ML18239A237
| ML18239A237 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/03/2018 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Entergy Operations |
| References | |
| Download: ML18239A237 (10) | |
Text
Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE EXPLANATIONS Facility:
RBS First Exam Date:
2018-07 Written Exam Outline Explanation Resolution 1 NRC Generated 2
Recent NRC HQ audit Explanations have discouraged Systems / E/APEs that are sampled multiple times on the RO exam from being sampled again on the SRO exam. This affects System 209002 HPCS, which is Qs 5 and 6 on RO exam and Q77 on SRO. Need to choose a different system for Q76 that is not sampled twice on RO exam in T2G1 Choose System 264000 (SF6 EGE)
Emergency Generators (Diesel / Jet)
EDG, K/A 2.4.20 Knowledge of the operational implications of EOP warnings, cautions, and notes.
Sampled 0 times on RO exam T2G1.
Action: New question written with new KA.
3 Rejected K/As reviewed and are justified. Replacements are acceptable.
For future exams request replacement K/As from NRC.
Action: We will request any future replacement K/As from the NRC.
4 5
Administrative JPM Outline Explanation Resolution 1
JPM A1 - title Determine if Reactor Remains Shutdown Under All Conditions - Incomplete SCRAM. Or Determine if Adequate Shutdown Margin Exists if your facility uses that term.
Supplemental info says RO will perform Enclosure 26, but this is listed as CONTROL ROD INSERTION METHOD DETERMINATION in EOP-5 Rev 317, and doesnt seem relevant to Action: Revised the title of the JPM to Determine If the Reactor Remains Shutdown under All Conditions
- Incomplete SCRAM Also revised title of A5 (SRO version of the JPM)
Explanation: The full title of Enclosure 26 is Control Rod Insertion Method / Reactor Will Remain Shutdown Under All Conditions Without Boron Determination Enclosure 26 Is dual-purpose, it provides methods for inserting rods as indicated in step SRQ-5 of EOP-1A ATWS as well as determining if the reactor will remain shutdown
OBDI 202 - IOLE Process Rev 3 the RO task. Ensure RO is required to also determine the REASON reactor will not remain shutdown if that is the direction the JPM goes.
under all conditions as indicated in the first override in EOP-1A step RCA-4. The RO will receive a full core display with the current rod pattern and then apply criteria to determine if the reactor will remain shutdown.
The criteria is control rods which are not fully inserted are surrounded by three fully inserted control rods on each face adjacent side and by one fully inserted control rod diagonally The answer is that it will or it will not remain shutdown.
Action: A que will be added to the JPM for the evaluator to ask the justification for the ROs answer with the answer key for the evaluator.
[NRC: Ask for the justification on the answer sheet so no evaluator verbal cue is required]
2 A2 - title Perform Single Loop Operation Surveillances Is this going to be performed in the Simulator?
Explanation: This JPM is run in the classroom. The RO is provided the data necessary to complete the surveillance. He completes the surveillance and then evaluates it against Tech Spec surveillance criteria.
3 A3 - If HPCS is going to be out of service for any scenarios and there are any postings in the simulator as a result e.g. on handswitches, ensure that scenario is run after this JPM is administered.
Explanation: HPCS will NOT be out of service for any of the proposed simulator scenarios so no compensatory action is necessary.
4 A4 - Ensure this is an ability-based task and not a series of questions and answers akin to a written exam question, or a direct look-up. The supplemental info sounds like the intent is for the examiner to ask the applicant questions and document responses, but that isnt the format we administer admin JPMs.
Explanation: This is the new JPM. In order to keep it in the classroom environment that would consist of pictures computer screens and simulation with a lot of questions and answers. More procedure reading then skill-based. Therefore, this JPM needs to be replaced. The JPM will be replaced with a bank JPM; however, there will still be two new admin JPMs administered.
