ML19217A294
| ML19217A294 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/20/2019 |
| From: | Greg Werner Operations Branch IV |
| To: | Vistra Energy |
| References | |
| 50-445/19-06, 50-446/19-06 50-445/OL-19, 50-446/OL-19 | |
| Download: ML19217A294 (7) | |
Text
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Written Exam Outline Comment Resolution 1
Note - NRC generated RO and SRO written exam outlines and were provided to CPNPP as Rev 0. Rev 1 was issued by CP prior to integrated outline submittal that corrected several administrative errors.
N/A 2 RO Form ES-401-2: For Q17 (T1/G1, p. 2), the K/A is G2.1.20, not G.1.20 (error on outline provided to CP).
Will CorrectES-401-2 for RO will now be on Rev. 3 3
RO Form ES-401-2: For Q27 (T1/G1, APE 77, p. 3), the K/A (G2.4.11) is not included in the list of allowable T1 and T2 generic K/As - resample to an allowable G2.4 K/A. (error on outline provided to CP). Note - SRO Q80 is for APE 77 with K/A of G2.2.40.
Will randomly resample a Generic 2.4 K/A listed in NUREG-1021, ES-401, Section D.1.b 4
RO Form ES-401-4: For Q14, EK1 is Natural circulation and cooling, including reflux boiling so it isnt strictly reflux boiling.
Discuss basis for rejection in more detail with Chief Examiner to ensure the justification on the 401-4 is accurate. The EK1 is included in the KA catalog under EPE 011, LBLOCA, so is it applicable to CP?
What is the training material (or other ref materials) at CP that covers core cooling during LBLOCA? What training material is available for discussion of reflux boiling (regardless of EPE/APE or system)?
During a LBLOCA there is no natural circulation, natural circulation cooling, and minor reflux boiling may occur but is not credited as a source of core cooling. The cooling medium credited during a LBLOCA is forced cooling flow from the ECCS system injecting to the RCS. The RCS will depressurize with only the static pressure of the pumps injecting. The SGs will de-couple and will be unable to provide cooling medium without water in the U-tubes. As water is injected to the core it will create steam which will then flow back out of the break, some may flow to the SGs and then back down the Hot Leg to the core but not enough to credit for core cooling. Our Accident Analysis training material supports this, see: Lesson Plan and Notes for Transient Accident Analysis LO21.MCO.TAA Will update ES-401-4 to state that it is not a concernnot that it doesnt occur
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Written Exam Outline Comment Resolution 5
RO Form ES-401-4: For Q55, briefly explain why G2.1 wasnt resampled before G2.4.
Also for Q55, was it considered that that the purpose or function of a major system or component might be why the EOP contains steps to isolate it? Discuss with Chief if the K/A is an acceptable match for the EPE - then document the result.
Looked at balance of Generic categories sampled on exam. G2.4 had only been sampled 2 times other than the generic K/A questions at the end of the RO exam. Decided to randomly sample a G2.4 in this case to attempt to balance the Generic categories a bit more.
The FRZ-0.2A, Response to Containment Flooding procedure considers sources of water available that could be contributing to containment flooding and isolating those separate systems to stop the flooding. We do not have a separate system that would stop or control containment flooding.
6 RO Form ES-401-4: For Q65, briefly explain why G2.2 wasnt resampled before G2.1.
Also for Q65, ensure the exam reference materials include the list of unit differences (and the list of simulator differences to Unit 1).
Will randomly resample a new G2.2. Erroneously replace the G1.1.28 from Question 55 onto Question 65 7
RO Form ES-401-4: For Q38, are there not contingency procedure steps for failure of an AFW discharge valve to open/fully open or if there is reduced flow from either train (as a result of a discharge valve from fully opening)? Or if AFW flow is operationally controlled or adjusted but a discharge valve fails open/closed/throttled?
Researchingwill resolve by Exam Submittal Date 8
RO Form ES-401-4: For Q48, explain how it was determined that the PZR must be empty with regard to the original K/A.
Due to conditions created by Reflux Boiling it was determined this K/A will be resampled. Will change ES-401-4 to read Could not write a question about PRZR level during reflux boiling due to conditions in the Pressurizer.
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Written Exam Outline Comment Resolution 9
RO Form ES-401-4: For Q75, disagree that a T3 question cant be written about alarm prioritization (white/yellow/red annunciators, plant alarms) in the Emergency Procedures/Plan section.
Depending on site-specific guidance, it could be that its not possible to write a question with sufficient discriminatory value? Discuss with Chief and document the result.
The discriminatory value of this question, a generic question with no reference to any system or specific alarm, would be less than LOD 2.
If I were able to reference specific alarms that had annunciated in the control room and discuss which was of higher priority, this would be sufficient.
Will update ES-401-4 to read Could not write a generic question about alarm prioritization without being alarm/unit specific that is greater than LOD 1
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Administrative JPM Outline Comment Resolution 1
RO Form ES-301-1: Any good Bank JPMs for Emergency Procedures/Plans? This topic was not selected on last two NRC exams - is there any reason to not replace the Rad Con JPM with an EP/P JPM?
