ML22354A254

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6_RBS-2022-12 Form 2.3-3 Draft Operating Test Comments (Final)
ML22354A254
Person / Time
Site: River Bend Entergy icon.png
Issue date: 12/14/2022
From: Heather Gepford
NRC/RGN-IV/DORS/OB
To:
Entergy Operations
References
Download: ML22354A254 (1)
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Text

RBS 2022-12 Draft Operating Test Comments Nov 17 RBS responses are in orange.

[Nov 16 Note: Final comments in green]

[Nov 7 Note: Post-Validation comments are included in red]

RBS responses are in purple.

NOTE: This summary is being provided in lieu of Form 3.6-4, Operating Test Comments.

Events and Evolutions Checklist

1. RO9 still has only bare minimum I/C/RX/N events.
2. The Total event count column is all wrong for crew C. Not sure where these numbers are coming from.

Generic Scenario Comments

1. Scenarios 1 and 2 both have SCRAM the reactor as a CT simply because the automatic scrams are blocked, no in-depth ATWS actions required. This is redundant. Rework Scenario 2 for more depth of EOP actions and make it the spare. Ensure bean count is adequate.
  • Revised scenario 2 to include ATWS which created additional CTs and removed scram CT. Also included additional EOP actions.
2. GENERIC: NUREG 1021 states that The examination author should vary the ICs (including power levels), normal operations, malfunctions, and major transients among the scenario set and periodically include startup and low-power situations. Scenario Set is defined as all scenarios that are developed, reviewed, and approved for examination administration. The scenario set does not include the spare scenario. Scenarios 1, 2, 3 are all 100% power. Scenario 4 is low power, but it is proposed as the Spare, therefore it is not part of the Scenario Set. As proposed, this scenario set does not meet the NUREG guidance.
  • Low Power(S4) to be in Scenario Set with S2 asspare
3. All scenarios: Add boilerplate statement: if an applicant/operator or the crew significantly deviates from, or fails to follow, procedures that affect the maintenance of basic safety functions, those actions may form the basis of a CT identified in the post-scenario review. (ES-3.3)
  • Added termination criteria statement to all Scenarios
4. All scenarios: Significant misconception about the level of detail needed in these guides for an initial license exam. These look like Requal scenario guides.

Bottom line, if an applicant is performing an action that is directed by some procedure, that procedural step needs to be cited verbatim. If an applicant makes an error and the examiner has to document it, the examiner is going to cite the procedural guidance that was not met, and should not have to do research after the exam to identify it - it should already be documented in the guide. Per NUREG 1021 ES-3.4, D.2, Specific Instructions for Developing Scenario Guides: Complete a Detailed Operator Action Form for Each Event in Each Scenario. Document all required operator actions (e.g., opening, closing, and throttling valves; starting and stopping equipment; raising and lowering level, flow, and pressure; making decisions and giving directions; acknowledging or verifying key alarms and automatic actions).

  • Added procedure guidance for all manipulations in the scenario guides.

Included hardcard as attachments and EOP-3 isolation verification attachments.

Scenario 1 (100%):

1. MAJOR: Recirc line break
2. Specify what time in core life in initial conditions [GENERIC]
  • Added MOL to 1/2/3 and BOL for 4
3. Event 1 Normal - CRS should also get credit.
  • Gave credit to CRS
4. CT-1: In general, when referencing Level setpoints, include the range and setpoint, e.g., Level 2 (-43 inches NR).
  • Added inches value and Level Range to all scenarios
5. CT-2 Success path says Open 1st ADS/SRV this isnt correct, it should be 7 ADS valves.
  • Changed CT-2 to commence and continue with at least 5 SRVs.
6. Event 7, where the CT-1 action takes place, explicitly highlight/annotate that this is a Critical Task step. [Generic]
  • Added note above CT for all scenarios, bolded, and put in red.
7. Include step numbers for EOP-directed actions
  • Put step numbers for all scenarios
8. The level of detail provided in the EOP section of guide might work for Requal but not an NRC initial license exam. Statements like ATC: Perform actions IAW AOP-1 to reset the Reactor Scram and Verifies isolations IAW AOP-3 are inadequate for an NRC initial license exam. All steps that the applicants are reading and performing need to be included in the examiner guide, and the step number cited. Include snips of the flow chart where that facilitates understanding. GENERIC.
  • Added Actions of AOP-3 and Attachment 1 and 2 to Att. Section
  • Added OSP-53 ATT 19 for Isolating Recirc Pumps
9. What is the ATC supposed to be doing in event 10? Hes not credited with anything. If an applicant is performing an action, it needs to be documented.
  • Added isolation of recirc loop for ATC and Attachment
10. Need to include an explicit termination criteria.
  • Added statement to termination criteria to ALL scenarios Post Val
11. D-1 cover page, event 7, add Loss of Div 3 HPCS bus to event.
  • added as requested
12. D-1, cover page, event 8, clarify that this is an SRV
  • added as requested
13. D-1, cover page, event 9 - did RWCU pumps trip automatically? ATC said he isolated the valves first. We discussed modifications to valve response.
  • Gagged the suction valves (F001/F002) open
14. Event 4 - CRS gets credit for a C, not just TS.
  • Gave the CRS credit for the C
15. CT-2: We discussed modifications to the bounding criteria. I wrote down When Lrpv decreases less than 162 inches, ED and restore level > 162 with low pressure sources within 15 minutes
  • Changed the critical task to Restore and Maintain RPV water level above

