ML23018A188
| ML23018A188 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/28/2022 |
| From: | Nuclear Management Co |
| To: | NRC/RGN-III/DORS/OB |
| Iskierka-Boggs T | |
| Shared Package | |
| ML21188A291 | List: |
| References | |
| Download: ML23018A188 (1) | |
Text
Monticello Operating Test Outline Identified Issues:
Form 3.2-1 RO ADMIN JPMs COO2 K/A listed as 2.1.45 with IR of 4.2. NUREG-1123 Rev 3 has 2.1.45 with IR 4.3 (editorial change). DONE-SAT.
Verify EC JPM (IV of RCIC-S,N) is really New from (IV of HPCI-2018); same JPM Number? Compare JPM Steps. DONE-New JPM-SAT.
Form 3.2-1 SRO ADMIN JPMs Potential for 3 JPMs on this exam from previous two exams:
o Outline form states that only 1 is allowed to be randomly selected from the previous 2 exams. Does this mean that only 1 can be allowed directly from the past, or does it allow for 1 direct and 1 modified to be included?
(Allowed 1 P and 1 N or M-SAT.)
COO1 is from 2018 exam and is identified as being MODIFIED. (Missing P for Previous 2 exams on the form)
(Verify how modified - also, is this an SRO-only job task? Do ROs perform a Pre-job Brief?) SRO Task & JPM is Modified-SAT.
RC is from 2020 exam and is DIRECT. Is actually the allowed P-SAT.
o COO2 SRO - License Maintenance Responsibilities was used on 2020 exam.
The JPM numbers for the two activities are different though, need to verify that different aspect is being tested. DONE-SAT.
o EC JPM for 2022 exam is same as 2018 but with different JPM number listed (listed on Form 3.2-1 for the 2016 Exam). Ensure that different requirement/door being tested. DONE-SAT.
K/A IRs not included (required?) on the form. All verified to be greater than 2.5 JPM RC K/A Listed is 2.3.15 which is DELETED in NUREG-1123, Rev 3. Needs a new K/A assigned or task needs to be changed. K/A changed-2.3.11-SAT.
Form 3.2-2 Control Room and In-Plant JPMs JPM a (CRD Pump Swap over) identified as being on 2020 exam. Exact same JPM title and number also used on the 2018 exam. Is there an issue having the exact same JPM on three exams in a row? (I would prefer that it is not used, or if used, modified to not be the same as previous two exams) (not prohibited)-SAT.
JPM c (Respond to Inadvertent ADS) lists K/A as 218000 A4.02, Ability to manually operate and/or monitor in the control room: ADS logic initiation (IR 4.2).
o Should A4.03 for Ability to manually operator and/or monitor in the control room:
ADS logic reset be used instead for more accurate applicability? SAT.
JPM g - K/A is documented as A4-01 and should be changed to A4.01 for consistency.
DONE-SAT.
Form 3.2-2 Numbers (All meet requirements)
RO Form Numbers: 4 Alternate; 9 Direct; 2 Emergency; 1 Engineering; 1 low power; 2 New 0 Mod; 3 previous; 2 RCA SRO Form Numbers: 4 Alternate; 8 Direct; 2 Emergency; 1 Engineering; 1 low power; 2 New 0 Mod; 3 previous; 2 RCA SCENARIO POTENTIAL ISSUES from Form 3.4-1 Events and Evolutions Scenario 2, Event 7 (Major) for SRO in ATC is counted as the second MC for this applicant. If the BOP performs these actions, then the SRO applicant will have had to completed Scenario 1 Event 3 (SJAE PCV fails) as the BOP to obtain proper MC credit.
(Extra is built in, but something to watch for during OV)
Scenario 3, Event 8 (after Major) for SRO in ATC has 2 MCs in this scenario. Event 8 being after the major has potential to be performed by BOP. If the ATC SRO does not perform Scenario 3 Event 5 (A CRD FCV fails close) then this applicant does not meet MC credit. (Extra is built into scenario, but something to watch for during OV)
SCENARIO EVENT COMPARISON DUPLICATES:
All scenarios have at least 4 events in them that are not found on previous 2 exams.
Events used from previous exams come from different exams and not all on the same one. Therefore, the scenarios meet the NUREG guidelines for New scenarios and does not fall into modified.
SCENARIO 1 Event 2 (A MFRV Lockup) used on 2018 Exam Scenario 3 Event 2 Event 3 (A SJAE PCV Fail Closed) used on 2018 Exam Scenario 3 Event 3 Event 4 (Degraded vacuum reduce recirc flow) used on 2018 Exam Event 4 Event 7 (RWCU fail to isolate when SBLC is injected) used on 2018 Exam Event 7 (3 new events - SAT.)
SCENARIO 2 Event 2 (OATC raise power using RR to ~45%) used on 2020 Exam Scenario 2 Event 2 (Reactivity Manipulations arent subject to Previous use rule.)
Event 4 (CR seal fail drift in) similar to 2018 Exam Scenario 1 Event 2 (different rod used)
Event 3 (RCIC inadvert initiation) used on 2020 Exam Scenario 2 Event 3 Event 4 (Operational Basis Earthquake causes 11 Srvc Wtr Pump trip) used on 2018 exam Scenario 2 Event 7. Major is same as well but failure following Design base earthquake is slightly different. 2022 has LOCA w/LOOP, 2018 has unisolable TORUS leak. Meets NUREG requirements for modifying the major to affect the events following the major.
(4 new events - SAT.)
SCENARIO 3 (Spare)
Event 1 (perform test 0141) used on 2018 Exam Scenario 3 Event 1, and on 2020 SPARE (Still OK since the Spare was not used in 2018. SAT.)
Event 2 (11 recirc pump runback to 30%) used on 2020 SPARE. (Still OK since the Spare was not used in 2018. SAT.)
Event 4 (11 RBCCW trip and 12 RBCCW fail to start) used on 2018 Exam Scenario 1 Event 3 Event 5 (A CRD FCV fail closed) used on 2020 SPARE. (Still OK since the Spare was not used in 2018. SAT.)
Event 9 (C ADS ARV Fail open upon Blowdown) used on 2020 SPARE.
(Still OK since the Spare was not used in 2018. SAT.)
(4 new events - SAT.)
EXAM SCHEDULE:
Overall, the proposed exam schedule appears to be satisfactory Mon - Wed has all 3 scenarios being performed along with a SIM JPM, and Admin JPMs. Being only 3 examiners (with Troy) there is a potential for longer days. I am okay with this as long as the facility feels they can perform all of these activities in one day and not have anything run over to the next day.
I am good with the assignment of examiners to applicants.