ML19241A464
| ML19241A464 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 12/06/2018 |
| From: | Joseph Demarshall Nuclear Management Co |
| To: | NRC/RGN-III/DRS/OLB |
| Demarshall J | |
| Shared Package | |
| ML17164A416 | List: |
| References | |
| Download: ML19241A464 (16) | |
Text
Monticello 2018 Initial License Exam Outline Review Comments 1
Simulator Scenario Outline Comments General Comments:
o NRC: There is no low power scenario (defined as criticality to 5% power). The lowest initial condition is a power ascension commencing at 17% in Scenario #2.
(Information only comment; a low power scenario is desirable but not mandatory per ES-301).
MNGP: Licensee is aware of the desire for a lower power scenario. A lower power scenario generally would not allow for the required malfunctions with verifiable actions for an initial exam.
NRC comment information only.
o NRC: Scenario 1, Event 2, Inward Rod Drift, credits the OATC with both a reactivity manipulation and a component failure. Additional information needed to determine whether it would be acceptable to count this event failure twice for the OATC (i.e.,
plant response to the Inward Rod Drift, nature of the reactivity manipulation, etc).
Potential impact to ES-301-5 minimum count totals for applicants evaluated as the OATC in NRC Scenario #1.
MNGP: The initial action required for the inward rod drift is to deenergize rod control power. This action will fail to stop the drift which will require the OATC to select the drifting rod and drive it full in. If the OATC fails to drive the rod in manually, it will stop at notch position 20 resulting in uneven flux distribution; therefore a reactivity manipulation is required. Driving the rod full in results in a power reduction of 3-5%.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to credit the Inward Rod Drift event as a Component Failure only, and to separately provide a new event for Reactivity.
[7/9/2018 - Scenario #1 Outline and associated ES-301-5 forms appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Scenario 1, Event 5, Loss of power to the only available CRD Pump, requires the crew to insert a Manual Scram. Is the Manual Scram required/driven by TS (e.g., Reactivity Control Systems TS 3.1.5, Control Rod Scram Accumulators)? If so, the associated TS would need to be specified on the D-1 for this event.
MNGP: The manual scram is directed by the abnormal procedure for a loss of CRD flow. The concern is the inability to maintain the accumulators charged which may result in control rods not inserting into the core at the required scram rate or not at all. There are no Tech Specs directly associated with a loss of CRD Pumps Discussed comment with MNGP on 5/31/2018. The resultant condition (loss of both CRD Pumps and 0 psig charging header pressure), results in a TS required action to place the Mode Switch in S/D if Charging Header Pressure not restored to 940 psig within 20 minutes (TS 3.1.5, Condition B). MNGP explained that it will be evident to the crew at the onset that pump restoration will not be timely and that the
Monticello 2018 Initial License Exam Outline Review Comments 2
crew will take prompt action IAW the Abnormal Procedure to place the Mode Switch in S/D upon loss of the remaining pump prior to evaluating TSs.
[NRC comment sufficiently addressed.]
o NRC: Scenario 1, Event 6, assigns Event Types C and M to the crew. The crew verifiable actions (i.e., use of steam driven pumps for RPV injection) for the trip of all Reactor Feed Pumps (RFPs), a concurrent/post EOP entry component failure identified in Event 6, are not clearly understood based on the following:
It is assumed that the verifiable action pertaining to the use of steam driven pumps (based on the Event 6 Description), intends the use of HPCI and RCIC to mitigate the trip of all RFPs, however:
(a) the Manual initiation of HPCI scripted for the OATC in Event 7, appears to be a separate verifiable action intended to specifically address only the post EOP entry component failure of HPCI to auto initiate on Hi DW Pressure, and (b) RCIC was previously removed from service in Event 4 due to inadvertent initiation and injection.
Note that the Event 6 crew component failure is only specified in the ES-301-5 blocks that correspond to component failure (I/C) for the SRO Instant positions of Scenario 1. Additional information is needed to understand what crew verifiable actions, if any, are being credited for the trip of all RPFs component failure listed in Event 6, concurrent with the major.
MNGP: The C - Crew for Event 6 may be removed from the D-1 and ES-301-5.
There are no verifiable actions for the trip of the RFPs. Verifiable actions may be taken by the crew for the LOCA (Torus Sprays, DW Cooling), however, they may not be taken if the crew prioritizes RPV water level.