Will research this idea some more 2
RA1: Is applicant required to perform more than just obtaining data from table and plugging into a calculation from the SOP? Is there at least one higher cognitive level step?
Applicant is required to obtain the correct data and use the procedure to calculate the correct values 3 RA4 - is applicant required to obtain data from an RWP (and not read from a long list of Initial Conditions)?
Will look at creating an RWP and ask students if they can perform the work based on limits set by Health Physics.
4 SA1 - is it operationally valid to just conduct a medical review of license status? Or is reviewing the medical requirements part of a broader review of eligibility to stand watch?
Also, what is reference procedure? Same as RA2?
JPM involves more than just medical reviewalso includes whether or not an operator can continue license duties 5 SA5 - based on Task Summary, this appears to have LOD < 2 (almost like direct look-up). Discuss details with Chief Examiner.
Will revise ES-301-1 JPM summary to reflect that the examinees will perform the PAR
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Control Room / In-Plant System JPM Outline Comment Resolution 1
S-1: What guidance is used for the applicant to determine the need for a Turbine runback when Heater Drain Pump trips?
Also, submit revised form ES-301-2 with new JPM.
The applicant will use ABN-302, Section 4.0. Initial Operator Action to perform step 1 Will revise ES-301-2 and put procedure in JPM Summary 2 S-1. Is the manual Turbine runback to 700 MWe procedurally driven? How does applicant know how far to runback Turbine?
Yes, per ABN-302 3
S-1: Does the IC include an Annunciator Alarm when the Lo-Lo Rod Insertion Limit is exceeded or does the alarm fail (due to some plausible fault or incorrect alarm setpoint adjustment)? If the alarms occurs, should probably add that to the description as it significantly impacts the JPMs Level of Difficulty (LOD). If alarm occurs, consider failing alarm for increase in LOD.
Yes, there is an alarm.
Alarm failure considered Will add the alarm to the ES-301-2 JPM summary 4 S-2: Will securing 1 of 4 ECCS pumps eliminate indications of RHR pump cavitation on the simulator?
Yes 5
S-3: How long (minutes, seconds) before auto reactor trip following partial opening of PORV 456 (applicant response time)?
Will run this JPM and find a good place to fail PORV for candidates to have enough time to react but not too much time where no prudent action is required (30-60 seconds would be appropriate) 6 S-3: Does the JPM include a test of 8000A (with no issues or faults)?
Yes 7 S-4: Are there any time requirements associated with tripping the reactor or stopping RCPs? If so, are they Time Critical?
No 8
S-4: Since there is a total loss of SSW, are both EDGs affected requiring both to be placed in Pull-Out?
No, other train SSW pump remains running Will identify Standby CCW Pump 1-02 and DG 1-01 on ES-301-2 JPM Summary (vice using terms affected and unaffected)
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Control Room / In-Plant System JPM Outline Comment Resolution 9
S-8: What does DRMS stand for (Alarm Procedure DRMS)? Does this JPM qualify as an Engineered Safety Feature (EN)?
Digital Radiation Monitoring System Will update ES-301-2 JPM Summary to explain that a CVI should have automatically occurred and did not 10 P-1: What is the physical separation of the two valves?
Separate Rooms Will add procedure to the ES-301-2 JPM Summary Description 11 P-2: What is the physical separation of the three valves? Is operation of the hand switches identical?
Will look at adding some breakers or valves to JPM in a different location to ensure JPM is of proper discriminatory value
PROPOSED OUTLINE COMMENTS Rev 1 Facility:
CPNPP Date: 1-22-2019 First Exam Date:
6-10-2019 OBDI 202 - IOLE Process Form Rev 3-btl Simulator Scenario Outline Comments Comment Resolution 1
Scenario 1: Not acceptable for a scenario to be comprised of all Component failures. Each scenario should consistent of at least one Instrument failure, preferably two per scenario. Discuss NUREG-1021 guidance with Chief Examiner.
Will replace a Component Malfunction with an Instrument Malfunction.
2 Scenario 1: What are 3 malfunctions after EOP entry? See Target Quantitative Attributes table.
Will update Quantitative Attributes to 2 malfunctions after EOP entry 3
Scenario 1, Event 8: How does this event influence the operators choice of mitigation strategy? (Appendix D, C.2.c, Malfunctions after EOP Entry)
Chief Examiner is researching this topic 4
With respect to industry OE, isnt the scenario set rather light on electrical events? (only 1 event in all 4 scenarios - Scenario 1, Event 2 - Loss of 6.9 KV Transformer).
When combined with non-AP Sim JPM (S-5), the overall op test doesnt appear to be balanced with respect to electrical malfunctions/transients. [No failure of EDGs to auto start or auto load onto their bus or trip after loading, no degraded bus voltages/frequencies, no electrical bus fires or loss of buses that impact future events] Discuss opportunities to incorporate more industry OE electrical-related events prior to submittal of proposed op test with Chief Examiner.
Will attempt to work in the CPNPP cut cable event on scenario 4 as a use of Site OE and to add an electrical event to the scenario landscape.