ML16293A971

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2016-07 Proposed Outline Comments
ML16293A971
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/11/2016
From: Vincent Gaddy
Operations Branch IV
To:
References
Download: ML16293A971 (11)


Text

INTEGRATED OUTLINE COMMENTS Rev 1 (CP-2016-07)

Facility: CPNPP First Exam Date: 07-11-2016 Written Exam Outline (April 4, 2016)

Comment Resolution 1 NRC Generated Written Exam Outlines N/A From discussion on 1-13-16, Q87 was identified as not having Chief Examiner requested that K/A be retained. Question was written 2 a 55.43(b) tie - to confirm, CP was able to identify a tie to with 55.43(b) tie.

55.43(b) for selected KA G2.2.3?

Is there a reason for the order of Q78 and Q79? Their order is Questions are not out of order. NRC stated that it was acceptable to out of sequence on the ES-401-2. reorder questions as desired, but not to continue to move them after an assigned question number. Any questions that appear to be out of 3 order are Questions with replacement K/As and the original Question/K/A was already assigned to that Question #.

Q79 was originally system 038. When replaced with system 025 this moved Q79 before Q78.

4 Likewise, is there a reason Q25 is out of order? (T1/G2)? See item 3.

Likewise, is there a reason Q35 and 36 are swapped, and See item 3. This comment appears to be related to the Question # in 5 Q37 and 38 are swapped, and Q40 and 41 are swapped, and ( ) which were agreed could be reordered based on CPNPPs ordering Q52 is out of order (T2/G1)? philosophy.

6 Likewise, for T2/G2 - why are Q64 and Q65 out of order? See item 5.

RO: K/A Category Point Totals for Tier 2 Group 2 are incorrect Corrected.

for K2 and A3. K2 should be 0 (not 1) and A3 should be 1 7

(not 0). The point totals for T2/G2 are correctly listed on ES-401-1 (skyscraper form). OBDI 202 - IOLE Process Rev 2

Written Exam Outline (April 4, 2016)

Comment Resolution From ES-401-4: Q63 - Original K/A was knowledge of the The operators job responsibilities do not require them to perform operational implications of effect of pressure on CTMT leak these types of calculations during normal or emergency operations. As rate in the E/APE of Loss of CTMT Integrity. The argument such the K/A has no operational validity for CPNPP. ES-401-4, 8

that operators are not trained on performing CTMT leakage Rejected K/A list will be revised to state clearer reason for rejection.

calculations does not justify replacement of K/A. Provide Chief Examiner for info as to why this K/A must be replaced.

From ES-401-4: Q15 (Q - Original K/A was power supply to Per discussion with Chief Examiner on 4-13-16, it was determined that CS pumps and theyre powered directly from 6.9 kV K/A rejection was appropriate but may be rethought if quality of 9 Safeguards bus - Are any other ESF pumps also powered replacement question did not meet the needs of all parties.

directly from 6.9 kV Safeguards buses? If not, then concur with LOD=1 and reselecting replacement K/A From ES-401-4: Q36 (Q63) - On 1-13-16, we discussed The original replacement went from K2 to A3 (as others K2s were not replacement of Q38 (Q65) K/A 075 K2.03 with 001 A3.07. available in system 074; A3 was the only category at 0 test items and Now you replaced K/A 071 A2.09 with 075 A2.02. How does all others were at 1). When system 071 A2.09 required replacement, it 10 this approach comply with replacement K/A criteria? Do was desirable to stay in the A2 category and as system 75 had concur that this original K/A should be replaced. originally been sampled but was no longer on the outline, it was chosen as the replacement system.

From ES-401-4: Q37 (Q65) - Concur with replacement IF Correct. CPNPP has no ARM features or interlocks that provide for 11 CPNPP ARM system design has no features or interlocks that isolation.

provide for Fuel Bldg isolation.

From ES-401-4: Q79 - Does CP have any questions in its Reviewed 040 AA2 K/As. Wrote new question to 040 AA2.05. Revised Initial License or Requal exam banks with the original K/A? ES-301-2 and ES-401-4.

On the surface, it appears that an SRO level question should 12 be able to be written for the original K/A. Also, why not select another AA2 K/A before selecting a different E/APE? All other AA2 IRs are > 4.0.

Of all questions that had K/A replacements, how many 3 (Questions 24, 37 & 44) 13 questions qualify as BANK? OBDI 202 - IOLE Process Rev 2

Administrative JPM Outline (April 4, 2016)

Comment Resolution General comment: all calculated values should include a band Understood.

