ML19351E241
| ML19351E241 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/29/2019 |
| From: | Chuck Zoia Exelon Generation Co |
| To: | NRC/RGN-III/DRS/OLB |
| Zoia C | |
| Shared Package | |
| ML17164A344 | List: |
| References | |
| Download: ML19351E241 (6) | |
Text
Byron 2019 Initial License Exam Outline Review Comments 1
JPM OUTLINE COMMENTS NRC Comment RA 1.2 How was this JPM modified to be different from 2016 NRC Exam.
RA 2 Similar JPM used on 2014 NRC Exam. How is this JPM different from the 2016 Cert Exam and the 2014 NRC Exam?
RA 4 REPLACE; Fire response procedures are not E-Plan or implementing procedures [ES 301 D.3.a; page 10 of 33]
SA 4 REPLACE; Reportability not E-Plan or implementing procedures [ES 301 D.3.a; page 10 of 33]
b Not listed as previous 2 exams on ES 301-2, but appears to be very similar to NRC 2017 exam Simulator JPM a.
e ES 301-2 lists incorrect K/A for NRC 2019 exam Simulator JPM e, Drain the PRT. K/A should be 007A1.01 (Maintain quench tank water level within limits) per 8/22/18 phone call with CE.
f Recommend replacing JPM as it overlaps with Simulator Scenario 1 Event 1(also prevents loss of Event 4). If scenario is run before JPM it may precondition the BOP applicants for the JPM giving them an advantage. If JPM is run before scenario all applicants will have seen the associated procedure and the event will not provide the necessary discriminatory evaluation of the applicant performance.
Alternatively, replace Scenario 1 Event 1.
j What is the modification? Simply changing the failed valve from 8000A to 8000B may not be significant.
Byron 2019 Initial License Exam Outline Review Comments 2
Simulator Scenario Outline Comments Scenario 1 Overview Recommend changing initiating condition for Event 3 (power increase) to state and the 1B Diesel Generator has been loaded to at least 4100 KW Event 1 Overlaps with Simulator JPM f, Synchronize DG to Bus. See JPM f comment.
Event 8 Since the failure of the 1A DG is contributor/ initiator to the Major Event (Loss of All AC Power), event cannot be credited as a separate component failure.
Event 8 This will be the third exam in a row that has a loss of ALL AC power. How is this event different than the previous two exams?
Scenario 2 Event 6 Evaluate whether taking manual control of Pressurizer Level controller to prevent overfill of pressurizer should be a Critical Task (CT) (i.e. could failure to perform action result in a RPS actuation?)
Scenario 3 General Marginally meets modification requirement (minimum of two events not used on previous two NRC exams). Event 7 may qualify as modified since second MSIV fails to close (this them would be a third event not used on last two NRC exams).
Scenario 4 Event 2 May want ensure that no crew sees both this scenario and Scenario 2. Same level instrument but with failure in opposite direction (high vs low)
Event 2 Evaluate whether taking manual control of Pressurizer Level controller to prevent loss of inventory in pressurizer should be a Critical Task (CT) (i.e.
could failure to perform action result in a RPS actuation?)
Event 3 Evaluate whether taking manual control of SG PORV to prevent depressurization of SG should be a Critical Task (CT) (i.e. could failure to perform action result in a RPS or ESF actuation?)
Event 3 Overview discussion lists the incorrect TS (3.4.4 vs. 3.7.4) for failed open SG PORV Scenario 5 Event 5 Evaluate whether taking manual control of Pressurizer Pressure controller to prevent over pressurization of PCS should be a Critical Task (CT) (i.e. could failure to perform action result in a RPS actuation?)
General Comments Low Power
- Scenario, etc.
Replace one scenario as discussed, and provide a pedigree for each scenario that specifies how ES-301 D.5 (pp. 15-17) requirements were met Crews Eliminate surrogates per table below. Revise corresponding Forms ES 301-5 (and ES 301-6) to reflect these changes
Byron 2019 Initial License Exam Outline Review Comments 3
Overlap issues There may be overlap between certain written exam questions and those specific JPMs with similar K/As. Review at Onsite Validation.
Byron Outline Submittal and Comments received timeline. Information obtained from TQ-AA-201-F09 NRC Communications Log and emails.
08/08/18 0930 Delivered Operating Exam Outline to C. Zoia at Region 3, including the following:
Examination Security Agreements (Form ES-201 -3)
Administrative Topics Outline(s) (Form ES-301-1)
Control Room/In-Plant Systems Outline (Form ES-301-2)
Scenario Outlines (Form ES-D-1)
Completed Checklists:
o Examination Outline Quality Checklist (Form ES-201-2) o Transient and Event Checklist (Form ES-301-5)
Also discussed written exam and solicited for KA changes:
Obtained changes as follows:
(RO #6) from APE26AA1.05 Loss of Component Cooling Water (CCW), Ability to operate and / or monitor the following as they apply to the Loss of Component Cooling Water: The CCWS surge tank, including level control and level alarms, and radiation alarm. To APE026AA1.06 Loss of Component Cooling Water (CCW), Ability to operate and / or monitor the following as they apply to the Loss of Component Cooling Water: Control of flow rates to components cooled by the CCWS (RO #10) from APE054G2.1.31 Loss of Main Feedwater (MFW) Ability to locate control room switches, controls, and indications, and to determine that they correctly reflect the desired plant lineup. To APE054G2.1.25 Loss of Main Feedwater (MFW), Ability to interpret reference materials, such as graphs, curves, tables, etc.
(RO #19) from APE003AK1.10 Dropped Control Rod. Knowledge of the operational implications of the following concepts as they apply to Dropped Control Rod: Definitions of core quadrant power tilt. To APE003AK1.15 Dropped Control Rod. Definition and application of power defect.