-162 inches using low pressure injection systems within 15 minutes of water level lowering below -162 inches.

16. Event 2 incorrectly references CCP pump B, should be A.
  • Changed the guide to reflect CCP A
17. Event 5 - specify in [brackets] that ATC takes controller to manual and throttles open. [GENERIC comment all scenarios - specify actual action taken]
  • Specified all actions taken within brackets and in red font.
18. Termination criteria - should be specific, When RPV level is being restored by low pressure ECCS systems
  • Changed termination criteria as requested Scenario 2 (100%): SPARE
1. MAJOR: Loss of Condenser Vacuum.
2. Loss of condenser vacuum is an abnormal occurrence, not a Major.
  • Changed to Abnormal
3. Event 6 Loss of Feed / Condensate is a separate event and it is the major event for this scenario.
  • Changed major event to ATWS. Drives further into EOPs requiring attachments and rods to be inserted.
4. Insufficient actions for the examiners to evaluate within the EOPs. Where is the challenge to plant safety that needs to be mitigated? The reactor scrams, the crew trips the Generator and starts HPCS and thats it? Added additional EOP steps with addition of ATWS.
5. Event 2: The level of detail for operator actions is almost non-existent. Quote the required actions from AOP-5 directly, as well as the procedural actions to lower reactor power. This scenario guide looks like a Requal guide which is insufficient for an initial license exam.
  • Added detail to all events throughout the guide.
6. Event 3: state Reference and enter TS LCO 3.1.7 Condition B.
  • Added 3.1.7 Cond B to statement
7. Event 6/7/8: Cite the steps from the relevant AOPs that are being entered verbatim. AOP-1/2/3.
  • Added procedure guidance for all manipulations.
8. Why is every page of the scenario guide Titled ENCLOSURES? Formatting issue.
  • Removed and only in the Enclosure section
9. Need to include an explicit termination criteria.
  • Added statement to termination criteria to ALL scenarios Post-Val
10. D-1 event 8 amplify that RCIC trip and HPCS inj valve fail close also occur
  • Added as requested
11. Event 6 BOP also gets C credit.
  • Gave BOP credit for event 6
12. Event 1 CRS also gets N credit
  • Gave CRS credit for event 1
13. Need Sim Diff entry for PPC condenser vacuum plotting.
  • Differences list has been updated.
14. Event 5: Ensure Test Pushbutton doesnt allow starting of TGOP.
  • Diasbled the test pushbutton
15. Post-EOP entry: All of the actions that are directed also need to be captured in separate fields for the BOP and ATC as well. This is where the examiners evaluating the BOP and ATC applicants will immediately reference.
  • Updated as requested Scenario 3 (100%):
1. MAJOR: Unisolable steam leak
2. The scenario outline (aka, D-1) lists a tech spec only event for event 2, but it is not in the summary or the required operator actions (aka, D-2) form.

Added event 2 to the summary and required operator actions This moved ALL other events down (i.e. original event 2 moved to event

3)
3. CT-1 and 2 safety significance is not sufficiently detailed enough. See 2018 Scenario 3 justifications, and tailor to this specific scenario. Example: Per EOP-3 bases for steps SC-13, 14, and 15, If temperatures, radiation levels or water levels in any one of the areas listed in Table SC-2 approach their maximum safe operating value, adequate core cooling, containment integrity, safety of personnel, or continued operability of equipment required to perform EOP actions can no longer be assured. A reactor scram is initiated through entry of EOP-1 to reduce the primary system discharge into secondary containment and in anticipation of possible RPV depressurization in Step SC-17.

Added wording to CT-1 safety significance for max safe rad levels from bases on max safe AND SC steps 13-15 Added wording to CT-2 safety significance due to a widespread issue of rad levels posing a greater threat to

4. CT-1: Will the RCIC room Max Safe Operating Temperature be reached in this event? The CT says the bounding criteria is radiation only, but the narrative states it is any max safe value, which is how the 2018 CT was bounded.