1 or range of acceptable answers, and every band or range shall be justified and documented.

RA1 - is this the exact JPM from the 2013 NRC exam? By Agreed to replacement. Replaced with Bank JPM.

2 reviewing this exam, will applicants know 50% of Admin JPMs (RA1 and RA3)?

RA2 - ensure a copy of original JPM is included in Proposed Not required per NUREG-1021, but will be included. This is an error 3

Exam submittal. trap as the potential exists to give the unmodified version of the JPM.

RA3 - is this the exact JPM from the 2013 NRC exam? By Yes. No as RA1 has not appeared on any NRC exams.

4 reviewing this exam, will applicants know 50% of Admin JPMs (RA1 and RA3)?

RA4 - does CPNPP have a Bank JPM that would test No. ROs have no administrative responsibilities other than to operate Emergency Procedures/Plan? Typically, JPMs as described or act as a communicator which does not have written requirements if in the Task Summary offer little insight into Licensed Operator being asked to fill the role.

competence as the tasks are essentially the same as a 5

General Rad Worker. It is difficult for these types of JPMs to qualify for LOD > 1.0. In addition, CPNPP has not tested ROs in the Emergency Procedures/Plan category in the last 3 NRC exams (at least).

6 SA3 - is this the exact JPM from the 2013 NRC exam? Yes.

SA4 - is this the same as RA4 but with an SRO element Yes. Added second K/A and IR for SRO only portion.

7 added? Also, add the Generic K/A (and IR) that covers reporting requirements to the ES-301-1. OBDI 202 - IOLE Process Rev 2

Administrative JPM Outline (April 4, 2016)

Comment Resolution SA5 - is this the exact JPM from the 2014 NRC exam? It No this is an Emergency Classification that has never been used on an appears that for the 2013 and 2015 NRC exams, SA5 was to Initial Operating Test. It is Direct from Bank because it has been used Determine PARs. For the 2014 and 2016 NRC exams, SA5 is once on a Requal Operating Test.

to Classify an Emergency Plan Event. Discuss with Chief 8

Examiner how this is not a predicable Admin JPM. One option is to change the JPM to a Chemical or Toxic Gas Emergency classification if CPNPP has these types of procedures. OBDI 202 - IOLE Process Rev 2

Control Room / In-Plant System JPM Outline (April 4, 2016)

Comment Resolution Generic comment - what does the number in parentheses The numbers in parentheses refers to the CPNPP JPM number (either that follows all the K/As mean? For example, for S-1, it is from the bank or the number assigned after the test when it will be 1 (RO1024A). added to the bank). The number is the CPNPP task number followed by an alpha character if more than one JPM exists tied to the specific task.

Potential overlap with 2013 NRC exam: Are S-3 and S-8 the S-3 replaced with different JPM not used on any of the last 3 exams.

same JPMs that were used on 2013 NRC exam? Are This is a modified JPM last used on the 2012 NRC at which time it was S-5 and P-1 modified JPMs from those used on the 2013 a New JPM.

exam? S-8 issame JPM as was used on 2013 NRC exam and is being 2 retained.

The modified version of S-5 was unable to be validated. The 2013 NRC exam version is being used.

P-1 is not modified from the 2013 exam, but is an existing bank JPM on the same task.

S-1: To confirm, CPNPP does not intend to freeze Correct.

3 procedures for this class of applicants. Correct?

S-1: Is Summary Description correct for critical steps in that Correct.

4 the entire bank is withdrawn to a known position then H-8 is aligned?

S-2: Is the JPM designed for the applicant to perform the Yes both valves are tested. Time is not a concern.

operability test on both PORV Block Valves? If time is a 5 concern, consider having applicant perform the second PORV Block Valve (first one done by previous Crew and test was turned over to next shift). OBDI 202 - IOLE Process Rev 2

Control Room / In-Plant System JPM Outline (April 4, 2016)

Comment Resolution S-3: For CPNPP, are Time Sensitive Actions (TSA) S-3 is being replaced with a modified JPM, Respond to a Shutdown considered the same as Time Critical actions defined in Loss of Coolant.

NUREG 1021 (must be completed within a time period specified in a regulation or a facility commitment to the NRC)?

6 See Appendix C, B.5 Develop a Time Standard.

Also, JPM steps that record start/stop times for TSAs need to Yes, this will be included where appropriate (S-5) include cues for Examiners and places to record start/stop times for accurate and ease of documentation.

