ML17103A279

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2017 Clinton Power Station Initial Licensed Operator Examination Operating Exam Comments and Responses
ML17103A279
Person / Time
Site: Clinton Constellation icon.png
Issue date: 02/09/2017
From: Chuck Zoia
Operations Branch III
To:
Exelon Generation Co, Exelon Nuclear
Shared Package
ML16308A462 List:
References
50-461/17-301
Download: ML17103A279 (12)
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Text

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response Operating Test RO 1. Whats the basis for designating JPM steps 4-6 and 8 as 1. IAW CPS 3831.01 steps 2.1 - 2.3, the Admin critical steps over any other step? information recorded in blocks 305, 306, JPM407 2. Neither the procedure or the data sheet provides guidance for and 307 is reported to the NRC, and the normal in block 309, or what to enter/not enter if tailpipe temp INPO CDE, thus making these steps is not normal. On what bases could the JPM be failed if a critical. The facility agrees that JPM step value is entered in the block? 1 should be designated as a critical step.

3. CPS 3831.01 identifies ITS 5.6.4 as a requirement and 2. CPS 3101.01 Main Steam (MS) step reference. ITS 5.6.4 has been deleted from ITS. 2.2.2 provides the definition of a leaking
4. Initial conditions: how would time of actuation and duration be SRV (tailpipe temperature > 220°F). The determined? Provide this information in a format that the step is failed if the examinee enters any candidate could determine the information (alarm display, time value indicating that the tailpipe event recorder, etc.). temperature has returned to normal.

Added clarification to the comments section of JPM step 8.

3. The station will initiate an AR to correct the procedure deficiency after the exam is complete.
4. The station does not believe this will add value to the JPM. The main objective of the JPM is to test the candidates ability to retrieve and document regulatory data and determine that the SRV is leaking based on evaluation of tailpipe temperature data.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response RO 1. JPM step 1 - standard specifies that candidate sign the 1. OP-AA-105-102 Attachment 2 - fifth Admin attachment. Attachment only requires printed name, not column in the shift position log requires JPM484 signature. Should this step be a critical step since accurate active license signature, not printed completion is required to complete the license document? name. The critical objective of the JPM

2. For JPM step 3 - in the cue, insert the words if necessary is to test the candidates ability to before the words ask him/her. evaluate his/her license maintenance
3. In the initiating cue blocks on pages 6 and 12, bold the 4th requirements, not to fill out the form, so sentence concerning working a mixed shift schedule. the facility does not believe step 1 is a critical step.
2. Incorporated comment as requested.
3. Incorporated comment as requested.

RO 1. The comments in JPM steps 2 and 4 should be moved and 1. Incorporated comment as requested.

Admin inserted as a note prior to JPM step 2. 2. Re-ordered steps as requested.

JPM526 2. The JPM steps are not written in the order of isolation valves 3. Corrected the JPM step number.

first, followed by vent/drain valves last. 4. The station contends that inclusion of

3. The last JPM step is mis-numbered (should be 5, listed as 3). 1IA078A would be completely acceptable
4. JPM step 5 - if 1IA078A is included, should be considered a if included in addition to 1IA083A on a competency hit. clearance order, thus not a competency hit if included.

RO 1. Is the entire room posted as an HRA, or just in the vicinity of 1. The high rad boundary is confined to the Admin the PRM? If just the PRM area, it alters the RWP PRM cubicle, not the entire room. JPM JPM532 requirements. step 3 cues the examinee to identify the

2. Add a note or comment to step 2 describing the location of the RWP requirements for entering the area H2 analyzers. with the highest dose rate, which is the
3. Consider providing the examiner with copies of the other PRM - a high rad area. The JPM is survey maps, or the direction of what the examiner should do, correct in listing a specific HRA briefing if the applicant indicates the H2 analyzers are in another as required to enter the area.

location. 2. Incorporated comment as requested.

4. On the RWP, change the date, survey index #, and cal due 3. Added a comment to JPM step 2 to date to current date. provide evaluator guidance in the event the examinee indentifies the incorrect survey map.
4. Added current dates to the survey map and the RPW for JPM532.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response SRO 1. Provide a copy of the 3D monicore printout in the JPM 1. Provided for review during prep week.

Admin package. 2. Added 9820.01 to the list of procedures JPM425 2. Evaluator instructions - add a copy of CPS 9820.01 to the list to provide the student.

of procedures to provide to the applicant (if requested). 3. While JPM step 5 is an expected action,

3. Seems like JPM step 5 should be a critical step. it is not required by CPS 9820.01, thus
4. Sanitize the dates on the 3D case and print on pink. not a critical step.
4. Updated the 3D case in the JPM folder with sanitized dates.