Will only be on rad levels as this is the only parameter they can check on their own (temperature requires backpanel role play)

NRC - We have historically incorporated backpanel role play at RBS when the applicant wants to check temperature.

Table included for temperature role play.

5. Event 1: what procedure is being entered and referenced? Not cited in guide.

Added ATC to take actions IAW SOP-3 and AOP-24 to lock up HPUs

6. Event 4: What is procedurally directing the APRM to be bypassed?

Added EN-OP-115 guidance for bypassing APRM

7. Event 6: ATC, explicitly list the actions IAW AOP-1 to reset the reactor scram.

Added AOP-1 Actions

8. Event 6: BOP, include reference for isolations verified IAW AOP-3.

Added AOP-3 Actions and Attachments as reference

9. Event 7: What procedure is directing that the crew check Recirc Pump downshifted? Understanding there is a skill of the craft element, if somebody fails to do it we want to be able to cite a procedure directing this to be checked.

Added AOP-1 action to verify Recirc Pump Downshifted.

10. Event 8: Same comment: what is procedurally directing crew to verify all isolations occur as required on Level 3?

Added AOP-3 step to verify isolations

11. Event 9, is it just radiation or is it any Max Safe Value? Include bounding criteria in CT statement, before third area.

Just Radiation levelsSee comment 4

12. Need to include an explicit termination criteria.
  • Added statement to termination criteria to ALL scenarios Post Val
13. Event 8 Recirc Pump A fails to downshift -- ATC did not see this occur. Is this a viable event to retain in the scenario?
  • Removed this malfunction and added a reactivity event.
14. Event 9 RHS-AOV63 - specify what this component is. This event was responded to by the BOP vice the ATC.
  • Gave the BOP credit for the component malfunction.
15. CT-2: Need to edit scenario file to add a 3rd area radiation level increasing. As validated, only 2 areas experienced increasing radiation levels.
  • RHR C room is the third area affected. Updated the critical task to reflect this.
16. Event 6 TS call - specify that Function 1 is the function affected. Generic for any TS call with associated ECCS/RPS/PAMS/etc functions affected.
  • Added Function 1 and table to the guide
17. Event 10 where CT is referenced need to include full bounding criteria i.e. before 3rd area exceeds MSOT
  • Updated the critical task to say Emergency Depressurization before Max Safe radiation levels are reached in the third Secondary Containment area (RHR C).

Scenario 4 (5%):

1. MAJOR: SBO
2. CT: What is the basis for the 15 minute bounding criteria to shut DG output breaker?
  • Added note about 15 minutes in the safety significance. Was already in the performance standard. 15 minutes causes an escalation from ALERT to Site Area Emergency.
  • REMOVED THIS CRITICAL TASK. We do allow the crew to manually start the diesel generator and raise frequency to tie it to the bus, but then we trip the diesel to drive the crew further in the EOPs. To get the crew to exercise EOP-1C1 only RCIC can be available, so we trip the diesel after 5 minutes and exercise EOP-1C1.
  • NRC - This can remain a CT - the crew doesnt know that the DG will trip again so they need to demonstrate the ability to recover from a SBO condition while they have the ability to do so.

Kept the DG as the critical task

3. Outline, Event 8 should be titled DIV 1 DG Underfrequency
  • Swapped event 8 and 9 (didnt match outline/summary/event)
  • Changed Event 9 to DIV 1 DG Underfrequency
  • NRC - Need to specify on the D-1 and summary that Div 2 DG fails to start also and cannot be started.
  • Updated as requested
4. Outline, CRS should be getting credit to the events the board operators are.
  • Added to CRS:
  • C on event 2
  • C on event 3
5. Event 1: the event is to continue plant startup. Complete lack of detail in this event one step? What rod? What actions? What procedure is in progress?

Mode change? Provide the next 3 rods in sequence to be withdrawn.

  • Added SOP-71, RC&IS steps
  • We still need to add the rod information. Gary and Terry are in the simulator validating material right now.
6. Event 4: Lack of detail or reference to specific steps. Is any AOP entered?
  • Added SOP-9 actions for swapping level control signals
7. Event 6: Lack of detail or reference to specific procedural steps. Is the standby pump supposed to be manually started?
  • Will not be able to start standby Bypass EHC pump
  • Added OSP-53 guidance for operating drains
8. Events 7/8/9: Lack of detail or procedural reference.
  • Added Snips of 1C1 to guide
  • Added OSP-53 Hard Card for starting and closing Div 1 D/G
9. Make both DGs fail to start, and when Div 1 DG is manually started its frequency is low.
  • Added to guide that Div 1 D/G must be manually started and raise frequency
10. What other actions is the crew performing with this LOOP/SBO? I want to see them get deeper in this procedure and realign power from offsite via alternate means. Insufficient actions in the EOPs for the examiners to evaluate.
  • Tripped diesel and added EOP-1C1 requirements to be exercised.