Discussed comment with MNGP on 5/31/2018. MNGP confirmed that there are no verifiable actions associated with the trip of RFPs and agreed to make the necessary changes.
[7/9/2018 - Scenario #1 Outline and associated ES-301-5 forms appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Scenario 1, Events 6 and 7, both list Major for the Event Type. It appears that the Major Event would actually be the Event 6 LOCA, and that Event 7 is a stand-alone post EOP entry component failure (HPCI failure to auto initiate on Hi DW Pressure) for the OATC. Note that the D-1 for Scenario 1 assigns an M to the crew for Event 7 in the Event Type column, but Form ES-301-5 does not specify Event 7 in the blocks corresponding to the Major for any of the crew positions.
Only Event 6 has been specified in the ES-301-5 blocks that correspond to the Major for the crew positions in Scenario 1. Note also that Event 7 has been correctly specified for the OATC position in the ES-301-5 blocks that correspond to component failure (I/C) in Scenario 1.
Monticello 2018 Initial License Exam Outline Review Comments 3
MNGP: The M - Crew may be removed from Event 7.
Discussed comment with MNGP on 5/31/2018. MNGP concurred that the Event 6 LOCA was the Major transient and agreed to revise the D-1 accordingly.
[7/9/2018 - Scenario #1 Outline and associated ES-301-5 forms appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Scenario 1, Event 7, Manual initiation of HPCI after failure to automatically initiate on high DW Pressure, assigns the credit for this post major transient component failure to the OATC. Does the OATC typically operate HPCI/RCIC during LOCA scenarios?
MNGP: The OATC is typically assigned RPV water level control and the BOP is typically assigned control of containment parameters. It is expected that the OATC will be assigned to initiate HPCI.
Discussed comment with MNGP on 5/31/2018. MNGP provided the necessary clarification.
[NRC comment sufficiently addressed.]
o NRC: Scenarios 1 and 2, Events 1 and 6 respectively, both require the BOP to manually start the standby Service Water Pump, albeit under different circumstances (i.e., pump swap as part of a Normal evolution versus failure of the standby pump to auto start on component failure). Three RO applicants are presently assigned to the BOP position in both Scenarios 1 and 2, as indicated on the ES-301-5, and will see this similar activity twice.
MNGP: The normal evolution requires coordination with the out-plant operator who will manually manipulate valves before and after the pump swap. Additionally, the normal evolution requires the BOP to setup the standby pump for automatic start.
The SW pump trip requires the BOP to manually start the pump as an immediate operator action and enter the abnormal procedure for a loss of service water.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to replace the Scenario 1, Event 1, Service Water Pump swap, with a different evolution/activity (TBD) for the Normal event.
[7/9/2018 - Scenario 1 Outline appropriately revised to address this item; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Scenario 2, Event 4, Leaking Core Spray Valve, event description states Out plant actions will be unsuccessful in stopping the leak and the BOP will isolate A Core Spray. It is unclear what is meant by the term Out plant actions.
MNGP: The outplant operator will be directed by the control room to vent the system. This action will be unsuccessful due to a broken valve stem.
Monticello 2018 Initial License Exam Outline Review Comments 4
Discussed comment with MNGP on 5/31/2018. MNGP provided the necessary clarification.
[NRC comment sufficiently addressed.]
o NRC: Scenario 4, Event 3, Recirc Pump R/B and Scoop Tube failure to lock, event description states: The plant will be in the unanalyzed region of the P-F Map and the OATC will reduce power using control rods to exit. Apparently the unanalyzed region of the P-F Map is the equivalent of an Immediate Exit Region that does not warrant prompt action to insert a Manual Scram. Additional information needed regarding use of the term unanalyzed region as it relates to the immediacy of operator actions to promptly shutdown the reactor. If a crew were to insert a Manual Scram upon entry into the unanalyzed region of the P-F Map, would that course of action be entirely unexpected? Is Region 2 of the P-F Map also considered to be an unanalyzed region?
MNGP: The unanalyzed region is an immediate exit region that does not require a manual scram. It would be unexpected if the crew were to insert a manual scram. If the OPRMs are operable, which they are, the procedure directs a power reduction to exit the Unanalyzed Region. Region 2 operation would be allowed by the procedure as it is not a part of the unanalyzed region.