SRO 1. It is indicated that night shift begins at 1900 on the previous 1. The facility believes that annotating the Admin day, it seems appropriate to indicate that all other shifts begin beginning of the night shift is necessary JPM483 at 0700 (either that or remove the notation for the night shift). to eliminate any confusion for the

2. Ive seen this JPM before, or something similar at another examinee being evaluated as to the start site? time for the night shift. The annotation is not required for the day shift entries and would add unnecessary wording to the JPM, making it more confusing.
2. This is a new JPM for CPS. It was developed and modified from JPM-FP-S-FMP-01-001 from Monticello Nuclear Generating Plant.

SRO 1. Procedural references - ITS 3.5.1 and B3.5.1 should be 1. Added ITS to procedural references as Admin added. requested.

JPM469 2. This JPM examines multiple generic KAs (2.2.13, 2.2.40, 2. Added KAs 2.2.13 and 2.2.41 to KA table 2.2.41). JPM should be include all applicable KAs, or on JPM page 9.

rewritten to address the specific KA. 3. The hang sequence is in accordance

3. Applicants may question correctness of the hang sequence; with the requirements of OP-AA-109-101 specifically the CS for the WLP. section 7.3.1. In addition, JPM469 was
4. Essentially the same JPM as the last exam at CPS, with the developed from an approved clearance.

exception of the component. 4. The station agrees that JPM469 is modeled from JPM538 administered on the ILT 14-1 NRC Exam, but the JPM469 does not contain the same types of deficiencies as JPM538, and is therefore correctly designated as a new JPM.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response SRO No comments Admin JPM536 SRO 1. Title of JPM should be Classify an emergency event and 1. Changed title as requested.

Admin determine PARs or tell the applicant a GE has been declared 2. The facility disagrees that a loss of FC is JPM482 in the initiating cue. indicated. The conditions in the initiating

2. I would argue that the standard for JPM step 1 is incorrect. cue do not meet the threshold for a loss The presence of hydrogen in the drywell and inability to of FC (containment radiation levels are <

maintain level above TAF is indicative of a loss of FC, and 41.3 r/hr).

thus a loss of two barriers and a potential loss of the third. 3. The facility contends that the PAR

3. PAR is inconsistent with the PAR flowchart. Neither the recommendation is correct for a PAR procedure nor flowchart indicate the need to evacuate the being made from the Control Room downwind sector. under the conditions where a Rapidly
4. Step 4 cue - change the word when to if. Progressing Severe Accident is not in progress.
4. Changed as requested 4 of 12

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response MCR 1. Step 1 - Unless there has been a change to the circuitry, this 1. The performance of JPM step 1 is JPM448 is not a critical step. required to accomplish the task standard

2. Step 4 - Unless there has been a change to the circuitry, this and is also required to be performed by is not a critical step. the operating procedure and is therefore
3. Either add 8.1.3.7 & 8.1.3.8 or provide an explanation of why critical IAW NUREG 1021 Appendix C the task is truncated before then. (C3).
4. Remove reference to ReMA in the inititating cue. 2. The performance of JPM step 4 is required to accomplish the task standard and is also required to be performed by the operating procedure and is therefore critical IAW NUREG 1021 Appendix C (C3).
3. Adding steps 8.1.3.7 and 8.1.3.8 does not add any evaluator observable actions from the examinee and unnecessarily lengthens the JPM. Added a comment to step 8.1.3.6 to explain why the task is truncated.
4. Removed reference to ReMA in the initiating cue.

MCR No comments JPM530 MCR 1. Add a note prior to step 1 to state that procedure step 8.1 is a 1. Added note as requested.

JPM419 continuous action step with no physical actions required. 2. Added the word momentarily as

2. JPM step 2 - add the word momentarily between and and requested.

depress. 3. Added note as requested.

3. JPM step 3 - add a note that procedure steps 8.5.1.1 and 8.5.1.2 are continuous action steps with no expected actions required.

MCR No comments JPM288 5 of 12

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response MCR 1. What is the regulatory bases for the JPM being time critical? 1. The 20 minute requirement is listed in JPM473 2. Separate JPM step with multiple actions into separate JPM USAR 5.4.7 as part of our design bases.

steps. 2. The facility contends that the format of complex JPMs into the step/element/standard format makes the JPM easier to evaluate. Each of the standard items is an individual step.

MCR 1. Separate JPM step with multiple actions into separate JPM 1. The facility contends that the format of JPM503 steps. complex JPMs into the

2. Either dont perform step 4.3 or else complete the step as part step/element/standard format makes the of the setup. JPM easier to evaluate. Each of the
3. JPM grading summary page lists the JPM as time critical. standard items is an individual step.
2. Step 4.3 was listed as partially complete to make the JPM more efficient to administer. Step 4.3.3.3 is needed to accomplish the task standard and to ensure enough critical steps for the JPM.
3. Changed the JPM grading summary page to non-time critical.