Post-Val

1. NRC - Restore DG CT - the crew doesnt know that the DG will trip again so they need to demonstrate the ability to recover from a SBO condition while they have the ability to do so.
  • Restored the DG as the first critical task.
2. Delete CT non-discriminatory or verifiable.
  • Deleted as requested
3. Event 1: changes to rod pull pattern.
  • Specified that rod 2437 needs to be withdrawn from 12 to 48.
4. Event 2: new rod pull pattern, applicant will not be able to insert rod to 00. Edit narrative accordingly.
  • Added a note in the guide to specify that the rod cannot be inserted past position 12.
5. Event 9 body narratives says DG trips 5 minutes after started which is not what we desire. It should trip after being tied to the bus.
  • The DG will trip immediately after its tied to the bus NRC: I would like it to trip maybe a minute after its been tied to the bus so that the operators action to restore power is successful at least for a period of time. Just make it a manual trigger.

Added manual trigger and notes throughout the guide to coordinate with the lead evaluator to manually trip approximately 1 minute after the output breaker is closed.

6. Termination criteria is incorrect.
  • Corrected the Termination criteria

GENERIC JPM Comments

1. Many JPMs have following errors: Inaccurate, incomplete, or missing pedigree data. Applicant cues not matching examiner cues. JPMs not matching Outlines.
2. Remove The task is satisfactorily met when verbiage from task standard (generic - all JPMs).
3. Try to get more steps on a single page where possible. A lot of white space taken up in the Notes field for example.
4. Cleaned up all JPMs to minimize white space.

JPM S1:

1. JPMs have Critical Steps not Critical Tasks. Check all JPMs for this.
2. Remove the cue that steps 1 a-c are complete. They are calls to the field that will take less than a minute. I think it is cleaner to start at the beginning of the procedure. Added steps 1a-c.
3. Task standard needs to state something like a minimum of 250 psig. As written, if someone goes to 260 psig they do not pass. Added minimum of 250 psig to the stem.
4. should be marked modified from December 2010 exam, JPM S4, since the starting of the pump is identical, it is the alternate path that is different. Marked modified from Dec 2010. Included the bank question in submittal.

Post Val

5. 5 minute validation time
6. Applicants cue sheet does not match examiner guide. Deconflict.

Updated validation time and cue sheet.

JPM S-2:

1. Use the formal name of the pumps in the title vice system designator (CCS).

Added formal noun name of the pumps in the title.

2. Initiating cue should not designate steps 5.1 - 5.5 for completion. It simply needs to state IAW SOP-0017, Section 5.1. - examiner will tell applicant when complete. Removed steps 5.1 - 5.1 from the student cue sheet and initiating cue.
3. Step 4 incomplete statement: verified CCS-MOV15C. Corrected step 4 standard.
4. Take the applicant referenced ARP-870-55 out of step 5 standard. We want them to do that but if they stop it from memory we wont fail them for it.

Corrected step 5 standard.

5. Believe there should be a requirement that 2 CCS pumps are running at the end of the JPM. Specifically, if applicant secures P1A before securing P1C, such that

only one CCS pump is running at the end of the JPM, applicant needs to recognize need to restart CCS P1A. Added CCS A and B pumps are running to the terminating cue.

Post Val

6. 5 minute validation time
7. Place CCS-P1C in lockout as part of initial setup so applicant has to reset it as part of step 1, which becomes critical.

Updated validation time and added critical step 1.

JPM S-3:

1. The narrative in outline for this JPM implies the alternate path starts as soon as the HPCS pump is started, which is incorrect. Update the narrative to clarify that the alternate path is triggered on establishing 1000 gpm HPCS flow. Updated narrative in the outline (rev 1).
2. What is initiating HPCS? Step 4 says Low RPV water level - is this spurious?

This is a spurious reactor water level low instrument failure that caused the initiation. Actual water level will not be low.

3. What happens if applicant goes to the alarm response procedure H13-P601/16A/A04? Will it get them to the right place? The ARP is written for an actual initiation, not a spurious or inadvertent initiation. The ARP will not help them.
4. Take this JPM farther and require applicant Stop HPCS pump per AOP step 5.2.3. Added step 5.2.3 to the JPM, but I did not make the step critical.

Post Val

5. 6 minute validation time Updated validation time.

JPM S-4:

1. Initiating cue should not designate steps 4.2.1 - 4.2.5 for completion. It simply needs to state IAW Section 4.2 examiner will tell applicant when complete. Updated the initiating cue in the examiner copy and cue sheet to include only section 4.2.
2. Synopsis sheet with the outline says the K/A is A1.05, the JPM says it is K3.04.