Discussed comment with MNGP on 5/31/2018. MNGP provided the necessary clarification, noting that Unanalyzed Region is labeled as such on the Monticello P-F Map.
[NRC comment sufficiently addressed.]
o NRC: Scenario 4, Event 7, SDV Vent & Drain Valves failure to close on the Scram/rising radiation levels, is designated as the Major. The D-1 Event Description for the post EOP entry component failure (Event 8), describes the action to be taken by the OATC to attempt a reset of the Scram in an effort to isolate the SDV. However, the D-1 assigns this Event 8 verifiable action to the crew instead of the OATC. Additional information is needed to understand what crew verifiable actions, other than those described for the OATC, are being credited for Event 8.
Also, Event 8 has not been listed anywhere on Form ES-301-5 for Scenario 4.
Further, the Event 8 post EOP entry malfunction is directly associated with a mitigative strategy that the crew would normally be expected to implement in response to the Major; it does not test the crews ability to separately recognize/diagnose and respond to a malfunction that meets the intent of the Malfunctions after EOP entry Target Attribute per Scenario metric specified in NUREG-1021.
MNGP: The Post malfunction is designated as Crew because several actions will be taken. The OATC will first attempt to isolate the SDV, and then try to reset the scram; both will be unsuccessful. The CRS will anticipate a blowdown and direct the BOP to open the Bypass Valves to depressurize the RPV to the main condenser.
This action will be successful and slow the rate of the rising radiation levels but eventually blowdown will still be required. This major transient and post malfunction
Monticello 2018 Initial License Exam Outline Review Comments 5
were approved by NRC Region 3 and used for the 2015 NRC Exam. Event 8 is listed for the SRO on the ES-301-5 for Scenario 4.
Discussed comment with MNGP on 5/31/2018. The CE noted: (1) that Event 8 is NOT listed on the ES-301-5 that was delivered to the NRC, and (2) that the post EOP entry malfunction on the 2015 Exam was not listed as a failure of the Scram to reset, but rather a failure of 2 out of 3 ADS valves to open for the ED. MNGP agreed to replace the post EOP entry malfunction.
[7/9/2018 - Scenario #4 Outline and associated ES-301-5 forms appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Form ES-301-5 for Scenario 4 incorrectly specifies: (a) Event 1 as a BOP I/C Event Type (in addition to Event 2), and (b) Event 3 as an Instant SRO I/C Event Type. Also, the D-1 for Scenario 4, Event 4, specifies an Instrument rather than a Component Failure. Additional clarification needed to understand why Event 4 would be an Instrument vice Component Failure.
MNGP: Event 1 should not be a BOP I/C for Scenario 4 (typo). Event 3 should not be an SRO I/C for Scenario 4 (typo). Event 4 should be labeled as a component failure (typo).
Discussed comment with MNGP on 5/31/2018. MNGP agreed to make the necessary changes.
[7/9/2018 - Scenario #4 Outline and associated ES-301-5 forms appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o
Monticello 2018 Initial License Exam Outline Review Comments 6
o o NRC: The Total Numbers exactly match the Minimum requirements for each evolution, failure, and transient on the ES-301-5 for one of the Crew 2 ROs and the one Crew 4 RO. In addition, the Crew 3 SRO-I has what appears to be an unusually high Count Total for the I/C Event Type (i.e., 12) compared to the SRO Instants on the other crews. It may be necessary to run the Spare scenario in order to meet the Minimum requirements of ES 301-5 for the two ROs if the scenarios dont run exactly as scripted.
MNGP: The crew 3 SRO with the 12 I/Cs is completely coincidental based on the fact they are in the SRO position for two of the heavier loaded scenarios.
Additionally, the two ROs with minimum I/Cs is also coincidental. The large and diverse class makeup requiring multiple crew alignments will inevitably result in these requirement numbers.
Discussed comment with MNGP on 5/31/2018. Considered potential impacts to the exam schedule resulting from the need to run a spare scenario.
[NRC comment sufficiently addressed.]
