ML20267A206
| ML20267A206 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/26/2020 |
| From: | Greg Werner Operations Branch IV |
| To: | Entergy Operations |
| References | |
| Download: ML20267A206 (7) | |
See also: IR 05000382/2020008
Text
Attachment 6
OBDI 202 - IOLE Process
Rev 3
PROPOSED OUTLINE COMMENTS
Facility:
First Exam Date:
08/17/2020
Written Exam Outline
Comment
Resolution
1 NRC Generated, updated by licensee
No resolution required.
2
Record of Rejected K/As - For SRO tier
2, group 1, question 15 (should be
question 90), there is not a K/A 2.27.
What K/A is the resampled one?
Used rev. 3 K/A Catalog in error when making
this random selection. Removed this line item
from the 401-4. For the RO exam, also
removed RO62 from the 401-4 because I also
used rev. 3 K/A catalog when selecting a new
K/A. The same K/A in Rev. 2 had an
importance rating of < 2.5.?
3
All other K/A changes were reasonable -
update the 401-2, 401-3 with the new
K/As.
Updated the 401-2 and 401-3 with the new
K/As.
4
5
Administrative JPM Outline
8/17/2020
Comment
Resolution
1
A4, A9 on last NRC exam
A3, A7, A9 on 2017 NRC exam
A9 on last two NRC exams.
Classify an event was on last 4
NRC exams
This seems like a lot of overlap. Has it
been the same event or different events
the past 4 exams? Will it be different on
this exam from the last 4?
How are [A4 and A9] and [A3, A7, and
A9] different from previous exams?
Were the JPMs that were on the last two
NRC exams randomly selected? Are
they significantly modified? Please
reference NUREG 1021 section ES-301
D.1.a and D.2.a for significant
modification criteria. I need to verify that
the modification altered the course of
action of the JPM.
From D.2.a, A significant modification means
that at least one condition has been
substantively changed in a manner that alters
the course of action of the JPM.
For JPM A9, verified that this emergency
declaration is different than the declarations
on the last 4 exams. In the last 3 exams
(2018, 2017, 2015), the declaration was on
different tabs in the declaration matrix. In
2014, the declaration was in the same tab,
but involved a different initiating condition and
EAL. This JPM is new as stated on the 301-1
for the SRO.
A4 is different from previous exams because
it is a calculation of stay time base on the
Waterford 3 yearly administrative dose limit.
(2000 mr/year). Also, the dose rates, previous
yearly exposure, and final stay times are
different than any previous exams.
Updated A4 on the 301-1 for the RO.
Changed the description of the activity to read
Calculate stay time to perform a tagout
Attachment 6
OBDI 202 - IOLE Process
Rev 3
verification. Room dose rate and operators
yearly dose provided. The stay time will be
based on the W3 administrative yearly dose
limit (2000 mr/year). This will show on the
301-1 that the JPM is modified from the
previous two years.
A3 and A7 were the administrative JPMs that
were randomly selected. The limit is 1 JPM
from the previous 2 exams for the both the
RO and SRO 301-1. The JPMs have been
altered from the previous one given because
the plant data book data and curves have
changed (this is a new cycle). But the
changes dont meet the definition of a
significantly modified JPM from D.2.a.
Removed the M (Modified) from the 301-1
2
For the admin JPMs taken direct from
bank, have they been used on audit
exams?
None of the admin JPMs taken direct from the
bank will be used on the upcoming (2020)
audit exam.
3
4
5
Control Room / In-Plant System JPM Outline
8/17/2020
Comment
Resolution
1
S1 might be a SF2 not SF1; ensure it is
SF1
004 Chemical and Volume Control System is
SF1. Aligning Charging to HPSI Header A
requires the operation of CVC valves and the
verification of charging flow. The steps to
perform this action are located in OP-901-
112, Charging or Letdown Malfunction.
2
3
4
5
Simulator Scenario Outline Comments
8/17/2020
Comment
Resolution
1 Only Scenario 2 goes into Contingency
Procedures - the requirement is 1
It is very typical for W3 to only have one
contingency procedure out of a set. We will
Attachment 6
OBDI 202 - IOLE Process
Rev 3
This locks us into running scenario 2 for
everybody - which is fine if it validates
okay and the schedule gets revised; but
I would prefer another scenario go into
contingencies to give us more choices
for the spare.
ensure it validates well.
Is it a requirement that everyone must see
the contingency procedure scenario or is
the requirement that one scenario in the
set must be a contingency procedure? If
everyone must see the contingency
procedure, we will need to make another
contingency procedure. I dont see in any
of the NUREG forms that every applicant
must be evaluated entering OP-902-008.?
2
Scenario 2, Critical Task 2 is not
bounded. Please use measurable
criteria for what successful performance
is - e.g. prior to (insert event X
happens) or within a given time limit.
Please see NUREG 1021 Appendix D,
section D.1.c.
