ML17132A132
| ML17132A132 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/12/2017 |
| From: | NRC/RGN-II |
| To: | Tennessee Valley Authority |
| References | |
| Download: ML17132A132 (13) | |
Text
Personally Identifiable Information Withhold Under 10 CFR 2.390 Enclosure 7 Browns Ferry Nuclear Plant Units 1, 2, and 3 Senior Reactor Operator Initial License Operating Examination Post Examination Response Facility Comments Made in Accordance With ES-501 Attachment I (See Attached)
BEN 2017 NRC Exam for ILT class 1703 Post Operating Exam Comment JPM 694 Minimum Staffing-SM personal emergency The Facility acknowledges that there was an error in the initial staffing provided to the candidates that was not detected during validation or during the NRC Preparation Week. This error resulted in not having an SRO to relieve the STA of duties other than STA duties within 10 minutes as required by procedure.
Step 3 of the JPM to move the Outside Unit Supervisor/Incident Commander (IC) to fill the Ui Unit Supervisor position should not have been a Critical Step.
Step 4 of the JPM to fill the Incident Commander position with a qualified RO was incorrectly changed during the NRC Preparation Week to be a Critical Step without due diligence on the part of the Facility.
Step 5 of the JPM is revised to call in an additional SRO due to the error referenced above.
Applicant Performance:
Applicants identified that the Shift Manager position is required at all times and filled the position with the most senior active SRO.
Applicants identified the requirement to restore minimum staffing within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Some Applicants temporarily redistributed shift manning to fill the shift positions.
Bases for Post Exam Comment:
Step 3 of the JPM to redistribute the shift to fill the Unit 1 Unit Supervisor position should not be a Critical step.
Bases:
I OCFR5O.54(m)(2)(i) reduces the number of SROs by one for three Units with two Control Rooms vs three Control Rooms.
10CFR5O.54(m)(2)(iii) states: When a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the units technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times.
The Facilities position is that this condition is met by the Unit 2 Unit Supervisor because Unit 1 and Unit 2 share a Control Room.
Tech Spec 5.2.2.b states: Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
OPDP-1 Attachment 1, Shift Staffing, Section 1.O.B states: In addition to the SM on site, a second active licensed SRO shall be in the control room at all times. The SM may, from time to time, act as relief Operator for the licensed SRO assigned to the control room.
Step 4 of the JPM to move a qualified RO to the IC position should not be a critical step.
Bases:
OPDP-1 Attachment 1, Shift Staffing, Section 1 .0.G states: At BEN, the Incident Commander will be one of the Unit Supervisor positions not assigned to a unit or the STA role.
Note: Prior to Rev 33 of OPDP-1, dated 7/14/20 14, the IC position could be staffed with a qualified RO or SRO.
There is currently no procedural requirement to fill the IC position with an RO.
The intent of this step was to temporarily assign responsibility for the IC duties to a qualified RO until the position could be filled by calling in an SRO.
There is precedence for filling the IC role with a qualified RO during the unexpected absence of one of the Unit Supervisor/SRO positions. On 2/8/201 5, an on shift Unit Supervisor had to leave the site due to a medical emergency. The responsibility for the IC role was temporarily assigned to a qualified RO from 0830 until 1004, when an additional Unit Supervisor reported to the site and relieved the RO of IC duties. This is documented in the Operations log on 2/8/2015.
Currently BFN does not staff the shift using ROs in the IC role. According to the BEN Learning Management System, however, there are 14 ROs qualified as Incident Commander.
Step 5 of the JPM to comply with Tech Specs 5.2.2, Unit Staff, is a Critical step.
The Applicants are required to call in a replacement SM or an SRO to replace the original SM. The Applicants are also required to call in an additional SRO due to the error in the initial manning which will allow the IC and STA position to be independently staffed.
Based on the information above, the Facility recommends accepting a revised JPM answer key with two Critical steps (See Attached).