Potential Duplication/Overlap Concerns (additional detail / information needed from Licensee to support NRC review and determination of acceptability):
Monticello 2018 Initial License Exam Outline Review Comments 7
o NRC: 2018 NRC Exam Scenario 1 and 2015 NRC Exam Scenario 4 both have major transients involving a LOCA with ED required, where HPCI was manually initiated and subsequently trips on high exhaust pressure.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to either trip HPCI on something other than high exhaust pressure (e.g., overspeed, control oil leak, etc) or prevent HPCI from starting altogether, and to include an additional post EOP entry malfunction (Core Spray Pump fails to Auto start on high DW pressure).
[7/9/2018 - Scenario #1 Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o o NRC: 2018 NRC Exam Scenario 3 and 2015 NRC Exam Scenario 3 both have major transients involving an ATWS followed by the failure of the first SBLC to start.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to modify the post EOP entry malfunction (i.e., Failure of RWCU valves to isolate on SBLC initiation).
[7/9/2018 - Scenario #3 Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: 2018 NRC Exam Scenario 4 and 2015 NRC Exam Scenario 2 both have major transients in which a failure of the SDV Vent & Drain Valves to close following a Scram results in radiation levels reaching Max Safe Rad values in two areas of Secondary Containment, requiring the crew to ED.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to replace the post EOP entry malfunction with failure of the STBY Gas Treatment System to start on Hi Rad Levels in Secondary Containment.
[7/9/2018 - Scenario #4 Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o
Monticello 2018 Initial License Exam Outline Review Comments 8
o
Monticello 2018 Initial License Exam Outline Review Comments 9
JPM Outline Comments General Comments:
o NRC: With respect to the Control Room / In-Plant Systems JPMs, it appears that the last time Safety Function (SF) #8, Plant Service Systems, was tested was on the 2009 NRC Exam, which means that SF #8 will not have been tested for five consecutive NRC Exams dating back to 2009 (i.e., 2018, 2016, 2015, 2013 and 2010 exams).
MNGP: There are minimal topics in Safety Function 8 (Four). Safety function 8 was used on the 2015 Audit Exam. For the 2018 NRC Exam, Safety Function 8 was not used based on overlap concerns with written questions and scenario events.
Discussed comment with MNGP on 5/31/2018. MNGP agreed to replace In-Plant JPM k with a SF #8 JPM.
[7/9/2018 - JPM Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: ES-301-2 for the SRO-U applicants uses SF #5 twice; once in the Control Room Systems section and once in the In-Plant Systems section of the outline. The five systems and evolutions selected for an SRO-U applicant should evaluate at least five different safety functions. Note that replacement of one of the two SF #5 JPMs (i.e., JPM D or JPM J) will impact the minimum outline criteria specified for Type Code EN (JPM D) or Type Code E (JPM J).
MNGP: The use of SF #5 twice for the SRO-U was overlooked as it is allowed for the SRO-I. Propose that the SRO-U receive JPMs - C, E, F, I and J. JPM-C should be labeled as an EN as described below, thus the SRO-U will meet all the requirements of ES-301-2.
Discussed comment with MNGP on 5/31/2018. MNGP proposal determined to be acceptable.
[7/9/2018 - JPM Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: Control Room Systems JPM C, Manual Switchover of HPCI Suction from Torus, was used on the 2016 NRC Exam (labeled JPM D) and has been identified as a previous 2 exams JPM. Although the associated JPM number (JPM-B.03.02-005) is the same, and the task appears to be the same or similar for both JPMs, the SFs listed on the 2016 (SF #4) and 2018 (SF #2) NRC Exams are different. In addition, Type Code EN, previously assigned to JPM D on the 2016 NRC Exam, has not been assigned to JPM C on the 2018 NRC Exam. If the SF for JPM C has not been correctly assigned, then the potential exists for the same SF (i.e., SF #4) to be evaluated twice in the Control Room Systems section of the ES-301-2 outline.
MNGP: The task being performed for this JPM is covered under K/A 206000 A4.04 (Ability to manually operate and/or monitor in the control room: Major System Valves). This K/A is listed for Safety Function 2 (Reactor Water Inventory Control)
Monticello 2018 Initial License Exam Outline Review Comments 10 and also for Safety Function 4 (Heat Removal from Reactor Core). JPM E (Place Shutdown Cooling in Service) for the 2018 NRC Exam is appropriate for Safety Function 4 and doesnt overlap with JPM C (Manual Switchover of HPCI Suction from Torus to CSTs). JPM C, however, should be labeled with a Type Code EN as it was for the 2016 NRC Exam (typo).