Action: Replace this JPM with Radiation Control JPM used on March 2014 NRC exam. The title of the JPM is Determine Radiological Brief and Protective Clothing Requirements. Revise ES-301-1 to reflect JPM change out.
[NRC: This should count as P previous 2 exams, since there was no op test on 2015-05 retake.]
5 A9 - Does the applicant classify the event as part of this JPM or is that information provided?
Explanation: The SRO applicant will not need to classify the event. He will be told that an emergency classification has been declared. The applicant will fill out the 50.72 form for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> notification requirements.
Action: As was done with A1/A5, shortened title to NRC Notification Requirements
OBDI 202 - IOLE Process Rev 3 Control Room / In-Plant System JPM Outline Explanation Resolution 1 Label JPMs S1 S2 P1 P2 Etc., not a. b.
- c. d.
Action: ES301-2 has been updated with proper label.
2 JPMs j and k file names are both labeled RJPM-NRC18-P2. One of them should be P3 Action: ES301-2 has been updated with proper name.
3 Combine all 3 301-2 outline files into one by using RO SRO-I SRO-U See example.
Action: ES301-2 has been updated to one outline.
4 Fill out the quantitative attributes table on ES-301-2 with actual values (e.g.
<9(2)/<8(2)/<4(1) etc.)
Action: ES301-2 has been updated with additional table to contain required and actual attributes.
[NRC: D + N or M does not equal 11 for ROs or 10 for SRO-Is, which it should.]
5 Is JPM b S2 administered in simulator?
Doesnt say so.
Action: ES301-2 has been updated to have S2 completed in the simulator.
6 JPM d S4 sounds very similar to scenario 2 event 4.
Action: ES301-2 has been updated with new safety function 4 JPM.
[NRC: S4 explanation is still titled Reset FCV runback 2016 audit, and old K/A]
7 JPM S6 Is there discriminatory value to this JPM as an evaluation tool beyond the manual SCRAMs performed in the scenarios?
The manual scram performed in the scenarios will be performed using the mode switch. This JPM requires the operation of the RPS manual scram pushbuttons that are only used when the mode switch fails to operate.
8 JPM P2 specify what component E51-F063 is.
Action: ES301-2 has been updated with proper noun name.
9 Should JPM g be categorized as Low Power/Shutdown L?
Action: ES301-2 has been updated with Low Power designation.
10 SRO-Is are slated to have only 4 alternate path JPMs, which is the minimum (4-6). Prefer that they have 5 for margin. Recommend SRO-Is perform JPM a S1, and a different JPM be RO-only.
Action: ES301-2 has been updated with designating S6 as the RO only JPM. This allows the SRO-Is to have 5 alternate path JPMs.
11 JPM f S6 title should be Manual Scram Pushbutton Monthly Surveillance Action: ES301-2 has been updated with the proper title.
12 What is M in JPM S5 type code?
OBDI 202 - IOLE Process Rev 3 Simulator Scenario Outline Explanations Scenario 1 Explanation Resolution 1
GENERIC TO ALL: Make the D-1 Event Description on 1st page more succinct -
should be a quick reference. Move the detailed information into the Scenario Activities page, which is typically more narrative in nature.
Example: Scen 1 Event 2: LPRM 06-15D fails upscale / Half SCRAM.
Action: D-1s for all scenarios have been updated.
[NRC: Place initial conditions on 1st page]
[NRC: ALL and CREW are being used interchangeably. Use ALL]
2 GENERIC: For all credits given to the board operators, the CRS gets credit too. E.g. C (BOP / CRS), I (ALL), N (ATC / CRS).
Action: D-1s have been updated to include CRS credit for all events.
3 Event 3 is credited as both C and R for the ATC, which is not allowed - can only be credited as one or the other for a given operator. Is the C supposed to be credited to the BOP?
Action: Removed R from ATC for event 3.
Explanation: The BOP is supposed to get credit as well. The BOP will have separate verifiable actions on his panel.
