ML22175A194
| ML22175A194 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/23/2021 |
| From: | Joseph Demarshall Operations Branch I |
| To: | Public Service Enterprise Group |
| Shared Package | |
| ML21020A061 | List: |
| References | |
| EPID L-2022-OLL-0002 | |
| Download: ML22175A194 (8) | |
Text
Salem 2022 Initial License Exam Outline Review Comments
Simulator Scenario Outline Comments
GENERAL COMMENT
S (ALL SCENARIOS)
o NRC: Simulator Scenario Summaries, do not consistently specify the procedure Title or Noun Name the first time a procedure designator is referenced in the applicable event summary descriptions. Inclusion of procedure Titles / Noun Names serves to enhance the summaries by providing additional context and clarifying information.
Salem: Included procedure titles on all simulator scenario summaries outlines.
o NRC: All applicant positions (i.e., ATC, BOP, CRS) are credited with a Reactivity Manipulation for the designated Reactivity Event Type in each of the scenarios.
Only the ATC position should be credited with the Reactivity Manipulation. The BOP and CRS positions should be credited with Normal Evolutions for the planned power changes scripted in Event #1 for each scenario.
Salem: Corr ected outlines to only credit the ATC position with a Reactivity Manipulation. The BOP and CRS position were credited with a Normal Evolution if they performed an action to support the Reactivity Manipulation.
o NRC: ES-301-5, Transient and event Checkl ist, and the D1 Target Quantitative Attributes per Scenario Table for each scenario will need to be appropriately revised to reflect the necessary changes to the ES-D-1 scenario outlines identified herein.
Salem: All ES-301-5 check lists have been updated to reflect changes due to the ES-D-1 changes and includes the SRO-U only doing two scenarios for N+1.
o NRC: On the ES-D-1 outline forms for each scenario, identify which events are associated with the individual Critical Tasks (CT) by including the CT designator (i.e., CT-1, CT-2, etc.) in the corresponding Event Description Column.
Salem: Corrected outlines to specify which events have an associated Critical Task.
o NRC: NUREG -1021, Appendix D, requires each Critical Task (CT) to include the four elements listed below. For the 75-Day submittal, provide a CT information page/sheet with each scenario that identifies how the individual elements are met.
a) Safety Significance b) Initiating Cue c) Measurable Performance Standard, specifically.
1 Salem 2022 Initial License Exam Outline Review Comments
- i. Expected action(s) ii. Safety-significant boundary conditions/criteria that clearly define at what point a CT must be accomplished d) Performance feedback
Salem: Included in each outline the four elements for each Critical Task in each scenario. Each CT also defines the boundary conditions or criteria at which point the CT must be accomplished per the guidance of the Westinghouse Critical Task Document, Revision 3.
- SCENARIO #1
o NRC: Scenario #1, Event 5, RCS Leak, should be designated as a Component Failure, rather than the Major Event. Accordingly, Event 6, Large Break LOCA, should be designated as the Major Event and not a Component Failure.
Appropriately revise the Event Summary Descriptions for Events 5 and 6.
Salem: Events 5 and 6 were revised per NRC comments. (now Events 4 and 5 respectively).
o NRC: Scenario #1, Event 5, RCS Leak, should be designated as a Tech Spec (TS) Event. RCS Operational Leakage LCO 3.4.7.2 has applicability to this event and should therefore be evaluated during the conduct of NRC Exam Scenario #1.
Salem: Corrected outline to add TS event to RCS Leak (now Event 4)
o NRC: Scenario #1, Event 2, 23 SG Pressure Channel 3 Fails Low, should be removed. This Component Failure has no operational impact or verifiable actions and was only included to ensure that the number of TS events for this scenario met minimum Quantitative Attribute requirements. The inclusion of LCO 3.4.7.2 in Scenario #1, Event 5, obviates the need for Event 2. Remove Event 2 and renumber the events accordingly.
Salem: Event 2, 23 SG Pressure Channel 3 Fails Low, was removed from outline. Events were renumbered.
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- SCENARIO #2 (Designated Spare Scenario-Information Redacted)
o NRC:
Salem:
o NRC:
Salem:
o NRC:
Salem:
o NRC:
Salem:
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Salem 2022 Initial License Exam Outline Review Comments
- SCENARIO #3
o NRC: ES-D-1 Target Quantitative Attributes Table for Scenario #3 lists EOP-TRIP-1 for Item 5, EOPs entered/requiring substantive actions (1 -2).This is incorrect.
The Actual Attributes Column should specify 0 and the Event No. Column should specify -------. NUREG-1021, Appendix D, Section C.2.f, EOPs Used, states Moreover, the primary scram response procedure that serves as the entry point for the EOPs is not counted. An Attribute Value of 0 for Table Item 5 was determined to be acceptable by the Chief Examiner on the basis that (a) Scenario
- 3 is a complex scenario that exercises Contingency EOP Procedure FRHS-1 for the Loss of Secondary Heat Sink, (b) FRHS-1 requires the use of alternate decision paths and prioritization of actions within the EOP to mitigate a CSFST Heat Sink Red Path condition, and (c) FRHS-1 has measurable actions that must be taken by the crew.