Discussed comment with MNGP on 5/31/2018. MNGP explanation determined to be acceptable.
[7/9/2018 - JPM Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
Potential Duplication/Overlap Concerns (additional detail / information needed from Licensee to support NRC review and determination of acceptability):
o NRC: Control Room Systems JPM D, Manually Insert a Group 3 Isolation, appears similar to JPM E, Manually Insert Group 5 Isolation, on the 2016 NRC Exam, and may be a candidate for the previous 2 exams classification, although not designated as such (would cause the previous 2 exams Control Room/In-Plant Systems Outline metric to be exceeded for the RO and SRO-I exam levels).
Appears that the only difference between these two JPMs is in the Group Number, and that the actions to manually insert a Group Isolation may be the same or similar, irrespective of the Group to be isolated. A change in the Group Number alone would not satisfy the significant modification criteria for JPMs.
MNGP: The five different Group isolations at MNGP all involve isolating different valves on different systems. In this case, inserting a Group 3 Isolation means manually closing the valves for the RWCU System and a inserting a Group 5 Isolation means manually closing the valves for the RCIC System. These are completely different JPMs on different systems that close different valves.
Discussed comment with MNGP on 5/31/2018. MNGP explained that the actions to manually insert a Group Isolation require the applicant to manually close the isolation valves for different systems depending on the individual Group assignments. MNGP explanation determined to be acceptable.
[NRC comment sufficiently addressed.]
o NRC: RO Admin Conduct of Operations (#2) JPM, Overtime Restrictions / Fatigue Management, appears to be similar in task (based on title) to the corresponding JPM on the 2015 NRC Exam (would cause the previous 2 exams overlap metric for the RO license level to be exceeded).
MNGP: Admin #2 (JPM-FP-S-FMP-01-002) is the same task that was used for the 2015 NRC Exam (JPM-FP-S-FMP-01-001) however; the critical steps in the 2018 JPM have been revised such that examinee must interpret different overtime days worked to determine that the 10CFR limits will be exceeded. The JPM is Significantly Modified.
Monticello 2018 Initial License Exam Outline Review Comments 11 Discussed comment with MNGP on 5/31/2018. The proposed JPM is NOT designated as (N)ew or (M)odified on the ES-301-1 (designated as R,D). MNGP agreed to replace the JPM.
[7/9/2018 - JPM Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: SRO Admin Radiation Control JPM, SRO Emergency Exposure Control, appears to be a similar in task (based on title) to the corresponding JPM on the 2015 NRC Exam (would cause the previous 2 exams overlap metric for the SRO license level to be exceeded).
MNGP: SRO Emergency Exposure Control (JPM-A.2-401-003) is the same task that was used for the 2016 NRC Exam (JPM-A.2-401-002) however; the critical steps in the 2018 JPM have been revised such that the examinee must interpret different exposure levels. The JPM is Significantly Modified.
Discussed comment with MNGP on 5/31/2018. The proposed JPM is designated as (N)ew on the ES-301-1 (i.e., R,N), rather than (M)odified. In addition, the JPM is designated as (R,N) on the 2015 Exam (Not the 2016 Exam as indicated above).
The JPM also uses the same K/A for the 2018, 2016, and 2015 Exams. MNGP agreed to replace the JPM.
[7/9/2018 - JPM Outline appropriately revised; changes confirmed. NRC comment sufficiently addressed.]
o NRC: SRO Admin Emergency Procedures/Plan JPM, EAL Classification, appears to be similar in task (based on title) to the corresponding JPMs on the 2015 and 2016 NRC Exams (would cause the previous 2 exams overlap metric for the SRO license level to be exceeded).
MNGP: Monticello currently has a large variety of EAL JPMs. SRO EAL Classification (JPM-A.2-101-003) is the same task that was used for the 2015 and 2016 NRC Exams, however, the 2018 NRC Exam tests a different EAL classification.
Discussed comment with MNGP on 5/31/2018. Determination of acceptability is contingent upon the actual submittal.
[8/17/2018 - Submittal received on 8/14/2018. CE review determined the SRO Admin Emergency Procedures/Plan EAL Classification JPM to be sufficiently different from the corresponding JPMs on the previous two NRC Exams. NRC comment sufficiently addressed.]