S-4: Will applicant receive an annunciator alarm in response No.

to over speed condition? If so, add to Summary Description 7

(since K/A is Turbine valve indicators, alarms and annunciators).

S-5: For the additional Alternate Path (cavitation), does Cavitation alternate path removed, returning to direct from bank 8

procedure guidance exist for the applicant to follow? version.

9 S-5: See S-3 for TSA question. STI-214.01 provides guidance. NRC to review.

S-5: What is the RWST level at the start of the JPM? When 7%.

does TSA-2.8 (70 seconds) start? Will it be clear to the TSA starts when operator reads less than 6%.

examiner? Will it be consistent from one applicant to the It should appear clear to the examiner as the applicant should be 10 next? reading the RWST level meters and then commence the evolution when they see indication that level is less than 6%.

It should be consistent between all applicants.

S-5: Is TSA-2.8 (70 seconds) applicable when there is two No longer applicable with return to bank JPM. 70 seconds is valid with alternate paths involved? In the end, both trains of the single failure which exists in the bank JPM.

11 Containment Spray are secured so it would seem there isnt really a time limit for transferring CS to Recirc Mode.

S-5: Is the cue to continue on with performance of the No longer applicable. Procedure enhancement captured as ROs were procedure required? What is the direction in the Initiating confused by intent of step and consistent performance could not be 12 Cue? Shouldnt the applicant be expected to know they obtained during validation. SROs were clear on the procedure intent should continue without being directed? and execution. OBDI 202 - IOLE Process Rev 2

Control Room / In-Plant System JPM Outline (April 4, 2016)

Comment Resolution S-6: Ensure Ops and Training concur that not performing S-6 is being replaced with S-6 from 2014 NRC exam per Chief 13 sync scope ops is sufficient JPM failure criteria. Examiner request.

S-6: If possible, add more critical steps to this JPM. Transfer See item 13.

14 2 buses? Performing an additional action after Bus 1A4 has been transferred?

S-7: Ensure this is NOT an event on any of the simulator It is not.

15 scenarios.

P-2: Can this JPM be performed on either unit? All three plant JPMs have a Unit 1 and Unit 2 version. Current plans are to have P-1 performed on Unit 1 as a contamination area may 16 interfere on Unit 2; P-2 to be performed on Unit 1 as the Unit 2 version is different panels and switches as has not been validated. P-3 will be the Unit 2 version.

P-2: Summary Description is missing K/A and IR at end of Corrected.

17 paragraph.

P-3: Is there an opportunity to incorporate actions from the No actions to be performed with the exception of transgressing from applicant in response to the security threat as they transition Control Room to Hot Shutdown Panel. Initial Conditions will be 18 to the Hot Shutdown Panel? Depending on the actions, this reviewed to ensure no concern over security actions will lead to might cause this JPM to be withheld from public disclosure applicant confusion during task performance.

and require SUNSI handling requirements.

P-3: For CPNPP, is it called Hot Shutdown Panel (as Both are used at CPNPP.

19 identified in the Summary Descriptions) or Remote Shutdown Panel (as on ES-301-2)?

P-3: If possible, add more critical steps to this JPM. Transfer The entire Attachment from ABN-905B is five steps long. The only 20 more equipment from Control Room to HSP? Start more actions nor performed are terminating the boration.

equipment than just Boric Acid Transfer Pump? OBDI 202 - IOLE Process Rev 2

Simulator Scenario Outline Comments (April 4, 2016)

Comment Resolution Number Critical Tasks (CTs) in each scenario as CT1, Okay.

CT2, etc in order to promote more effective Generic 1 communications between NRC and CPNPP Exam Development Team.

The basis for the safety significance of each CT needs This is already adequately covered in the ES-D-1s. No additional to be clearly identified and documented in the Scenario action needed.

Guide. The Critical Task Determination table is an Generic 2 acceptable means to document this, however, since there is not a specific column in the table dedicated to this, either create one or make sure the information is added to the Safety Significance column.

For the Target Quantitative Attributes table on Form D-1 That is correct. There was an error on a ES-D-1.

Generic 3 for all scenarios: EOPs entered/requiring substantive actions does NOT include E-0. See Appendix D.

Initiating Cues for the Lead Examiner will be Not necessary, but will be included.

established during validation. If possible, include how Generic 4 each event will be initiated (by Lead Examiner, on timer, at specific procedure step, etc) in the Scenario Summary for all scenarios.

