial Conditions - establish a power band instead of just 0.7%
Changed to 1-2%
2 For all CTs: Need to better define the tasks to capture success criteria.
Corrected 3 In Target Quantitative Attributes table -
Need to verify all numbers Corrected per discussion with Chief and revised complete document.
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 4 Swap Events 4 &5 to alternate events between ATC and BOP Corrected Scenario 3 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Swap Events 2 & 3 to alternate events between ATC and BOP Corrected Verify TRM was provided as reference This is provided in the Control Room (SIM)
Scenario 4 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Event 2 - what procedure is used to take manual control?
Corrected Scenario 5 For all CTs: Need to better define the tasks to capture success criteria.
Corrected per discussion with Chief and revised complete document.
In Target Quantitative Attributes table -
Need to verify all numbers Corrected Event numbers in narrative are mis-numbered since increase in power is not identified as Event 1 Corrected Event 2 - what procedure is used?
Added procedure to description Need to discuss breakout of events after earthquake to separate events from precursors.
Corrected
PROPOSED OUTLINE COMMENTS Rev 2 OBDI 202 - IOLE Process Rev 1 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.