MCR No comments JPM427 MCR 1. Dave questions the alternate path designation of this JPM. 1. JPM474 contains each of the attributes JPM474 2. Separate JPM step with multiple actions into separate JPM listed in NUREG 1021 App. C for steps. alternate path JPMs, therefore it is the

3. JPM step 5 - provide procedure only after located in the rack. facilitys contention that it is an alternate
4. JPM step 4 - add a note before the step that if the hard card is path JPM.

used, to jump to JPM step 6. 2. The facility contends that the format of complex JPMs into the step/element/standard format makes the JPM easier to evaluate. Each of the standard items is an individual step.

3. Incorporated comment as requested.
4. Incorporated comment as requested.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response In-Plant For JPM step 4.3, add a cue to the examinee that the RCIC Gland Added as requested.

JPM247 Seal Air Compressor is not running.

In-Plant Since both breakers are in series, rotating one breaker handle is Based on procedural adherence standards JPM222 critical. Rotating the second handle is a competency hit if missed. and redundancy, the facility contends that turning both handles off is critical in the event of a failure of one of the breakers.

In-Plant No comments.

JPM431 7 of 12

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response Scenario 1. Events 1 and 2 - combine into one event. 1. Combined events 1 and 2 as requested.

1 2. The SRO TS call is questionable since the DG is already inop. 2. The ITS has to be re-entered. The

3. Does the speed ramp up after the output breaker is opened, or facility contends that the ITS call is valid.

does the diesel just trip? 3. The trip is tied to the opening of the DG

4. Event 4 - Provide information on how the BOP determines the output breaker (with a 2 second time status of the PR001 sample pump. If all sub-bullets are delay) to simulate the DG speed ramping closed, shouldnt the main bullet be closed. up before tripping in the simulator lesson
5. Event 8 and 9 - EOP-1 and critical task statements state that plan. DG speed is not directly indicated TAF is -162, while the critical task statement states -160. in the MCR with the output breaker open.

Which one is right? Make this consistent. 4. Provided BOP indications for sample

6. Termination criteria - should include containment parameters pump failure in the scenario guide.

are being controlled per EOP-6. Changed the main bullet to closed.

7. Critical tasks 5. Inserted that TAF is -160 inches on Wide o What is the basis for 17.5 minutes of level reaching Range Level Indicators in events 8, 9 TAF? and in the critical task statement.

o RPV 1.1 should be revised; EOP-3 entry is not 6. Included containment parameter control required until level reaches TAF (-162 inches). ADS in the termination criteria statement as should have automatically initiated 105 seconds after requested.

RPV level reached -145.5 inches. Therefore, it seems 7. Critical Tasks that the CT should be either: a. The 17.5 minutes is based on automatic initiate, MANUALLY initiates ADS OP-CL-102-106-1001 CPS IAW hard card before [whatever the Master List of Operator performance criteria is (e.g., RPV level Response Times as a time reaches TAF)]; or sensitive action in the event of a WHEN RPV level drops to -162 inches, Enter medium LOCA where ADS fails and Execute EOP-3, Emergency RPV to initiate for any reason. 17.5 Depressurization, before [whatever the minutes was derived from PRA performance criteria is] analysis.

o RPV 1.2 - Why is starting LPCS critical? b. Critical task listing is appropriate

8. Quantitive attributes - critical tasks at 2 is questionable if as written - discussed with the LPCS isnt critical. CE.
c. Starting LPCS is critical because the magnitude of the leak is such that RPV level will not recover 8 of 12

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response above TAF if LPCS is not manually initiated.

8. Starting LPCS is critical as explained in 7.c above.

Scenario 1. Event 6 - ATWS 1. The MSL Leak is unisolable due to seat 2 a. MSL Leak is described as Unisolable, however it leakage past 1B21-F022D and 28D appears that it is. If it is Unisolable, there should MSIVs and a rupture of the MSL D be a report from the BOP/ATC stating such. piping in the Aux Building Steam Tunnel.

