CP-201600437, Comment (23) of Kenneth J. Peters on Behalf of Luminant Generation Company LLC on Draft NUREG-1021, Rev. 11, Operator Licensing Examinations Standard for Power Reactors.

Comment (23) of Kenneth J. Peters on Behalf of Luminant Generation Company LLC on Draft NUREG-1021, Rev. 11, Operator Licensing Examinations Standard for Power Reactors.

ML16137A501
Person / Time
Site:	Comanche Peak
Issue date:	05/05/2016
From:	Peters K Luminant Generation Co
To:	Cindy Bladey Rules, Announcements, and Directives Branch
References
81FR6301-1 00023, CP-201600437, NUREG 1021, Rev 11
Download: ML16137A501 (5)

Text

II Luminant CP-201600437 TXX-16069 May5, 2016 U.S. Nuclear Regulatory Commission Office of Administration OWFN-12-H08 Washington, DC 20555-0001 ATTN: Ms. Cindy Bladey Kenneth J. Peters Senior Vice President

& Chief Nuclear Officer Kenneth.Peters@luminant.com Ref: rJt.. &otJJ-I 0J

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 & 50-446 Luminant Power P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 6565 c 817 776 0037 f 254 897 6652 w V1 COMMENTS ON DRAFT NUREG 1021REV.11, "OPERATOR LICENSING EXAMINATION STANDARDS FOR POWER REACTORS"

REFERENCE:

1) Federal Register Notice/Vol.

81, No. 42/ March 3, 2016

Dear Ms. Bladey:

Per Reference 1, Lurninant Generation Company LLC (Luminant Power) is submitting comments on the draft NUREG 1021, Rev. 11, "Operator Licensing Examinations Standard for Power Reactors.

If there are any questions concerning this submittal, contact Mr. Garry W. Struble at (254) 897-6628 (office) or (254) 396-6286 (cell). SCD Sincerely, Luminant Generation Company LLC Kenneth J. PeteA /" By: ThomaU. McCool Site Vice President

! SUNSI Review Complete I Template=

ADM-013 E-RIDS= ADM-03 Add= "-n?* b0-5 '7) I /j:'A#-&ek)-

U.S. Nuclear Regulatory Commission TXX-16069 Page2 5/5/2016 Attachment-Comanche Peak Comments on Draft NUREG-1021, Revision 11 c -Marc L. Dapas, Region IV clo Vincent Gaddy, Region IV clo M. Watford, NRR clo Resident Inspectors, CPNPP clo Attachment to TXX-16069 ID Section and Page Appendix D, C.1.f Pages D-7 and D-8 Comanche Peak Comments on Draft NUREG-1021, Revision 11 * "Operator Licensini:i ExaminationStandards for Power Reactors

Comment The new 50% overlap requirement will likely result in less operationally challenging exams. Current scenarios are developed containing a complexity of events to discriminate between a competent and incompetent operator.

The new overlap requirement will lead to use of malfunctions and events that are less discriminating.

Most simulators have hundreds of malfunctions but a small percentage actually leads to observable discriminatory actions. There are also a very small number of major events. It is true that there are variable cause, location and size LOCAs, MSLBs, SGTRs, and Loss of All AC Power malfunctions but the ERGs lead essentially to the same conclusion for these major events. For LOCAs it is either cold leg recirculation, post LOCA cooldown and depressurization or loss of emergency recirculation.

The overlap limitation will also lead to longer than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> scenarios as the path to all but a limited number of contingency procedures and functional restoration guidelines coupled with the minimum number of opportunities for each position takes significantly more time. This .requirement will also challenge validation resources at each station as more time will be required to validate the scenarios with current licensed operators, which in turn challenges the work hour rule regulations.

1 Proposed Resolution This requirement should be excluded from the revision as it will only serve to fatigue the applicants during administration and the examination writers during development.

It will .also challenge federal work hour rule regulations for validation purposes.

With strained validation prior to NRC on site validation this change will also likely lead to more changes during the on-site validation.

Ensure that Form 301-4 is not revised with the 50% overlap requirement.

Attachment to TXX-16069 ES-301, D.5.b The new 50% overlap requirement will likely result in less This requirement should be excluded from Page 15 of 31 operationally challenging exams. Current scenarios are developed the revision as it will only serve to fatigue the containing a complexity of events to discriminate between a applicants during administration and the competent and incompetent operator.

The new overlap requirement examination writers during development.

It will lead to use of malfunctions and events that are less will also challenge federal work hour rule discriminating.

Most simulators have hundreds of malfunctions but a regulations for validation purposes.