4 Event 1, specify what E51-F064 is. Is it required to be closed because of the failure of the auto isolation, or is it expected to be manually closed?
Specify the TS Condition entered.
Action: D-1 has been updated to include valve number and noun name. E51-F064, RCIC STEAM SUPPLY OUTBD ISOL
- VALVE, 5
Event 4, D1 uses terminology NNS-SWGR1A, Activity Summary uses E22-S004. Use consistent terminology.
Summary also states that CRS references 5 TS LCOs - specify that he only enters 1 (3.8.9) if that is correct, and specify the condition (A/B/etc).
Action: Changed D-1 to be consistent (E22-S004).
6 Event 6: to clarify, available high pressure injection sources will not be able to maintain RPV level > -187?
Action: Added more details to outline scenario activities 7 Event 7/8 CT: Specify what quantitative restored level satisfies the CT.
Action: Changed CT-2 to include RWL to be restored above TAF (-162 inches)
Scenario 2 Explanation Resolution 1
Event 1 - Specify it is HPCS CST level(?) instrument. Specify instrument
- . Is an auto swap supposed to occur normally?
Action: Added designated failed instrument to D-1.
2 Event 2 - what is cause of degraded Explanation: Air in-leakage is the cause of
OBDI 202 - IOLE Process Rev 3 vacuum? Loss of Circ Pump? If so phrase event as Circ Water Pump #
trips. Condenser degraded vacuum.
the degraded vacuum.
3 Event 3 - Specify what RMS-RE13A is.
Specify what HVC-AOD51A is.
Action: Added both to D-1 descriptions.
4 Event 4 - Specify which Recirc FCV.
Action: Designated B Recirc FCV.
[NRC: D1 and summary say A Recirc FCV]
5 Event 5 - Split into 2 events.
Degraded vacuum is one Abnormal event.
ATWS is a separate major event.
Specify what relays / components fail to deenergize causing the ATWS.
Is there a success path to get all rods inserted?
Action: Split the events.
The success path will be to remove fuses per EOP-5 Enclosure 10 Action: Added components to the outline
[NRC: Credit event 5 also as a Component malfunction]
ATWS CT - Specify what Level/Power conditions are.
Action: Added to outline for CT-1.
So all 4 conditions need to be met to fail the CT correct?
7 Event 6 and 7 - Narrative says triggered by lead examiner, that doesnt sound correct.
Specify SLC pump designators.
Action: Changed to:
Triggered by operator action to start the first SLC pump
[Event 7 still says triggered by lead examiner. Events 6, 7 and 8 should say Initial Setup - Automatic.
Still didnt specify SLC pump alpha-numeric designators]
8 Give Critical Tasks designators - CT-1, CT-2, CT-3. [GENERIC]
Action: Added to outline 9
Event 6 CT - where does 5 psig LP hood come from as a bounding limit?
What is design pressure of turbine exhaust hood diaphragm?
Explanation: If pressure builds up inside the LP exhaust hood to about 5 psig, the blowout diaphragm is pushed outward sufficiently for a knife to penetrate the diaphragm causing it to rupture.(STM-110)(primary system steam release outside of containment)
OBDI 202 - IOLE Process Rev 3 Scenario 3 Explanation Resolution 1
Include examiner reference for MSOTs at end of D-2 guide, see attached.
Action: the D-2 guide will contain the MSOTs.
2 On a recent BWR-5 exam, we used the following CTs for a primary system discharging into Containment. Explain how BWR-6 procedure structure differs for SCRAM and ED requirements, allowing for looser CT bounding criteria. The RBS safety significance explanation sounds like it should be the same, i.e. SCRAM before ANY area reaches MSOT :
OBDI 202 - IOLE Process Rev 3 Action: Changed wording of CT-1 to any area.
[Specify how many SRVs must be opened to satisfy ED CT]
OBDI 202 - IOLE Process Rev 3 Scenario 4 Explanation Resolution Scenario 4 has been replaced with a new low power scenario.