Updated the outline to match the JPM.

3. Page 2 Method of Testing and Location dont have boxes checked. Updated method of testing and location.
4. For procedure step 4.2.1, there is a 5th verification of CMS-AR25A(B),

CONTMT/DRYWELL ANALYZER starts which is not included in JPM step 1.

Updated JPM step 1.

Post Val

5. 5 minute validation time
6. Generic Comment: Step 1 standard should reflect actual actuations. Should specify specifically which SAMPLE SWITCH selected (CONTMT), which sample valve opened, etc etc. Same for all standards.

Updated validation time and corrected standards to be actual manipulations.

JPM S-5:

1. Question pedigree states that this is Alternate Path - it is not. Updated pedigree that it is not an alternate path JPM.
2. K/A on outline doesnt match K/A on JPM. Updated KA on outline to match the KA on JPM.
3. Step 1 standard is not N/A - The standard is that the Applicant N/As the step.

Every step has a standard. Updated step 1 standard.

4. Initiating cue should not designate steps 5.9.1 - 5.9.9. It simply needs to state perform Section 5.9. Updated the cue sheet on the examiner copy and student cue sheet.
5. Outline: The E designator is emergency or abnormal in-plant and should not be applied to S5 on outline. Removed E from the S5 outline JPM S-6:
1. This JPM is effectively identical to Scenario 4 event 2. Replace this JPM. We will keep this JPM as written and change Scenario 4 event 2.
2. Be specific in the task standard and in the steps themselves (Starting with step 1) about what rod is being moved, referenced, identified, and at what position.

Updated cue sheet and examiner guide with rod 16-21 starting at position 10.

3. Will a rod drift alarm come in? Dont see reference to it in step 4 or 5. Added ARP to steps 4 and 5.
4. What procedural guidance is directing the applicants required response? Every alternate path has to have a documented procedurally-directed response, even if it is in general guidance like conduct of operations, etc. Alarm Response Procedure is added to alternate path steps.
5. How far is the rod allowed to drift before the applicants response is inadequate?

The rod is partially withdrawn when the JPM begins and this is not a time critical evolution, so there is no limit on how far the rod can drift before the response is required. There is a chance the rod fully withdraws before the applicant takes action, if the applicant references the ARP first.

6. The initiating cue should state Section 5.1 instead of 5.0. The examiner sheet and applicant cue sheets have been updated with 5.1.
7. The terminating cue should be when the drifting control rod is fully inserted.

Updated the terminating cue to include fully inserting the drifting rod.

Post Val

8. 5 minute validation time Updated validation time.

JPM S-7:

1. K/A on outline doesnt match K/A on JPM. Updated the KA on the outline to match the KA on the JPM.
2. No validation time provided. Updated validation time.
3. Task standard: add in accordance with SOP-53 Section 4.5. This will cover the critical nature of paralleling the DG correctly. Added SOP to the task standard.
4. Specify condition of plant, and grid in initial conditions. Still outstanding and validating in the simulator.
5. Synopsis sheet says the applicant will start on step 8 but the JPM has them starting on step 4.5.13. Verified the synopsis and cue sheets match starting on step 4.5.13.
6. Initiating cue should not designate steps 4.5.13 - 4.5.19. It simply needs to state, starting at step 4.5.13. Examiner and student cues have been updated to remove steps of JPM.

Post Val

7. I wrote down on initiating cue to pick up 500 kw, did we agree this was reasonable?

Added 500kw to cue and guide.

NRC: Terminating cue still says 175 KW Added 500 KW to step 6 and terminating cue. Also added note to step 6 that 500 KW is listed in the initiating cue.

JPM S-8:

1. Outline title should be HIGH-HIGH Rad Signal Updated the title on the outline.

Post Val

2. 5 minute validation time Updated validation time.

JPM P-1:

1. The outline says this JPM is Direct from bank but the JPM says source is New.

Which is it? This a NEW JPM. Made the correction on the outline.

2. Any step on an in-plant JPM in which an applicant is checking or manipulating a component should include an examiner CUE, to include as-found and as-left position of a valve, breaker, etc. GENERIC. Denoted the as-found and as-left positions and indications in the examiner CUE.
3. K/A on outline doesnt match K/A on JPM. Matched the JPM with the outline K/A
4. How much longer would performing all of Enclosure 5 extend this JPM by? The rest of the steps of Enclosure are performed in the Control Room.