NRC Operating Test Outlines and Audit Operating Test Outlines NRC: Determination of acceptability for the Operating Test Outlines is contingent upon the submittal of Audit Operating Test Outline material for NRC review and evaluation.
Monticello 2018 Initial License Exam Outline Review Comments 12 MNGP: Outlines for the 2018 Audit Exam will be submitted to the NRC once developed.
Incomplete Audit Operating Test Outline materials were submitted on 7/23/2018. While the outlines for the Audit scenarios were complete, the outlines for the Audit Walkthrough were not. The JPM titles for 4 of the 9 Administrative JPMs, and 4 of the 8 Control Room Systems JPMs were not provided. Discussed this issue with MNGP on 7/23/2018 and 8/10/2018. MNGP stated that all outstanding Audit Walkthrough outline material would be provided upon completion, shortly after submittal of the proposed NRC Exam (delivery scheduled for 8/13/2018).
Note: Confirmed no overlap between the information provided in the partially completed Audit Operating Test outlines submitted on 7/23/2018 and the NRC Operating Test outlines.
[8/24/2018 - Finalized Audit Operating Test Outlines received on 8/20/2018. CE review confirmed no overlap between the information provided in the finalized Audit Operating Test Outlines and the NRC Operating Test Outlines.]
Monticello 2018 Initial License Exam Outline Review Comments 13 Written Exam Outline Comments General Comments:
o NRC: The following discrepancies were noted during review of the Written Exam Outline:
Question 25: Editorial error in the EPE stem statement description; should be RADIATION LEVELS, not RADIATION LIMITS.
MNGP: Agree.
Discussed comment with MNGP on 5/31/2018. MNGP will update the outline as indicated.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 26: Importance Rating (IR) should be 3.8 for RO, not 4.2.
MNGP: Agree Discussed comment with MNGP on 5/31/2018. MNGP will update the outline as indicated.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 43: K5.05 does not pertain to Flow controllers, but rather Moisture Carryunder with an IR of 2.3.
MNGP: It is unclear where Flow Controllers and the low IR originated from.
Discussed comment with MNGP on 5/31/2018. The CE determined that the origin of the selected K/A was from the Reactor Water Cleanup System vice the Reactor Water Level Control System. This was confirmed by (1) RWCU K5.05 specifies Flow controllers, (2) K5.05 Importance Rating is 2.6, and (3) the fact that the RWCU System immediately precedes the RWLC System section in the BWR K/A Catalog. The CE approved the random selection of K/A K5.01 from the Reactor Water Level Control System section (259002) of the K/A Catalog. MNGP will update the outline accordingly.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 63: CFR reference was not provided for the K/A; should be 41.7.
MNGP: Agree
Monticello 2018 Initial License Exam Outline Review Comments 14 Discussed comment with MNGP on 5/31/2018. MNGP will update the outline as indicated.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 76: CFR reference is incorrect; should be 41.10 / 43.5 / 45.13.
The CFR currently referenced is associated with the A1 topic and not A2.
MNGP: Agree Discussed comment with MNGP on 5/31/2018. MNGP will update the outline as indicated.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 91: Editorial error in the A1 column; should be 03 instead of 01 (K/A is A1.03).
MNGP: Agree Discussed comment with MNGP on 5/31/2018. MNGP will update the outline as indicated.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Question 98: K/A selection is not linked to 10 CFR 55.43 as required by Note 9 on the Cover Page of Form ES-401-1.
MNGP: Agree. This is allowed IAW NUREG-1021 ES-401 (A question at the SRO-only level should test one (or more) of the seven items listed under 10 CFR 55.43(b) that the K/A is linked to, or it should test at a level that is unique to the SRO job position as determined from the facilities learning objectives. The fact that a particular K/A does not reference 10 CFR 55.41 or 10 CFR 55.43 does not, in and of itself, disqualify the K/A from testing on the RO or SRO written exam). The current question written meets these requirements.
Discussed comment with MNGP on 5/31/2018. The CE explained that the cited text from NUREG-1021 was applicable to RO/SRO Tiers 1/ 2, and also to RO Tier 3, but not for SRO Tier 3. The CE randomly selected K/A 2.3.11 as a suitable replacement for Question #98. MNGP will update the outline accordingly.
[7/9/2018 -Written Exam Outline appropriately revised; changes confirmed.