Documents Reviewed include:
IOCFR5O.54 Tech Spec section 5.2 OPDP-1 current and previous revisions BFN Learning Management System (LMS)
BEN eSOMS Operation Narrative Logs
I Job Performance Measure (JPM)
Minimum Staffing SM personal emergency, SITE: BEN JPM TITLE:
immediately leaves site JPM NUMBER: 694 REVISION: 2 TASK APPLICABILITY: I SRO .
STA El IUOEl NAUO El S-000-AD-89; Observe Conduct of Operations TASK NUMBER / TASK TITLE(S): Guidelines I
K/A RATINGS: I RO 2.9 SRO 3.9 I 2.1 .5: Ability to use procedures related to shift staffing, such as K/A STATEMENT: minimum crew complement, overtime limitations, etc.
I RELATED PRA INEORMATION: N/A SAFETY FUNCTION: Admin Conduct Of Operation
[ EVALUATION LOCATION: El In-Plant El Simulator El Control Room
- Other List Classroom El Lab L -
APPLICABLE METHOD OF TESTING: El Discussion ElSimulateiWalkthrough S Perform TIME FOR COMPLETION: N/A TIME CRITICAL (Y/N) N ALTERNATE PATH (Y/N) N Developed by:
Developer Date (Ensure validator is briefed on exam security per NPG-SPP-17.8.1)
(See JPM Validation Checklist in NPG-SPP-17.8.2)
Validated by:
Validator Date Approved by:
Site Training Management Date Approved by:
Site Training Program Owner Date I
I j/i OPERATOR: JPM Number 694 SRO DATE:
TASK STANDARD: Using the Shift Manning Sheet provided and the experience levels of the available SROs, determines the temporary SM for the crew and calls out a replacement SM.
PRA: NA REFERENCES/PROCEDURES NEEDED: OPDP-1 Unit 2 Tech Specs VALIDATION TIME: 15 Minutes PERFORMANCE TIME:______
COMMENTS:
Additional comment sheets attached? YES NO RESULTS: SATISFACTORY UNSATISFACTORY (Retain entire JPM for records)
SIGNATURE: DATE:
EXAMINER 2
I I!/ Job Performance Measure (JPM)
Classroom INITIAL CONDITIONS:
- All three Units are operating at 100% power
- Its Saturday Dayshift
- Shift staffing requirements have been met The Crew has been on watch for the past 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
INITIATING CUES:
You are the Shift Manager (SM) and a personal emergency requires you to immediately leave the site.
Review the attached weekly schedule and determine what actions are required to comply with all applicable shift manning requirements.
3
I II Job Performance Measure (JPM)
Weekly Schedule Group 2 MTWTFSS NOTE N000DDD A-SEE LEAVE BOOK SM & Hill, R.G. $
US-i Jones, T.R $ (@) PERFORM NO LICENSE DUTIES (b) BREAKIN NEEDED FOR AUO ROUNDS US-2 &, Rodgers, R.J. $
(U) CHECK PROFICIENCY LIST FOR BI NEED US-3 Speckman, T.B. $
(s) NOT EMERGENCY RESPONDER QUALIFIED US-4 %,w, s Hardin, D.D.
(w) CHECK MEDICAL RESTRICTIONS US-5 Holder, B.R. $
& MEDICAL OR RESPIRATOR FIT DUE THIS QUARTER US-6
% - BREAKIN REQUIRED TO WORK TS POSITION US-7
- STA QUALIFIED US-8 -
(I) LLRT LEVEL 1 TESTER (II) LLRT LEVEL 2 UO Aman,D.R.
- NOT SST QUALIFIED UO & Intauno ,M.A. $ -
NRC PHONE (]ITT)
UO Mascareno,T -
Tew,CE. $ - INCIDENT COMMANDER QUALIFIED UO (1) PERFORM NO-SOLO LICENSE DUTIES UO & Becker,T.E.
& (2) NOT FIRBNATCH QUALIFIED UO Best,D.L. $
UO & LoginsKC.
UO Morton, SA.
SM Hill SRO, Qualified SM 10 years experience Ui US Jones SRO 15 years experience U2 US Rodgers SRO 1 year experience U3 US Speckman SRO 10 years experience wcc Hardin SRO 20 years experience, medical restriction (cant lift >20 Ibs)
OS/Ic Holder SRO 7 years experience 4
I I/1 Job Performance Measure (JPM)
KEY In accordance with OPDP-1 page 8 of 77.