2. Event 8 description should be MSL isolation on high Added reports from the BOP/ATC as temperature, not low vacuum. requested.
3. ATC failure to scram - add a bullet to determine if shutdown 2. Corrected the Event 8 description.

criteria is met before initiating ARI. 3. This is not in accordance with OP-CL-

4. ATC scram choreography - open bullet to report EOP entries. 101-111-1001-F-02 Start of Scram
5. Based on changes to EOP-1, should ADS be inhibited before Choreography (ATWS). Once the RMS ensuring the Manual SCRAM Pushbuttons and ARI dont work is placed in shutdown and shutdown to insert control rods; AND IF so, then shouldnt ADS be criteria is not met, manual scram and ARI returned to its normal configuration (i.e., UN-Inhibited) when are initiated before reporting status of EOP-1A is exited to return to EOP-1? shutdown criteria to the SRO.
6. Should be actions to enter and execute EOP-6 (pool 4. Reporting of EOP entries is required by temperature following blowdown). the scram choreography and should be a
7. Critical tasks - RPV 5.1/6.1 - revise to specify insertion of closed bullet.

control rods (ARI). Revise SC 1.2 to state: Enters and 5. Per the immediate actions of CPS Executes EOP-3 Emergency RPV Depressurization when . 4100.01 Reactor Scram, that manual SRO directs, does not perform, the blowdown. scram and ARI will be immediately

8. Quantitive attributes - EOP contingencies requiring manually initiated before entering EOP-1 substantive - ATWS actions may not be substantive. and transitioning to EOP-1A. Therefore ADS will not be inhibited if ARI is successful in inserting control rods and achieving shutdown criteria.
6. EOP-6 would be entered and executed well after the blowdown is performed and the terminus criteria is met.
7. Revised RPV 5.1/6.1 as requested.

Added critical task to place RMS in S/D 9 of 12

ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response with no RR Pumps operating and the RMS in Run.

8. The facility contends that the EOP-1A actions in S2 (manually initiating RPS and ARI logic circuits) meets the definition of substantive contained in ES-301 D.5.f.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response Scenario 1. Event 4 - unless ATC makes the CRD drive water header 1. Changed event 4 to require ATC to 3 pressure adjustment, would not count this as an ATC adjust drive water pressure.

component failure. 2. CPS 3304.01 section 8.3.4.4 directs

2. When does the drive pressure have to be returned to normal returning Drive Water Diff Press to (after the rod is at the target position, when the rod is normal when the control rod is successfully withdrawn)? successfully withdrawn, but does not
3. Event 5 - table on page 15 of 17 - N683B and N690B cannot provide a specific position. For this be tripped at the same time. Since there is not an actual leak, scenario, it is expected that drive water what requires the penetration to be isolated immediately when differential pressure will be restored after ITS allows time to isolate the penetration? the rod is withdrawn one notch.
4. Declaring RCIC inoperable is not required until RCIC steam 3. The ATM trip status has been technically supply is isolated. verified correct by the validation team,
5. Event 7 - need to watch this one closely since this malfunction facility author, and the facility rep. Per starts at low power. If level is lowered, there will probably not OP-AA-103-102-1001 Strategies For be a need to inject boron. Determine why tripping RR Pumps Successful Transient Mitigation, section is not required by the EOP? 4.1.2.2 Manual Action in lieu of
6. CT 1 (RPV-6.1) needs a performance criteria. CT 2 (RPV- Automatic Action, when an automatic 6.2) - Scenario Guide states that CT is conditional. No action fails to occur as designed, conditions are specified in EOP; simply states to Inhibit operators are expected to place the ADS. RPV 6.3 - Whether or not RPV is lowered will be system or component in the desired dependent upon sequence of orders and whether or not state, report completion of the manual power is above 5% when step is implemented. action to the Control Room Supervisor,
7. Quantitive attributes - no issues noted. and follow-up with available procedural guidance to ensure the actions taken were correct and adequate.
4. Added the words after the RCIC steam supply line is isolated to the ITS 3.5.3 action line.
5. Manual tripping of the RR Pumps is not directed by EOP-1A. EOP-1A requires verification that the RR Pumps downshift when level reaches Level 3 and trip when RPV level reaches Level 2.

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ILT 15-1 NRC Exam Submittal Comments Clinton Power Station Date Received: _12/22/16__

ILT Class 15-1 Exam Date 1/30/17 Operating Test 2017-301 Item # UnSat/Editorial Chief Examiner Comment Facility Action/Response

6. Critical task listing was revised as follows:

o CT1 (RPV 6.1) was revised to include performance criteria (SLC initiated within 120 seconds of RPV level reaching Level 2.

o CT2 (RPV 6.2) was revised to add performance criteria (Inhibit ADS within 105 seconds of RPV level reaching Level 1).

o CT3 (RPV 6.3 to terminate and prevent injection to lower level) was eliminated.

o CT4 (RPV 6.3 to terminate and prevent injection from HPCS) -

added performance criteria to perform critical task before RPV level reaches Level 2 (the HPCS initiation setpoint).

Scenario Review comments made during prep week. Spare not needed 4 - Spare 12 of 12

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