Salem: The Quantitative Attributes Table for item 5 was changed per the above NRC comment.
- SCENARIO #4
o NRC: Scenario #4, Event 6, 21 CFCU Fails to Start in LOW Speed, credits ALL positions with a Component Failure. The Event Summary Description states that the crew will B lock and R eset 2A SEC and manually start 21 CFCU in LOW speed..
Would the actions required to start 21 CFCU in LOW speed be performed by both the ATC and BOP? Clarification required.
Salem: It is my understanding that the BOP would block and reset SEC and the ATC would start 21 CFCU in LOW speed. Therefore, in my judgement I credited ALL positions performing an action with this Event. Its difficult to be certain in how the CRS will direc t which position will perform an action, especially during exam conditions.
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JPM Outline Comments
- Admin JPMs
o NRC: Form ES -301-1 for RO applicants indicates that the Radiation Control Admin JPM, Determine personnel exposure and requirements for entry into a radiologically controlled area, has been Modified from previous versions, including the 17- 01 NRC Exam (previous 2 exams), by requiring the task to be performed for a different room entry and RWP. While the room location and RWP information may be different, the actions required to complete the task are essentially the same (i.e., not significantly different). Accordingly, the JPM is not considered to be sufficiently Modified. In addition, ES-301-1, Section D.1, specifically states ensure that the test topic does not become predictable by always performing a different variation of the same activity. The assigned K/A, Generic 2.3.13, Knowledge of radiological safety procedures pertaining to licensed operator duties, such as response to radiation monitor alarms, containment entry requirements, fuel handling responsibilities, access to locked high-radiation areas, aligning filters, etc, encompasses a variety of test items for use in evaluation of the Radiation Control Topic. Revise/replace the JPM as necessary to meet the intent of NUREG-1021 with respect to modification criteria and predictability.
[Note: ES-301-1 Quantitative Criteria for New or Modified is 1. Ensure that the revised/ replacement JPM is either New of Modified to meet the minimum Quantitative Requirement of 1 for the RO set of Admin JPMs.]
Salem: The RO Admin JPM was changed for a Containment Entry. The RO is being asked to determine the radiological stay times inside containment given a radiological survey map for the CFCU elevation and heat stress stay time.
After the RO determines stay times for Gamma and Neutron, the applicant will need to determine what is the most limiting stay time. In this case, the RO should determine that Neutron stay time is the most limiting.
o NRC: Form ES -301-1 for SRO applicants indicates that the Radiation Control Admin JPM, Determine personnel exposure and required authorizations for work in a radiologically controlled area IAW RP-AA-463, has been Modified from previous versions, including the 17- 01 NRC Exam (previous 2 exams), by requiring the task to be performed for a different room. While the room location may be different, the actions required to complete the task for a High Radiation Area are essentially the same (i.e., not significantly different). Accordingly, the JPM is not considered to be sufficiently Modified. In addition, ES-301-1, Section D.1, specifically states ensure that the test topic does not become predictable by always performing a different variation of the same activity. The associated event summary states that the SRO applicant will determine the dose exposure for two individuals performing a task inside the RCA using a radiological survey map and also identify the required authorization for entry into the High Radiation Area. A possible alternative could require the task to be performed for a Locked High-Radiation Area rather than a High Radiation Area. Revise/replace the JPM as necessary to meet the intent of NUREG-1021 with respect to modification criteria and predictability. Ensure that the JPM is written at the SRO license level. ES -301-1, Section D.3.c, states:
5 Salem 2022 Initial License Exam Outline Review Comments
In general, SROs have more administrative responsibilities than ROs; therefore, SRO applicants are evaluated in greater depth on the administrative topics. All SRO administrative JPMs must be written at the SRO level. RO applicants only need to understand the mechanics and intent of the related subjects as they relate to tasks at the facility.
Salem: The SRO Admin JPM was changed for a Containment Entry. The SRO is being asked to determine the radiological dose for two operators entering containment and to determine if any of the two operators will exceed the PSEG Administrative Annual dose limit of 2000 mRem. This is considered SRO level because the SRO must determine what authorization(s) is/are required for a containment entry at power when the unit is performing a downpour greater than 5%/hour. In this case, with the unit downpowering at 10%/hour, station procedures require RP Supervisor approval prior to entering containment.
- Control Room Systems JPMs
o NRC: Control Room Systems JPM a, Control Rod Exercise Surveillance, was scripted for use on the previous NRC Exam [19-01; Control Room Systems JPM c]. Salem intends to use the previous NRC Exam (19- 01) as their CERT Exam.