JPM P-2:

1. K/A on outline doesnt match K/A on JPM. Matched K/As for the outline with the JPM.
2. I think this should count as an EN JPM as well. Counted this JPM as EN and updated the outline.
3. Is it necessary to have cue cards for these steps? Examiner can more easily just point to Red light on and Green light off. Less paperwork to shuffle around in plant. Remove the cue cards and replaced with instructions in the examiner cue.
4. Task standard: explicitly state the final flow the applicant throttled to. Rewrote the task standard to reflect the final flow value.
5. The narrative for this JPM in the outline is opposite of how it is documented in the JPM. Outline says that applicant attempts to throttle flow using two valves, one of which does not work, and then has to go to flow controller. JPM as written has applicant attempt to throttle flow with flow controller which fails, and has to manually throttle valves. Matched the outline and JPM with the correct desired actions.
6. Try to get more than 1 step per page.
7. Eliminate preferably from cue.
8. Change task title to match first page Cleaned up guide to add multiple steps to page. Removed preferably from the cue and matched the task title.

JPM P-3:

1. K/A on outline doesnt match K/A on JPM. Matched K/As for the outline with the JPM.
2. Task standard: explicitly state the component manipulations required. Generic.

Updated task standard with components. Denoted the as-found and as-left positions and indications in the examiner CUE.

3. Step 5: Should applicant be calling MCR to obtain this information? Added to the standard that the applicant should contact the MCR and added dialogue to the cue.
4. The synopsis sheet states, the applicant will simulate manipulating two manual valves. Not correct. They are manipulating one manual valve and bleeding the air off two other valves. Corrected the information on the outline as requested.
5. NRC Post-Validation: JPM replaced.

RBS: Made the following changes to P-3

  • Changed AS Found position for two valves on step 4 and 5 of JPM

NRC: ALL ADMIN JPMs: Change Terminating Cue to Termination criteria, and change it to Applicant notifies examiner of completion of task. Putting the task standard in the terminating cue is not appropriate because it implies we would only terminate it if the applicant got the right answer.

Updated all admin JPMs Terminating criteria as requested.

JPM A-1:

  • K/A on outline doesnt match K/A on JPM. Matched K/As for the outline with the JPM.
  • Remove The task is satisfactorily met when verbiage from task standard (generic - all JPMs). Removed the verbiage from the task standard.
  • Change task standard for flowrate to 275-290gpm. Both 250 and 300 are not plausible based on accuracy of chart. Recalculate acceptable range of current.

5.75 to 6.25 mA would be acceptable based on curve reading. Replaced 250 and 300 with 275 and 290 with a current range 5.75 to 6.25 ma.

  • We can delete the separate key attachment for this one, fairly simple and self explanatory since you have the charts embedded in the examiner guide. Deleted the key as requested.
  • POST VAL: MARK UP 2ND GRAPH IN examiner guide (RCIC flow conversion)

RBS: Made the following changes to A-1 as requested:

  • Marked up 2nd Graph in the examiner guide as requested JPM A-2:
1. K/A on outline doesnt match K/A on JPM. Matched K/As for the outline with the JPM.
2. Title does match the task, nor the outline. Matched task title for the outline with the JPM.
3. The initiating cue in the JPM says use enclosure 5. The initiating cue handout is correct. Corrected the typo and labeled it enclosure 23.
4. less than 211 inches is not sufficiently discriminatory in the task standard.

Require an explicit range of -246 to -222 inches. This is also fairly wide, but reasonable if they choose to use the graph instead of calculating directly.

Changed the range to -246 and -222 inches.

5. Change initial ECCS SUCTION PRESS TO 27 PSIG. Acceptable rpv level 54 to 56 ft = -258 to -234 inches. Add to applicant answer sheet part 2, does adequate core cooling exist, AND WHY?

RBS: Made the following changes to A-2 as requested:

  • Changed suction pressure to 27 psig from 27.5 in all instances on Guide and cue sheet
  • Added WHY or WHY NOT adequate core cooling to cue sheet (answer sheet)
  • Changed acceptable value to 54 to 56 feet and -258 to -234 inches in guide
  • Made the RO and SRO formatting match where possible JPM A-3:
  • Is the order critical? Changed to work scheduled from lubricate the pump to inspect the casing. A system breach will be required.
  • The task standard should either list the critical components to be tagged, or state, The applicant identified the minimum components to be tagged in accordance with the answer key, attachment 1." Added more detail to the task standard including the order of components tagged.
  • With no system breach this is low level of difficulty, low discriminatory value -

suction, discharge, and breaker. If the order is not critical then some other system should be chosen, or a system breach incorporated. System breach will occur requiring the opening of the drain valve.

  • Outline states tagging out a fire jockey pump, but JPM states tagging out a pressure maintenance pump. While these are the same thing, the terminology should be consistent between the outline and the JPM. Matched the outline with the JPM.
  • Is the control switch critical, if the breaker is tagged open? [yes]
  • What procedural requirement dictates the order in which the tags must be hung?