1 Event 5 use NJS-SWG1A for consistency w/ event 6.
No change. These are two different buses in events 5 and 6.
2 Event 6: 2nd loss of all feed on this exam as an initiating Major event. Not a good practice.
3 CT-2: We want to ensure the crews are at relatively equal starting points relative to level for this CT. Meaning that if one crew enters alternate level control much later than another, level will be much lower than the other and therefore closer to a CT failure. Lets consider how to tie RCIC reset to time after request.
Similar Explanation for scenario 5 event 9 CT.
Will work on this during validation prior to prep week.
4 New Scenario 4: Initial conditions start at LESS than 5% power. Something low enough that we dont make a MODE change in event 1.
5 Event 6 is a component malfunction, Event 7 is a Major Event.
6 Events 8 and 9, specify the alpha-numeric designators of the components that fail. This is needed for reference in any write-ups for clarity. True for any event.
7 CT-1, 15 minutes to press ARI PBs seems excessive. Basis for 15 minutes?
8 CT-2, Specify criteria requiring ED.
Scenario 5 Explanation Resolution 1
Refer to the EDGs using the same nomenclature - Div 1 DG or DG 1A, dont alternate.
Action: Changed in outline 2
To clarify, DG 1A is inoperable due to fuel lube oil leak in event 3 but it is required to satisfy CT in event 8? Is it Action: DG-1A inop but available, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore lube oil level. Changed the cue to report low oil level, but no oil on the floor.
OBDI 202 - IOLE Process Rev 3 reasonable that crew may prevent DG 1A from starting in Event 3 due to fuel oil on floor? Seems tricky.
Tech spec has a lower level to declare the diesel generator INOP, the level will not be that low.
[Please clarify, Event description says TS 3.8.3.B will be entered due to LO < 367 gal]
3 What is the purpose of the RCIC steam leak if it is automatically isolated when DG 1A started - purpose is to bound the time required to start DG?
Action: Yes bounding of the CT and to restore one division of all safety related equipment for plant shut down and cool down.
4 Event 1 - are there any crew actions beyond lowering power, any components manipulated? If not, then this is really a reactivity event not a component malfunction. Dont want 2 reactivity credits in a single scenario.
Replace with true ATC component malfunction if thats the case.
Action: Changed the event to require the crew to swap to the standby pump and no power reduction is needed. Only take credit for the component mafunction 5
Event 7 sounds like 2 separate events -
LOOP/SBO, and RCIC Steam Leak.
Since there are no manual actions required for RCIC steam leak, still list it as a separate event but dont credit as a bean.
Action: Updated the D-1 to separate events.
6 CT#1 - what is basis for 15 minute time frame to start EDG? Sounds like MSOT is a more relevant bounding criteria based on the explanation.
Action: The 15 minute time frame is due to EAL escalation criteria for loss of offsite power. MSOT does not apply in this case only one area is affected by the steam leak which would drive the crew to scram which has already occurred due to the loss of power.
7 CT-2: Specify what level satisfies restore RPV level. Specify ED criteria on level.
8 CT-2: We want to ensure the crews are at relatively equal starting points relative to level for this CT. Meaning that if one crew enters alternate level control much later than another, level will be much lower than the other and therefore closer to a CT failure. Lets consider how to tie breaker reset to time after request.
GENERIC:
There is no low power scenario in this package. NUREG 1021 states that scenario packages should include a variety of operating conditions to include low power / startup.
Modify one of the scenarios to be low power i.e. 5% or lower power.
Action: Scenario 4 has been replaced with a new low power scenario.
OBDI 202 - IOLE Process Rev 3 There are two Loss of Feed major events in this package. Seems unnecessary given the range of initiating major events available. Replace major event or justify why sufficiently different to remain.
Include a similar reference page as that below for all scenarios in which MSOT is a consideration.
Action: MSOT table will be included in the D-2 as applicable.