ML20072N631
| ML20072N631 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/27/2020 |
| From: | Gregory Roach FirstEnergy Nuclear Operating Co |
| To: | NRC/RGN-III/DRS/OLB |
| Roach G | |
| Shared Package | |
| ML19121A156 | List: |
| References | |
| Download: ML20072N631 (3) | |
Text
Davis Besse 2020 Initial License Exam Outline Review Comments 1
Simulator Scenario Outline Comments General Comments o NRC: ES 301-4 form should list 3 abnormal events (events 3, 4, and 5) for scenario
- 1. Per Appendix D, page D-9, abnormal events which include a significant response (and a TS call) using an annunciator response procedure (vice an AOP) still count as an abnormal event. This would be true for event 4 on scenario 1.
Facility:
Agree, the crew will respond using a plant operating procedure, after discussion it was agreed that this action meets the criteria for an abnormal event.
o NRC: Please provide a list of EOPs Davis Besse considers to be Contingency EOPs.
Facility:
For the scenarios in this exam submittal:
Loss of Subcooling Margin Specific Rule 6 for station blackout Overcooling ATWS Lack of Heat Transfer Steam Generator Tube Rupture with:
- 1) Loss of primary pressure control
- 2) Loss of Primary system integrity
- 3) Loss of Secondary system integrity o NRC: ES D-1 for scenario 3 incorrectly lists restore seal return as CT-B. Should be annotated CT-3.
Facility:
Davis Besse has a site specific Critical Tasks for this event CT-B o NRC: ES 301-6 should be broken down by applicant and not by position. Note the SRO-U doesnt get any data reported under his section and the SRO-I applicants have no data reported for the Operate the Controls Competency. Filling the form by applicant will most accurately show how each applicant will have the opportunity to be graded under all of the required competencies. In addition, ensure that the correct scenarios are included in this review. Specifically, scenarios 2-5 if scenario 1 will be the spare.
Facility:
Agree, Chief examiner has provided an example of the format to use for the form.
This will be updated and included with the 75 day submittal.
Davis Besse 2020 Initial License Exam Outline Review Comments 2
o NRC: ES 301-5 should be redone to ensure correct scenarios are assessed in this review. Specifically, scenarios 2-5 if scenario 1 will be the spare.
Facility:
Agree, at the 150 day submittal date, the scenarios to be included in the exam were not yet decided, after discussion with the Chief examiner, the proposed scenarios have been selected. The form will be updated and included in the 75 day submittal.
JPM Outline Comments General Comments o NRC: JPM S4 is incorrectly characterized as (E) Emergency or abnormal in-plant on the SRO(I) ES 301-2 form.
Facility:
Agree, this was a typographical error on this form, the RO and SRO-U forms were correct as submitted.
Written Exam Outline/Audit Exam Outline o NRC: Potential conflict between NRC written exam question covering RO Tier 2 Group 1 K/A 026 A4.01 ability to manually operate and/or monitor in the control room containment spray system controls and JPM S5 Initiate Containment Spray.
Facility:
The content of the question and the actions contained in the JPM are not evaluating the same concepts. Question 42 asks about a procedural action in the Emergency Operating Procedure when the Borated Water Storage Tank has drained into the emergency sump and the required throttling of the CS discharge valve. The JPM uses the system operating procedure for placing CS in service following a LOCA due to the failure to automatically actuate. The CS discharge valve will be fully opened and the procedure does not include the reason for throttling, it verifies that the valve is open or throttled.
o NRC: Potential conflict between RO written exam and Certification exam question covering Tier 1 Group 1 K/A 057 Loss of Vital AC Instrument Bus AK3.01.
Facility:
The K/As are the same but the questions are testing different concepts. Two different busses are affected, written question 13 is related to Uninterruptible Bus YAU and certification question 15 is related to Non Nuclear Instrumentation bus NNI X AC.
o NRC: Potential conflict between RO written exam and Certification exam question covering Tier 2 Group 1 K/A 064 Emergency Diesel Generator K6.07.
Facility:
Written question 50 and certification question 49 test similar concepts but are different questions.
Davis Besse 2020 Initial License Exam Outline Review Comments 3
o NRC: Potential conflict between SRO written exam and Certification exam question covering Tier 3 K/A G2.4.9, Knowledge of low power/shutdown implications in accident (e.g. loss of coolant accident or loss of residual heat removal) mitigation strategies.
Facility:
The K/As are the same but the questions are testing different concepts, the stem conditions are different, and the correct answers are different.