[EN-OP-102 Protective Tagging]

  • Procedure that dictates order: Att 2 9.0 RBS: Made the following changes to A-3:
  • Added Specify Tagout hang sequence IAW EN-OP-102, ATT 2 section 9.0 to Step 2 performance for reference to sequence.
  • Added procedural guidance for tagging control switch and sequence requirements as reference from EN-OP-102

NRC: Task Standard: Add, in accordance with the key to the end of the task standard, and Provide a filled out Key for the examiner.

Task standard has been updated and key attached to the end of the examiner copy.

JPM A-4:

1. Telling the applicant the dose rate = 2000 mrem/hr and time to complete is 0.5 hr is LOD = 1. Provide a survey map and make the applicant identify the dose rate at the work area, (ignoring transit dose). Then ask the applicant to determine what the maximum stay is directly, vice asking if they are exceeded. Updated the task for the applicant to use a survey map to find the correct area dose rate.
2. The cue sheet given to operator includes information that the individual already has 1650 mrem, but the JPM guide does not state this and its not incorporated into the answer. This makes the part 2 answer incorrect. Since the individual already has 1650 mrem, they have 3350 mrem left to 5000 mrem. Therefore, the maximum stay time is 1.675 hours0.00781 days <br />0.188 hours <br />0.00112 weeks <br />2.568375e-4 months <br />, or 100.5 minutes. This disparity should have been evident on validation before submittal. Matched the cue sheet with the JPM.
3. Provide a starting dose year-to-date for the operator performing the work. 500 mrem
4. Are there any quarterly / site-specific dose limits that are more conservative than the 10cfr limit? [2000 mrem but doesnt apply to this emergency condition]
  • 4.5 rem for Max Admin Guidelines and 2 rem for Routine Annual Admin Guideline (River Bend Admin Limit)
5. Modify part 2 to Determine the maximum stay time allowed to ensure 10CFR20 dose limits are not exceeded.

RBS: Made the following changes to A-4 as requested:

  • Added 500 mrem year to date for operator performing work
  • Changed wording to 10CFR20 for all instances in JPM and Cue Sheet NRC: Add a note to step 2 explaining why the applicant should not subtract the current dose year to date from 5 REM TEDE limit, and the reference for this.

Added reference and note to step 2 for not subtracting the 5 REM.

JPM A-5:

1. JPM doesnt include a KA or rating in guide. Matched K/As for the outline with the JPM.
2. What is the applicant actually filling out? Is there a place where the applicant documents the actual difference between predictor and actual? Changed the task to review the form that is already filled out for discrepancies. Added two discrepancies for the applicant to identify.
3. Not liking that nothing is in error to be identified. Insert some errors. There are two errors for the applicant to identify. Control Rod pattern and MFLCPR.
4. This JPM should have a key identifying actual difference from tolerance. Two errors for the applicant to identify.
5. No validation time. Added a validation time of 10 minutes.
6. Edit step 2 to reference PCMAR in error vice MFLCPR. Same with task standard.

RBS: Made the following changes to A-5 as requested:

  • Changed Step 2 to reflect PCMAR vice MFLCPR and also on the task standard.

NRC: Terminating cue still erroneously says MFLCPR is in error vice PCMAR. ALL ADMIN JPMs: Change Terminating Cue to Termination criteria, and change it to Applicant notifies examiner of completion of task.

Terminating cue has been updated with generic statement.

JPM A-6:

1. K/A on outline doesnt match K/A on JPM. Matched K/As for the outline with the JPM.
2. I prefer the SRO applicant to review a completed calculation, identify error, calculate correct value, then determine required action. Changed the first action of the JPM to review a calculation vice doing a calculation.
3. Same comments on task standard as JPM A-2. Chose different values for this JPM and corrected the task standard.
4. The initiating cue in the JPM says use enclosure 5. The initiating cue handout is correct. Corrected the typo and labeled it enclosure 23.
5. Change initiating cue wording to Review the calculated Containment water level for accuracy IAW
6. Change task standard to applicant determined correct value of calculated Containment Water Level is 54 to 55 feet by direct calculation, or 54 to 56 feet by PCWL plot. Determined corresponding RPV water level of -258 to -246 inches by direct calculation, or -258 to -234 inches by PCWL plot.
7. Add in EOPs should be exited into SAPs because to Task Standard.

