ML17136A156

2017 Dresden Nuclear Power Station Initial License Reexamination Operating Exam Review Comments

ML17136A156
Person / Time
Site:	Dresden
Issue date:	03/06/2017
From:	Jesse Seymour NRC/RGN-III
To:	NRC/RGN-III/DRS/OLB, Exelon Generation Co
Shared Package
ML17110A111	List: ML17128A150 ML17136A141 ML17136A145 ML17136A156 ML17136A162 ML17138A234
References
Download: ML17136A156 (4)

Text

Dresden Retake Exam 2016-302 Review Comments

• Control Room JPMs o JPM a (S-N-a):

NRC: This JPM involves performing immediate actions per a hard card. The content appears to be all scram choreography actions. Are these task steps all part of scram immediate actions? NUREG-1021 Appendix C section B.3 says JPMs should not solely test immediate action steps and should include testing additional steps or items that are not from memory.

• Facility: not all actions are immediate actions or steps from memory; ARI initiation and subsequent actions are performed using a hard card procedure.

o JPM b (S-N-b):

NRC: Applicant handout materials do not include a copy of DAN 902 902-3 C-7 for the alternate path.

• Facility: will include a copy.

o NRC: Comment incorporated.

o JPM c (S-N-c):

NRC: The conditional note and cues provided as a contingency in the event that other examinees are in proximity should be removed. Since a single examiner will be conducting this reexamination, multiple examinees will not be performing different JPMs on the simulator floor at the same time.

• Facility: will remove cues.

o NRC: Comment incorporated.

o JPM d (S-N-d):

NRC: JPM cover sheet is missing AP (alternate path) in the title.

• Facility: will add AP.

o NRC: Comment incorporated.

o JPM e (S-N-e):

NRC: Include in the initiating cue that precautions and limitation have been verified in order to be consistent with the marked-up handout that the applicant will receive.

• Facility: recommended leaving initiating cue as is, as it ensures that applicant must make an initial decision concerning the correct procedural step to begin with.

o NRC: Resolution is acceptable.

o JPM f (S-N-f):

NRC: The performance steps of the task standard contain numbering errors; there are two step 05s and what appears to be step 06 is unlabeled with a step number.

• Facility: will fix numbering.

o NRC: Comment incorporated.

Dresden Retake Exam 2016-302 Review Comments NRC: The initial plant conditions say that rod H-08 has been inserted to position

00. The un-numbered performance step in the task standard states Verify ONLY withdraw block is applied to CRD H-08. DOP 0400-02, step G.4.f.1, says to verify that if IF the Rod is at 00, THEN insert and withdraw blocks are applied. Correct the task standard or explain why it is correct as currently written.

• Facility: will verify accuracy of JPM step and revise if needed.

o NRC: Comment incorporated.

NRC: It is likely that based upon the initiating cue provided, an applicant would also complete steps G.4.h through G.4.j before informing an evaluator that they had finished their assigned task. Corresponding performance steps and, if needed cues, should be included in the task standard for these.

• Facility: will add additional steps to the task standard as requested.

o NRC: Comment incorporated.

o JPM g (S-N-g):

NRC: This JPM is listed as being associated with K/A 400000 (Component Cooling Water System) A4.01 (Ability to manually operate and / or monitor in the control room: CCW indications and control); this is used to satisfy safety function 8 on the outline (Plant Service Systems).

• NRC: Per the BWR K/A catalog, Safety Function 8 includes the following systems:

o Fire Protection System (286000) o Fuel Handling (234000) o Instrument Air System (300000) o Component Cooling Water System (400000)

NRC: Based upon review of the JPM, the applicant appears to be operating components that are associated with circulating water, versus component cooling water. Please explain how this JPM is associated with the listed K/A and safety function. (Note NUREG-1021 ES-301, sections D.4.a and D.4.b discusses JPM system selections based upon safety functions.)

• Facility: will replace JPM with one related to a system that is associated with the safety function.

o NRC: Replacement JPM meets outline safety function and is acceptable.

• In-Plant JPMs o JPM i (S-N-i):

NRC: The cue that follows performance step 1 of the task standard says to provide an indication that Main (lower section) Breaker #4 (48/24 VDC TO 2B DISTRIBUTION BREAKERS) in Distribution Panel 2B is tripped. Performance step 6 of the task standard says that the applicant will find tripped and attempt to reclose Main (lower) breaker #4 (48/24 VDC TO 2A DISTRIBUTION BREAKERS).

Dresden Retake Exam 2016-302 Review Comments The cue that follows performance step 9 of the task standard says to provide an indication that Main Supply breaker #4 (48/24 VDC TO 2B DISTRIBUTION BREAKERS) tripped. Explain this apparent discrepancy and correct it if needed.

• Facility: will review and correct if needed.

o NRC: Comment incorporated.

NRC: The cue that follows performance step 9 of the task standard says to provide an indication following the closure of Bkr 1 that the breaker shows a few amps. Is this intended to instead be a simulated reading from the battery charger ammeters as the cue preceding the step suggests? Correct the cue if this is an error.

• Facility: will correct error.

o NRC: Comment incorporated.

o JPM j (S-N-j):

NRC: If the facility has a laser pointer available, please provide one as an aid for this JPM (used to indicate wire and terminal locations without having to break the plane of the open cabinet door.

• Facility: will provide if available.

o NRC: During validation, determination was made that use of a laser pointer would not be desirable.

o JPM k (S-N-k):

NRC: Two of the valves whose operation is simulated require RP surveys. Is the intent of the JPM to have the applicant identify the valves and discuss their operation from a distance sufficient that an RP survey is not required during the conduct of the JPM?

• Facility: intent is just to simulate from the ground; information is provided in JPM so that examiner is aware of requirements that applicant should describe when discussing the simulated operations.

• Admin JPMs o SRO CO1 (A-N-1-S):

NRC: Performance step 2 contains a typo; Manual is misspelled.

• Facility: will correct.

o NRC: Comment incorporated.

o SRO CO2 (A-N-2-S):

NRC: Divide initial condition #15 into multiple sentences for clarity. The current sentence structure could be confusing.

• Facility: will reword for clarity.

o NRC: Comment incorporated.

o SRO EC (A-N-3-S): no comments.

o SRO RC (A-N-4-S):

NRC: In performance step 4, would the total annual dose be 2005 mrem (1950 +

55) versus 2010 mrem?

Dresden Retake Exam 2016-302 Review Comments

• Facility: value is correct, there is an additional 5 mrem that must be accounted for in the JPM.

o SRO EP (A-N-5-S):

NRC: Add the following cue to the initiating cue on page 5 of the JPM as well as on the student handout (page 8): THIS JPM IS TIME CRITICAL.

• Facility: will include as requested.

o NRC: Comment incorporated.

NRC: It is requested that the facility indicate which information entered on the NARS form is part of the critical task, as opposed to any information entered which is not part of the critical task. For example, are the utility message number, state message number, additional information field, and approval signature part of the critical step? (These items do not appear to be related to the NEI 99-02 items that are related to the accuracy of a notification.) It is requested that the information that is part of the critical task be designated by annotating it on the key (such as by bolding) or by listing it in the performance standard step.

• Facility: fairly certain that all information entered on the key should be part of the critical task, however will research the question further and update steps as needed. Will update task standard and key to make all entered information that is associated with the critical task in bolded lettering.

o NRC: Comment incorporated.