(RO #36) from 010A3.01 Pressurizer Pressure Control System (PZR PCS). Ability to monitor automatic operation of the PZR PCS, including: PRT temperature and pressure during PORV testing. To 010A3.02 Pressurizer Pressure Control System: Ability to monitor automatic operation of the Pzr PCS including: Pzr Pressure.
(RO #58) from 016A2.04 Non-Nuclear Instrumentation System (NNIS).
Ability to (a) predict the impacts of the following malfunctions or operations on the NNIS; and (b) based on those predictions, use procedures to correct, control or mitigate the consequences of those malfunctions or operations: Voltage to instruments, both too high and too low.. To 016A2.01 Non-Nuclear Instrumentation System (NNIS).
Ability to (a) predict the impacts of the following malfunctions or operations on the NNIS; and (b) based on those predictions, use procedures to correct, control or mitigate the consequences of those malfunctions or operations: Detector failure.
Also pursued changes to the following K/As:
(SRO #76) EPE007G2.4.50 Reactor Trip. Ability to verify system alarm setpoints and operate controls identified in the alarm response manual.
(SRO #81) WE05G2.4.2 Loss of Secondary Heat Sink. Knowledge of system set points, interlocks and automatic actions associated with EOP entry conditions.
(SRO #91) 014G2.1.19 Rod Position Indication System (RPIS). Ability to use plant computers to evaluate system or component status.
I will find and suggest K/As without ties to the same generic K/As on the exam.
08/09/18 1004 Initial phone call on review of outline materials.
Chuck Identified potential overlap issues with JPM outlines and written exam. These were cases were the K/A identified on the JPM and the exam were similar and would have to be verified side-by-side when submitted.
RO Admin Conduct of Operations (note: RA-2) Perform Offsite AC Power Availability Surveillance K/A 2.1.31 with question #10 054G2.1.31. (Note: obtained change to question #10 to 054G2.1.25, but now similar overlap concern with SA-2)
JPM CR-d Respond to Main Generator Field Forcing 045G2.1.20 with question #2 009 G2.1.20 JPM CR-e Drain the PRT 007A1.03 with question #35 ( note: I believe he meant #34 007 A1.02. I also believe that the JPM should be A1.01 and does overlap with the question as written in actions.)
JPM CR-h Containment Release (With Rad Alarm) 029A1.02 with #59 029A3.01 Ability to monitor automatic operation of the Containment Purge System including: CPS isolation.
Also, SRO Emergency Plan JPM (note: SA-5) Screen Event for Reportability 2.4.30 with #99 2.4.30 and may require generation of new JPM or question to resolve.
08/09/18 1049 Additional phone call on review of outline materials, scenarios.
ES-301 pg 15 should have low - power, < 5%, replace set.
Also provide detail as to where events were previously used or how event used in past.
8/10/18 email received from Chuck Zoia:
This brief note broadly recaps those issues identified in my review of the operating test documents you gave me this week:
CREWS: Eliminate surrogates per table below. Revise corresponding Forms ES 301-5 (and ES 301-6) to reflect these changes (Due in submittal before OV)
JPMs: Concern was expressed for potential K/A overlap between certain written exam questions and those specific JPMs with similar K/As. (Due in submittal before OV)
SCENARIOS: Replace one scenario as discussed, and provide a pedigree for each scenario that specifies how ES-301 D.5 (pp. 15-17) requirements were met (Due in submittal before OV) 08/22/18 1300 Call to clarify expectations of Exam Development:
Operating:
Discussed need for low-power or start-up set. Chuck agreed that developing a start-up set about 10% reactor power, prepping to roll the turbine or rolling the turbine to 1700 rpm would be satisfactory.
What I had envisioned for noting events on D-1 sheets for past NRC or other use is what Chuck is looking for.
CR-e: Drain the PRT Informed Chuck that I would update the K/A to reflect performance of JPM. Changed K/A from 007A1.03 to 007A1.01 Ability to predict and/or monitor changes in parameters (to prevent exceeding design limits) associated with operating the PZR PCS controls including: Maintaining PRT water level within limits; to more accurately reflect JPM performance.
Written; Discussed and received concurrence on the following K/A changes:
(SRO #76) from EPE007G2.4.50 Reactor Trip. Ability to verify system alarm setpoints and operate controls identified in the alarm response manual. To EPE007G2.4.8 Reactor Trip. Knowledge of how abnormal operating procedures are used in conjunction with EOPs.
(SRO #81) from WE05G2.4.2 Loss of Secondary Heat Sink.
Knowledge of system set points, interlocks and automatic actions associated with EOP entry conditions. To WE05G2.4.16 Loss of Secondary Heat Sink. Knowledge of EOP implementation hierarchy and coordination with other support procedures or guidelines such as, operating procedures, abnormal operating procedures, and severe accident management guidelines.
(SRO #91) from 014G2.1.19 Rod Position Indication System (RPIS).
Ability to use plant computers to evaluate system or component status.
To 014G2.1.45 Rod Position Indication System (RPIS). Ability to identify and interpret diverse indications to validate the response of another indication.
(RO #59) from 029A3.01 Containment Purge System (CPS). Ability to monitor automatic operation of the Containment Purge System including: CPS isolation. To 029A4.04 Containment Purge System (CPS). Ability to manually operate and/or monitor in the control room:
Containment evacuation signal.
Also discussed the upcoming Ovation modifications. The plan for Byron is to update the simulator following completion of the October 2019 Exam.
Training to occur following by the installation in the upcoming refueling outages.
Chuck will call on Friday 8/24/18 at which time I will provide an updated Form ES-401-4.
08/24/18 1055 Talked with Chuck via telephone as I emailed password protected copy of Form ES-401-4 as of 8-23-18.