CTs are not included in the Scenario Summary. It is This information is included in the ES-D-2s, but will add additional helpful to the Examiners to know when it is expected information in the summary.

Generic 5 the CTs will be performed. Include CTs in the summaries if possible.

Scenario 1: Both Critical Tasks are associated with Scenario rewrite has corrected this issue.

1 Step 4 of FRZ-0.1. Scenario should have diversity Scen between Critical Tasks.

1 CT to manually initiate Cnmt Isolation Phase B is Definitely not LOD 1, but added complexity of manual isolation does 2 LOD<2. Need to create situation for an additional CT in not work and the applicant must align manually.

this scenario. OBDI 202 - IOLE Process Rev 2

Simulator Scenario Outline Comments (April 4, 2016)

Comment Resolution CT2 - Initiate Train B Chem Add Tank flow, does not Deleted as CT.

3 have a basis or reference identified in the Safety Significance column.

Event 4: the Event Description states RCS leak of 600 This is an RCS leak that progresses to a SBLOCA.

4 gpm on 10 min ramp. Does CPNPP consider this a leak or a LOCA?

Event 6: Scenario Summary states when EOP-1 is The response to a LBLOCA at this point in the scenario results in a entered, a LBLOCA will occur. How is this LOCA different recovery strategy which also includes progress through the 5 different than Event 4? Is it the same point of break but FRG response.

the timer is just removed? Not sure this qualifies as a separate Major Transient.

Since this is desired to be one of the scenarios seen by See item 1 for scenario 1.

all crews, add another RO event prior to the first Major.

6 Consider electrical bus fault that impairs equipment during Major Transient recovery such that a CT can be generated.

Termination Criteria - how long does it take to reach 17 minutes.

7 conditions for Transfer to Cold Leg Recirc? Concern is that this will take too long (>1.5-2 hrs) 8 Event 5: SRO also gets credit for component failure. Okay.

1 Event 1: SRO is also given credit for the Normal Okay.

Event 2: Is the rate of failure large enough to ensure all Scenario rewrite has occurred.

2 crews will enter the TS?

Scen The D-2s need to include sufficient Examiner Notes Okay.

2 and places to record when loss of subcooling occurs 3

and when RCPs are tripped in order to properly document pass/fail of CT1.

4 Event 8: SRO also gets credit for component failure. Okay. OBDI 202 - IOLE Process Rev 2

Simulator Scenario Outline Comments (April 4, 2016)

Comment Resolution For Events 6, 7 and 8, the SRO is also given credit for Okay.

1 Scen the component failures.

3 It would be helpful, but not required, to separate out Okay.

2 Events 6, 7 and 8 in the Scenario Summary.

1 Events 1-4: SRO also gets credit for the event. Okay.

Events 8-9: SRO also gets credit for the component Okay.

2 failures.

Event 4: Is the Reactor Power band from 6-8% the This is the procedurally controlled next plateau. The plateau where Scen 3 normal power band used in the plant when making the turbine is synched to the grid is 10 to 12%.

4 preps for synchronizing MG to grid?

Termination Criteria - does the scenario terminate Yes.

directly after the transition to EOS-1.2, Post LOCA 4

Cooldown and Depressurization, such that no steps are taken in EOS-1.2? OBDI 202 - IOLE Process Rev 2

Schedule Comments - Rev 0 (April 4, 2016)

Comment Resolution Chief Examiner to send CPNPP a version of the schedule If the Chief Examiner has his own schedule format that is fine but 1 using MS Word. This is the format to be used for the final rev of needs to be provided in sufficient time to not add additional burden.

the schedule.

Use of I (Instant) is used instead of D (Direct) for the one SRO Non-impactive.

2 (SRO-I vs SRO-D).

Thursday: Are S-2, S-5 and S-7 designed to be run No JPMs are designed to be run together. With only 9 candidates it 3

simultaneously or in series? was not deemed necessary.

4 Thursday: The block for S-3 is missing applicant R1. Correct.

Thursday: Are S-1 and S-6 designed to be run simultaneously See item 3.

5 or in series?

6 Thursday: The block for S-1 and S-6 is missing applicant R1. Correct.

7 Friday: The block for S-4 is missing applicant R1. Correct.

8 Friday: The block for S-8 is missing applicant R1. Correct. OBDI 202 - IOLE Process Rev 2