In TM-OP-100-03, Attachment 7.13,
Waterford 3 Critical Tasks, this is listed for
the standard for bounding this critical task:
Prior to exiting the step to align a LPSI pump
to replace a CS pump in Appendix 28.
This has been added to Scenario 2 critical
task 2.
3
Scenario 3, Critical Task 2 is not
bounded
In TM-OP-100-03, Attachment 7.13,
Waterford 3 Critical Tasks, this is listed for
the standard for bounding this critical task:
Prior to performing actions in OP-902-005,
Station Blackout Recovery.
This has been added to Scenario 3 critical
task 2.
4
Scenario 4, Critical Task 2 - the name is
not correct as the actual task is to cool
down and the bounding criteria is to
prevent lifting a SG safety valve. Please
reword.
The title of each critical task comes from site
training manual TM-OP-100-03, Simulator
Training. The title we used is from our
manual.
Agree, the task is to cool and depressurize
the RCS. The safety significant of these
actions is to prevent lifting the Main Steam
Safety Valves.
To address comment and maintain alignment
with our manual, critical task 2 in scenario 4
will be titled Cool and Depressurize RCS to
Prevent Lifting Affected SG Safety Valves.
5
Scenario 1 is the 2018 NRC exam
spare. Is there adequate assurance or
verification that this scenario was not
put into an exam bank and that nobody
on the 2018 exam security agreement
has disclosed the contents of the spare
scenario?
It can be assured that Scenario 1, which was
the spare for the 2018 NRC Exam, has not
been put into the exam bank. The scenario
has remained on the stand alone computer
in the exam room which is password
protected.
The only persons that have seen the
scenario is the operators that validated it for
the 2018 NRC Exam. These operators have
Attachment 6
OBDI 202 - IOLE Process
Rev 3
since been taken off exam security. The
validators have not been told which of the
four exams in 2018 was used as the spare
and it is not a guarantee that the 2018 spare
must be used as one of the four scenarios
created for the 2020 NRC exam.
6
Scenario 1, event 4 was on last two
NRC exams (spare in 2018)
Scenario 1 event 2, RCS Loop 1 Hot leg
transmitter failure high, has not been used
on any NRC exam.
Scenario 1 event 3, PMU counter fails to
secure flow, has not been used since the
2015 NRC Exam.
Scenario 1 Event 4, Pressurizer Level
Control Channel Level Transmitter, RC-ILT-
0110X, fails low, had not been performed
since 2014 NRC Exam. I did not see where
this event was performed in 2017.
Scenario 1 Event 5, RCP seal failure, was
performed on the 2017 NRC exam.
Scenario 1 Event 6, RCP trip with no Reactor
trip was performed on the 2017 NRC exam.
Scenario 1 Event 8, Containment Spray
Actuation System fails to actuate, had not
been performed since the 2015 NRC exam.
7
8
9
Scenario 2, event 2 was on 2018 NRC
exam
Scenario 2, event 3 was on 2017 NRC
exam
Scenario 2, event 4 was on 2017 NRC
exam
Scenario 2 events 1, 5, and have not been
on the previous 2 NRC exams.
To establish an additional gap between this
scenario and past scenarios, replaced Event
3 with an event not used in the previous 2
exams.
This will give this scenario 3 events not on a
previous scenario in the previous 2 exams.
10
A LOCA has been on the last two NRC
exams, need to ensure there are
significant differences
This LOCA requires entry into OP-902-008,
the Functional Recovery due to a loss of all
Containment Spray. A Low Pressure Safety
Injection Pump will need to be aligned to
address the Containment safety function.
This was not part of either of the last 2
exams.
In the 2018 exam, the LOCA included a loss
of all Low Pressure Injection Pumps and the
crew had to align a Containment Spray
Pump to address that safety function. The
crew did enter OP-902-008, the Functional
Attachment 6
OBDI 202 - IOLE Process
Rev 3
Recovery, but it was due to a loss of all low
pressure injection.
In the 2017 exam, The LOCA was followed
by an excess steam demand event. The
crew did enter OP-902-008, the Functional
Recovery, but it was due to having 2
separate events in progress.
In addition to different entry conditions each
exam, verified that the SRO prioritization
after entering OP-902-008 was different in all
3 exams.
11
Scenario 2, event 7 used on 2017 NRC
exam spare scenario. Is this in a study
bank or disclosed by anyone on exam
security?
This is not in any exam bank or study bank,
but after checking in ADAMS, the NRC did
include this in the exam package that was
posted in ADAMS in 2019.
As described above, a new event was added
to Scenario 2 to give it 3 events not used in
the last 2 exams. This event 7, though not
used, was posted in ADAMS, so we are not
counting that in the count for 2 or more
new/not used events for Scenario 2.