The SM becomes incapacitated, or The SM is otherwise unable to perform SM duties.
Then the following order of succession applies:
- 2. Any SM-qualified person with an active SRO license who is immediately available such as in training, or on site for another reason.
- 3. Most senior person on shift with active SRO license.
Move T.R. Jones to Shift Manager Move Bob Holder to Unit I Unit Supervisor Designate a qualified RO as incident commander In accordance with Tech Specs 5.2.2 Unit Staff Perform a Shift Manager call out and get a Qualified SM in the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
5
I !fij START TIME_______
STEP I STANDARD SAT I UNSAT Step 1: References OPDP-1 Conduct of Operations for guidance. SAT Standard: Determines that with the SM position vacant that the most senior UNSAT person on shift with an active SRO license will be selected as a temporary replacement. N/A Critical Step Step 2: References OPDP-1 Conduct of Operations for guidance.
SAT Standard: Determines that T.R. Jones is selected to fill the Shift Managers position temporarily. UNSAT N/A Step 3: Redistributes the shift to fill the US position. SAT Standard: Moves Bob Holder from Incident Commander to Unit 1 Unit UNSAT Supervisor.
N/A SAT Step 4: Redistributes the shift to fill the Incident Commander position.
U N SAT Standard: Moves Intauno or Best to fill the Incident Commander position.
N/A 6
STEP I STANDARD SAT I U NSAT Step 5: Complies with Tech Specs 5.2.2 Unit Staff Shift crew composition may be less than the minimum requirement of Critical Step 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected SAT absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum UNSAT requirements.
N/A Standard: Calls out for a replacement Shift Manager to be filled within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
STOP TIME END OF TASK 7
I1!/il Job Performance Measure (JPM)
Provide to Applicant Classroom INITIAL CONDJTIONS:
- All three Units are operating at 100% power
- Its Saturday Dayshift
- Shift staffing requirements have been met The Crew has been on watch for the past 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> as follows:
Weekly Schedule Group 2 MTWTFSS NOTE N000DDD
& A SYh LEAVE bOOK SM Hill, R.G. $ -
f) PERFORM NO LICENSE DUTIES US-i Jones, T.R $ -
(b) BREAKIN NEEDED FOR AUO ROUNDS US-2 &, Rodgers, R.J. $ -
(U) CHECK PROFICIENCY UST FOR BI NEED US-3 Speckman, 1.8. $ -
%,w, (s) NOT EMERGENCY RESPONDER QUALIFIED US-4 s Hardin, D.D. -
- (w) CHECK NEDICAL RESTRICTIONS US-5 Holder, J.R. $ -
& MEDICAL OR RESPIRATOR Fi DUE US-B BREAKIN REQUIRED TO WORK TS POSON US-7
- STA QUALIFIED US-8 (I) LIRT LEVEL I TESTER (II) LIRT LEVEL 2 UO Aman, D.R.
& # NOT 551 QUALIFIED UO Intauno ,M.A. $ -
NRC PHONE (lilT)
UO Mascareno,T Tew,C.E. $ INCIDENT COIMviANDER QUALIFIED UO -
& (1)- PERFORM NO-SOLO LICENSE DUTIES UO Becker,T.E.
(2) NOT FIREWATCH QUALIFIED UO & Best,D.L. $
UO & Logins,K.C.
UO Morton, S.A.
SM Hill SRO, Qualified SM 10 years experience Ui US Jones SRO 15 years experience U2 US Rodgers SRO 1 year experience U3 US Speckman SRO 10 years experience wCC Hardin SRO 20 years experience, medical restriction (cant lift >20 lbs)
OS/IC Holder SRO 7 years experience 8
I I!/1 Job Performance Measure (JPM)
INITIATING CUES:
You are the Shift Manager (SM) and a personal emergency requires you to immediately leave the site.
Review the attached weekly schedule and determine what actions are required to comply with all applicable shift manning requirements.
9