NRC comment sufficiently addressed.]
Monticello 2018 Initial License Exam Outline Review Comments 15 Potential Duplication/Overlap Concerns (additional detail / information needed from Licensee to support NRC review and determination of acceptability):
o NRC: The following potential duplication/overlap items were noted during review of the Written Exam Outline:
Question 78: SRO Exam Question samples the same K/A as RO Exam Question 8.
MNGP: Questions have been identified as having the same K/As and have been written differently to ensure no overlap.
Discussed comment with MNGP on 5/31/2018 and 7/11/2018. MNGP explained that different safety-related instrument air system loads were selected for the two Questions. Questions 8 and 78 were submitted as early review questions for preliminary evaluation on 7/23/2018.
[7/23/2018 - CE review determined Questions 8 and 78 to be acceptable as written. NRC comment sufficiently addressed.]
Question 100: K/A selection overlaps with SRO Admin Emergency Plan JPM (JPM-A.2-101-003); balance of coverage concern.
MNGP: JPM and Written question examine on completely different EAL classifications. NOTE: Monticello has implemented a new LAR to our EALs that has resulted in significant modification. EAL classifications are being more heavily weighted for this exam ensuring no overlap.
Discussed comment with MNGP on 5/31/2018 and 7/11/2018. MNGP explained that the SRO Admin JPM is a HOT EAL call, whereas Question 100 is a COLD (Mode 5) EAL call.
[NRC comment sufficiently addressed.]
Questions 18 and 23 deal with high offsite release rate, ventilation, and isolations, and are closely related.
MNGP: Questions have been identified as having the similar K/As and have been written differently to ensure no overlap. Control EFT CREF 18 23 rx Bldg & stby gas Discussed comment with MNGP on 5/31/2018 and 7/11/2018. MNGP explained that Question #18 is associated with the Control Room Emergency Filtration Trains, and that Question #23 is associated with the Reactor Building and Standby Gas Treatment System. Questions 18 and 23 were submitted as early review questions for preliminary evaluation on 7/23/2018.
[7/23/2018 - CE review determined Questions 18 and 23 to be acceptable as written. NRC comment sufficiently addressed.]
Monticello 2018 Initial License Exam Outline Review Comments 16 NRC Written Exam Outlines and Audit Written Exam Outlines NRC: The applicant, in Enclosure 11, MNGP 2018 ILT Audit Exam Methodology, of the submittal, states: (1) that the Audit Exam will be developed upon completion of NRC Exam development, (2) that Audit Written Exam development will conform to the same standards established for development of the NRC Written Exam (e.g., Tier/Group requirements, etc), and (3) that NUREG-1021, Revision 11, Section ES-401.C.1.g, fourth bullet, will be followed to ensure that there is no overlap between the Audit and NRC Written Exams.
Determination of acceptability is contingent upon the submittal of Audit Written Exam Outline/Test material for NRC review and evaluation.
o NRC: The Audit Exam Written Outline was submitted on 6/26/2018. The following potential duplication/overlap items were noted during review of the Audit Written Exam Outline.
Question 70: NRC Exam Question 70 and Audit Exam Question 97 both specify Generic K/A 2.2.35 for the Tier 3 Equipment Control category.
MNGP: NRC RO Question 70 is a generic Mode definition question and Audit SRO Question requires the examinee to determine Mode and apply it to Tech Specs and EALs. No overlap concern.
Discussed comment with MNGP on 7/11/2018. MNGP provided the necessary clarification.
[NRC comment sufficiently addressed.]
Question 95: NRC Exam Question 95 and Audit Exam Question 68 both specify Generic K/A 2.1.45 for the Tier 3 Conduct of Operations category.
MNGP: NRC SRO Exam question 95 is related to SRV Tech Specs and Audit Exam question 68 is not written yet. The 2.1.45 K/A (Ability to identify and interpret diverse indications to validate the response of another indication) is a broad K/A that can be used for almost every system in the plant. Question overlap is low risk Discussed comment with MNGP on 7/11/2018. Comparison between NRC and Audit Written Exam Questions will be required in order to confirm no duplication/overlap.
[8/24/2018 - Audit Written Exam Test material received on 8/20/2018. CE review confirmed no overlap between Audit Exam Question 68 and NRC Exam Question 95. NRC comment sufficiently addressed.]