RBS: Made the following changes to A-6 as requested:

  • Changed wording to Review the calculated Containment water level for accuracy IAW
  • Changed standard for direct calculation or PCWL plot in task standard and in the steps
  • Added EOPs should be exited and SAPs entered because ACC does not exist with RWL < -211 inches in reactor vessel JPM A-7:
1. Applicant should have a copy of REP-0037 filled out through step 4.1.8. Will provide the applicant with a copy of RE-0037 with appropriate sections filled out.
2. Task standard says has successfully performed Steps 4.1.9 through 4.1.13 of REP-0037 But JPM ends after completion of Step 4.1.12. Corrected the task standard.
3. JPM should require determination of any required actions. Added to the cue and JPM for the applicant to determine any required actions.
4. Post-val: change student handout to indicate %power volts = 65 exactly.
5. Be more specific in task standard about what he is determining.

RBS: Made the following changes to A-7 as requested:

  • Changed to make meter read 65% exactly
  • Added Determine Operability of APRMs and PBDS to task standard JPM A-8:
1. Initiating cue says you must determine / complete the following IAW : IAW what? Rewrote the initiating cue and the questions asked.
2. Task standard: completed the EP-4-ALL form IAW the key. Removed that question from the initiating cue.
3. The JPM guide states the individual has not volunteered, but the applicant cue sheet says Individual has volunteered to complete the task, which makes this a different JPM. Added a list of operators the applicant must choose from to complete the task.
4. Explain why 25 REM is the limit. This appears insufficiently discriminatory for an SRO. Incorporate some additional aspect to include a range of workers of diverse demographics with exposure history and choose the best candidate for the task, if supportable by station guidance. Added a list of operators the applicant must choose from to complete the task.
5. For better discriminatory value, give operator #1 a lifetime dose of 1.3 REM and Operator #3 a lifetime dose of 2.4 REM.
6. Initial conditions: I question if a SAE meets the criteria for Lifesaving or protection of large populations, which is required to exceed 10 REM exposure. I believe we either need to state a General Emergency has been entered, and valve needs to be isolated to protect a large population.

RBS: Made the following changes to A-8 as requested:

  • Changed lifetime dose of operator 1 and 3
  • Changed to General Emergency and added wording about protecting large number of the surrounding population.

JPM A-9:

1. K/A on JPM doesnt match K/A on outline. Matched K/As for the outline with the JPM.
2. Specify in task standard exactly what ALERT was satisfied. Specified the exact ALERT classification in the task standard.
3. Post-Val: eliminate initial condition line item related to diesel/grid impact to reduce number of evaluations needed to be done.

RBS: Made the following change to A-9 as requested

  • Removed diesel/grid impact from initial conditions on guide and cue sheet
  • Removed the short form from the guide and cue sheet. Added to the cue sheet to write declaration on the cue sheet.

NRC: Add within 15 minutes to the task standard.

Added within 15 minutes to the task standard and step 2.

Final Branch Chief Comments - Resolved as Requested

  • A2: Task standard: For better clarity, modify 2nd sentence to Determine corresponding RPV water level is -258 to -246 inches (for PCWL determined by direct calculation) or -258 to -234 inches (for PCWL determined from graph).
  • A4: task standard, should say 5000 mrem, not rem
  • A4: Task Standard: Modify to read: The applicant has successfully determined expected dose from the evolution was 1000 mrem and the maximum stay time allowed IAW 10CFR20 limit of 5000 mrem during a classified emergency is 2.5 hrs or 150 minutes.
  • A4: Initiating cue #2 to the applicant, modify to Determine the maximum stay time allowed in accordance with the Emergency Plan to ensure 10CFR20 Dose Limits for TEDE are NOT exceeded.
  • A4: Throughout JPM (other than Task Standard), replace 10CFR20, Occupational Dose Limits for TEDE with 10CFR20 dose limits for TEDE. This is consistent with the terminology in EP-4-ALL without cueing. The phrase 10CFR20, Occupational Dose Limits for TEDE, as written, implies the annual dose limit for (routine) occupational exposure as opposed to the 5 rem authorization for emergency workers.
  • A4: Applicant handout, Initial conditions, modify to An unisolable steam leak in the Main Steam Tunnel has occurred and an operator is needed to manually close G33-MOVF004, PUMP SUCTION CNMT OUTBOARD ISOL. The term operator is preferable because we dont distinguish the need for a volunteer until exposures > 25 REM are required.
  • A6: Task standard: For better clarity, modify 2nd sentence to Determine corresponding RPV water level is -258 to -246 inches (for PCWL determined by direct calculation) or -258 to -234 inches (for PCWL determined from graph).
  • A7: Add missing word to Step 3: "(Step 4.1.11) Operations will determine if bypassing the LPRM will CAUSE APRM A inoperable per Step 3.2.
  • A8: eliminate 10CFR20.1201 from Required Materials, not needed to complete JPM.
  • A8: Change K/A to G2.3.14 (jpm and outline)
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