12
13
14
Scenario 3, event 1 was on 2018 NRC
exam
Scenario 3, event 2 was on 2017 NRC
exam (different channel but not a
significant difference)
Scenario 3, event 7 was on 2017 NRC
exam
Event 3 is an Atmospheric Dump Valve
failing open and the removal of MW to
restore the plant to 100% power. This event
was last used in 2015.
Event 4 is the lowering of Condenser
Vacuum such that the crew will be required
to perform a rapid plant power reduction.
Although in this event which has never been
used on any NRC exam, condenser vacuum
will eventually lower to the point where the
crew should manually trip the Reactor or the
reactor will trip automatically at setpoint.
Event 7 has never been used on any NRC
exam. In 2017, the EDG output breaker did
not close due to the 3 to 2 tie breaker not
opening on an undervoltage condition,
requiring the crew to manually open the 3 to
2 tie breaker. In the 2020 scenario 3 event,
the EDG output breaker does not auto start
due to the voltage regulator failed low
requiring the crew to raise voltage to band
and then the output breaker would auto
close.
This will give this scenario 2 events not used
on the previous two exams. Three events if
event 4 is counted as a new event.
Attachment 6
OBDI 202 - IOLE Process
Rev 3
15
16
17
Scenario 4, event 3 was on 2017 NRC
exam
Scenario 4, event 5 was on 2017 NRC
exam
Scenario 4, event 6 was on 2018 NRC
exam
Scenario 4 events 1, 2, and 7 have not been
on the previous 2 NRC exams.
In the 2018 exam major event, the applicants
had to control the Main Turbine in manual
during the rapid power reduction and they
had to establish high pressure injection after
both pumps failed as a third critical task after
the safety injection signal. None of these
elements are in the 2020 exam.
In the 2020 exam, the Feedwater failure will
require manual operation of SG level during
the rapid power reduction. The Exciter Field
breaker will fail post trip and high pressure
injection pumps will not fail. This collection
of differences make the steam generator
tube leak and subsequent rupture
significantly different that previous exams.
These differences meet the NUREG
requirement for significant modification. To
establish an additional gap between this
scenario and past scenarios, a new
malfunction will be added post trip that has
not been used in any scenario on the last 2
NRC exams. This will give this scenario 4
events not on a previous scenario in the
previous 2 exams.
For comments 6-17, I need to confirm
that every scenario is new or
significantly modified (including the
major events) - at least two events have
not been used on the previous two NRC
exams; and that scenarios from the
licensees bank must be altered to the
degree necessary to prevent the
applicants from immediately recognizing
the scenarios based on the initial
conditions or other cues. Please see
NUREG Appendix D section C.1.f and
ES-301 D.5.b.
For major events:
Scenario 1-The major is an Excess Steam
Demand Event inside containment. There
has been one Excess Steam Demand Event
in the previous two exams but the previous
ESD was outside containment.
Scenario 2- The major is a LOCA.This
LOCA requires entry into OP-902-008, the
Functional Recovery due to a loss of all
Containment Spray. A Low Pressure Safety
Injection Pump will need to be aligned to
address the Containment safety function.
This was not part of either of the last 2
exams.
In the 2018 exam, the LOCA included a loss
of all Low Pressure Injection Pumps and the
crew had to align a Containment Spray
Pump to address that safety function. The
crew did enter OP-902-008, the Functional
Recovery, but it was due to a loss of all low
pressure injection.
Attachment 6
OBDI 202 - IOLE Process
Rev 3
In the 2017 exam, The LOCA was followed
by an excess steam demand event. The
crew did enter OP-902-008, the Functional
Recovery, but it was due to having 2
separate events in progress.
In addition to different entry conditions each
exam, verified that the SRO prioritization
after entering OP-902-008 was different in all
3 exams.
Scenario 3. For 2020, the major event is a
Loss of Offsite power and a failure of the
remaining diesel output breaker to close
because of the voltage regulator failing low
requiring operators to raise voltage manually.
For 2018, a loss of offsite power occurred
and the remaining EDG output breaker did
not auto close because the 3 to 2 tie breaker
did not auto open on under voltage requiring
the operator to manually open the 3 to 2 tie
breaker.
Scenario 4- The major is a Steam Generator
Tube rupture. The subsequent malfunction
on the 2020 NRC exam is a failure of a
Charging Pump to start. The subsequent
event on the 2018 NRC exam following the
Steam Generator Tube Rupture is a failure of
a HPSI pump to auto start.
The initial conditions for all scenarios were
different for the major that were overlapped
in the previous two exams.
Per the NUREG, if major is repeated from
any of the previous two exams, the author
should change the major event, the IC, or
subsequent malfunction to alter the course of
action.
This outline meets the requirement of the
NUREG for overlap of the major events.
For events, at least two events in each of the
four scenarios have not been used on the
previous two NRC exams; no scenarios were
used from the W3 bank. This requirement
being met is explained in the comments
above for each scenario.