ML22158A164
| ML22158A164 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/05/2021 |
| From: | Randy Baker NRC/RGN-III/DRS/OLB |
| To: | DTE Energy |
| Baker R | |
| Shared Package | |
| ML19128A199 | List: |
| References | |
| Download: ML22158A164 (3) | |
Text
FERMI 2 - 2020 Initial License Exam Outline Review Comments Simulator Scenario Outline Comments
- General Comments o NRC: As a reminder for scenario construction:
[With the exception of the SRO TS evaluations, each evolution, failure, or transient should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation, and, similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.]
- Technical Specification Event Concerns:
o NRC: The Scenario #1, Event 2 SRO Technical Specification (TS) evaluation is identified as a Tracking LCO. Please specify which TS LCO is impacted in Event 4 and ensure that it is also not a Tracking LCO, as these, as well as No Entry TS LCO evaluations are not counted for required TS events during applicant evaluations.
Facility: Event 2 is not counted as TS. Event 3 is TS that requires entry. Event 4 is TS and required entry.
- Scenario Comments o NRC: In Scenario #1, Event 3, replicates Event 3 from the previous NRC exam Scenario #1. Ensure this event is/was not used on the Audit exam.
Facility: Audit uses 2019 Scn #2 and Scn #5. Event is not used on the Audit o NRC: For Scenario #2, there is significant repetition of events from the previous NRC exam (Scenario #3) including the Major event and subsequent SBLC pump failure. As this could be considered a repeat scenario, how will this scenario differ from the previous NRC exam? May need to modify the mitigating strategy for the major event.
[To maintain test integrity, every scenario shall be new or significantly modified to ensure that the applicant has not had the opportunity to rehearse or practice the scenario. A significant modification means that, for each scenario, at least two events have not been used on the previous two NRC initial licensing operating exams. Additionally, scenarios that are extracted from the facility 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.]
Facility: Post ATWS SLC pump failure replaced with RWCU isolation failure that will require operation action to correct. (not used in last 2 exams) o NRC: Scenario 3, No comments 1
FERMI 2 - 2020 Initial License Exam Outline Review Comments JPM Outline Comments
- General Comments Again, need to ensure that these JPMs are not repeats from the Audit exam.
o NRC: SRO Admin JPM Equipment Control is listed as new. Ensure that this is significantly different from any Bank JPM that already exist for this evaluation activity.
Facility:
One other bank JPM (JP-OP-802-4101-102, Evaluate Degraded Power Sources) exists in which applicants must evaluate offsite power source operability. In the bank JPM applicants must evaluate a report of 345KV breaker failure during normal operation. In the new 2020 JPM applicants must implement applicable portions of the Degraded Grid abnormal procedure based on indications of degraded post-trip voltages. Although both JPMs result in evaluating the operability status of off-site power sources in TS 3.8.1, the initial conditions and evaluation process in the 2020 JPM are sufficiently different to warrant identifying it as New.
Fermi exam development staff have concluded that the new status is justified. We could certainly re-classify this JPM as modified if NRC believes it is warranted, since this change would have no significant effect on the JPM outline or exam content.
o NRC: SRO Admin JPM Radiation Control was on one of the previous 2 NRC exams. JPMs that appeared on previous two exams are required to be randomly chosen (ES-301-1). What was the random process that chose this JPM?
Facility:
Fermi uses a random number generator via Excel Spreadsheet RANDBETWEEN function to generate the JPM random selections. Each JPM was assigned a sequential number. This function returns a random integer number between the numbers specified. A random integer number is returned when the worksheet is calculated and the corresponding JPM was selected.
- NRC: For Simulator JPM b, how is this different from the Power Reduction required in Scenario #2, Event 5?
Facility:
The power reduction in SCN 2 event 5 is conducted using normal operating procedures and does not include any failures of recirc pump controls. The power reduction is directed from an alarm response procedure and must be performed using normal operating methods and rate restrictions. A rapid power reduction is not permitted for this condition.
The JPM b rapid power reduction is performed using a posted hard card designed for use in off-normal conditions such that standard power reduction methods and ramp rates restrictions do not apply. Additionally, the JPM is alt path, 2
FERMI 2 - 2020 Initial License Exam Outline Review Comments requiring applicants to recognize an equipment failure and utilize an alternate method to accomplish the rapid power reduction.
Fermi exam development staff, therefore, concludes that SCN 2 event 5 and JPM b are sufficiently different, such that no outline or content revisions are necessary.
o NRC: Is Simulator JPM d actually an Alt Path as listed in the Type Code column?
Facility:
JPM d is not alt path. This type code was entered in error and will be corrected.
This will result in 5 alt path JPMs for RO and 4 for SROI applicants, which still meets ES-301 criteria.
Written Exam Outline/Audit Exam Outline o NRC: Potential overlap between RO Admin JPM Equipment Control and written exam RO question #70. These two examples share K/A 2.2.41. Ensure the written question is focused on either a uniquely different electrical system, or mechanical system.
Facility:
New Question 70 written. Original version WAS too closely related to the JPM of the same K/A. This was originally submitted as an early review question, so the submitted version will be different from the early review version sent to the NRC.
o NRC: Potential overlap between RO Admin JPM Radiation Control and written exam RO question #72. These two examples share K/A 2.3.12. Ensure the written question is focused on a different radiological safety principle for licensed operator duties other than entry into a locker high radiation area.
Facility:
Question 72 and the JPM in question are completely different from one another.
o NRC: No Audit Exam Outline included with submittal. Examiner not able to verify that no overlap exists with NRC Exam. Please inform the NRC when the Audit Exam becomes available and provide a copy of the operating test outlines as a minimum.
Facility:
The operating exam outlines for the Audit exam have been submitted.
The written Audit Exam will be selected by the Initial Training group. They have several exams (2018, 2019, and 2019 Retake NRC exams, for example) to choose from. This is performed independently of the exam team. Form ES-401-6 Part 5 has been completed by selecting the audit exam was completed before the license exam was started.
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