(duplication/overlap concern with CERT Exam)
NUREG 1021, ES-301, Section D.1.a, states Operating tests may not duplicat e test items (simulator scenarios or JPMs) from the applicants audit test given at or near the end of the license training class. Simulator events and JPMs that are similar to those that were tested on the audit examination are permitted provided that the actions required to mitigate the transient or complete the task (e.g., using an alternative path as discussed in Appendix C) are significantly different from those required during the audit examination. The facility licensee shall identify for the NRC chief examiner those simulator events and JPMs that are similar to those that were tested on the audit examination.
Salem: CERT exam is not using the previous NRC exam simulator JPM c.
The CERT exam JPM c is performing the task to recover a dropped control rod. During recovery of the dropped rod two additional control rods drop into the core requiring the applicant to trip the reactor. This task is deemed not similar or a duplicate of t he previous NRC exam and not similar or a duplicate on the current NRC exam simulator JPM a.
o NRC: Control Room Systems JPM e, Manually Initiate Containment Spray and Open Phase B Valves in EOP-TRIP-1 During a LOCA, was scripted for use on the previous NRC Exam [19- 01; Control Room Systems JPM f]. Salem intends to use the previous NRC Exam (19- 01) as their CERT Exam. (duplication/overlap concern with CERT Exam)
NUREG 1021, ES-301, Section D.1.a, states Operating tests may not duplicat e test items (simulator scenarios or JPMs) from the applicants audit test given at
6 Salem 2022 Initial License Exam Outline Review Comments
or near the end of the license training class. Simulator events and JPMs that are similar to those that were tested on the audit examination are permitted provided that the actions required to mitigate the transient or complete the task (e.g., using an alternative path as discussed in Appendix C) are significantly different from those required during the audit examination. The facility licensee shall identify for the NRC chief examiner those simulator events and JPMs that are similar to those that were tested on the audit examination.
Salem: CERT exam is not using JPM f from the previous NRC exam.
o NRC: Control Room Systems JPM d, Perform Bleed and Feed IAW EOP-FRHS-1, and Scenario #3 post EOP Entry Malfunction Events both require the performance of actions within Functional Recovery Procedure EOP -FRHS-1 to address CSFST Heat Sink Red Path conditions. Although the actions are different, there is an element of similarity/ predictability in that the same Contingency EOP is utilized to accomplish the Red Path mitigative strategy for the Core Heat Removal Safety Function. Note that JPM d was used on the 17- 01 NRC Exam (previous 2 exams). Suggest replacing JPM d.
Salem: JPM d was replaced with the task to respond t o an RCP low standpipe level alarm and then take the actions per the console alarm procedure to align primary water to make up to the standpipe until the alarm clears. This task is now a Normal Evolution. The ES -301-2 criteria for Alternate Paths for each applicant were checked to ensure the minimum required number of Alternate Path criteria was met. ES-301-2 will be changed to reflect this change.
- In-Plant Systems JPMs
o NRC: Ensure that applicant knowledge of the differences between Salem Units 1 and 2 is appropriately evaluated by dividing the Operating Test coverage (i.e.,
conduct of In-Plant JPMs) between the two units.
Salem: ES -301-2 will be revised to designate In -Plant JPM j is for Salem Unit 1 Only.
7 Salem 2022 Initial License Exam Outline Review Comments
NRC Written Exam Outline/Audit Exam Outline
o NRC: ES-401.C.1.g states Facility licensees that prepare the examination shall implement appropriate controls to keep the comprehensive audit or screening examination that is given at or near the end of the license class from compromising the integrity of the licensing examination. The following potential duplication/overlap items were noted during review of the Audit Written Exam Outline. Comparison between NRC and Audit Written Exam Questions will be required in order to confirm no duplication/overlap.
- 000008 AK2.02 (NRC Exam Q2, Audit E xam Q2)
- NRC Exam Q15 (000058; AA2.01) and Audit Exam Q13 (000058; AA2.03)
- 008 K1.04 (NRC Exam Q36, Audit Exam Q 34)
- NRC Exam Q53 (078; K2.01) and Audit Exam Q54 (078; K2.02)
- 103 A3.01 (NRC Exam Q54, Audit Exam Q55)
- W E10:EA2.2 (NRC Exam Q84, Audit Exam Q84)
- NRC Exam Q88 (022; A2.05) and Audit Exam Q89 (022; A2.04)
- Tier 3 Generic 2.1.1 (NRC Exam Q66, Audit E xam Q66)
- Tier 3 Generic 2.1.3 (NRC Exam Q67, Audit E xam Q67)
- Tier 3 Generic 2.1.37 (NRC Exam Q95, Audit E xam Q68)
- Tier 3 Generic 2.2.13 (NRC Exam Q70, Audit Exam Q70)
- Tier 3 Generic 2.3.4 (NRC Exam Q71, Audit Exam Q73)
- Tier 3 Generic 2.4.17 (NRC Exam Q73, Audit Exam Q74)
Salem: A comparison between the NRC and Audit Written Exam was performed and changes to questions on the Audit Written Exam were performed to ensure no duplication or overlap concerns, including those items listed above.
CE (12/17/2021): Chief Examiner review confirms that all overlap concerns between the Audit and NRC Written Examinations have been sufficiently addressed.
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