With small percentage actually leads to observable discriminatory strained validation prior to NRC on site actions. There are also a very small number of major events. It is validation this change will also likely lead to true that there are variable cause, location and size LOCAs, MSLBs, more changes during the on-site validation.

SGTRs, and Loss of All AC Power malfunctions but the ERGs lead essentially to the same conclusion for these major events. For Ensure that Form 301-4 is not revised with LOCAs it is either cold leg recirculation, post LOCA cooldown and the 50% overlap requirement.

depressurization or loss of emergency recirculation.

The overlap limitation will also lead to longer than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> scenarios as the path to all but a limited number of contingency procedures and functional restoration guidelines coupled with the minimum number of opportunities for each position takes significantly more time. This requirement will also challenge validation resources at each station as more time will be required to validate the scenarios with current licensed operators, which in turn challenges the work hour rule regulations.

ES-303, D.1.d New method of grading TS evaluation opportunities will result in This requirement should be excluded from Page 3 of 9 unbalance difficulty between exams. Under current guidelines each the revision OR add clarification that a single event can only have 1 TS evaluation for a design target of 2, as that event that requires 2 TS action statements to not all Technical Specification component failures are not equal, the be entered will meet minimum design criteria.

new requirement will result in some applicants having significantly While this solution will not completely more opportunities to fail. eliminate the concern, it makes it much more manageable when designing quality exams. ES-303, D.2.b Changing the lowest rating factor from 1 to 0 is unnecessary and will Retain the guidance in NU REG 1021, Pages 5 & 6 of 19 requires facilities to expend resources aligning current practices and Revision 10 and make it a practice of using procedures to the change. NRC examiners and the NUREG already the guidance in ES-303 Section 2, Page 1-19 recognizes that sometimes the grading does not match the Lines 4-8 to resolve conflicts between the performance and judgment is required for a licensing decision.

See calculated grade and the judgment of the ES-303 Section 2, Page 1-19 Lines 4-8 for further details. This examiner.

change will expend significant resources for what experience has shown is less than a 1 % occurrence.

Ensure that Forms ES-303-1, ES-303-3, and ES-303-4 are not revised with the 0, 1, 2, 3 grading scales. 2 Attachment to TXX-16069 ES-303, D.2.b The proposed language of Revision 11 eliminates the allowance to give Retain the guidance in NU REG 1021, Revision Page 5of19 points back for noncritical errors. This allowance was necessary to 10, "If an applicant makes a single error related provide a candidate who is competent but makes just a few errors to be to a rating factor, circle an "If an applicant penalized without relief. makes two errors related to a rating factor, During a scenario an applicant can have multiple chances to show circle an "RF Score" of "1 "for that rating factor competency in an area. Some scenarios provide more than the unless the applicant correctly performed expected three chances and therefore can fail the applicant who is at another the minimum standard.

The practice of allowing points back can provide activity (or activities) related to the same rating the examiner a better picture of the candidate's ability. Due to the factor, in which case the "RF number ratings being revised to a more stringent criteria, this is even Score" shall remain at "2." In either case, a more important to the rating of the candidate than in previous exams. justification of the "RF Score" shall be documented on the applicant's Form ES-303-2.

For example, a score of "1" shall include documentation such as "the applicant correctly performed no other activities related to this RF during the simulator operating test'; whereas a score of "2" shall include documentation such as 'the applicant correctly performed another activity associated to this rating factor'. As stated above, if an error is related to a critical task then this requires an "RF Score" of "1." ES-303, D.2.b In the proposed revision, a missed critical task (CT} would result in a 3 Retain the guidance in NUREG 1021, Revision Page 6of19 point reduction with a score of 0. This appears to over penalize the 10 with regard to critical errors. applicant.

Revision 10 had a decrease of 2 points for this issue and since a 0 has more consequences on the overall grade, consideration should be given to a 2 point deduction.

If the applicant has more issues past 1 Critical error, they will appear and be graded in other areas, which would then lead to failure of the applicant.

3 II Luminant CP-201600437 TXX-16069 May5, 2016 U.S. Nuclear Regulatory Commission Office of Administration OWFN-12-H08 Washington, DC 20555-0001 ATTN: Ms. Cindy Bladey Kenneth J. Peters Senior Vice President

& Chief Nuclear Officer Kenneth.Peters@luminant.com Ref: rJt.. &otJJ-I 0J

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 & 50-446 Luminant Power P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 6565 c 817 776 0037 f 254 897 6652 w V1 COMMENTS ON DRAFT NUREG 1021REV.11, "OPERATOR LICENSING EXAMINATION STANDARDS FOR POWER REACTORS"

REFERENCE:

1) Federal Register Notice/Vol.

81, No. 42/ March 3, 2016

Dear Ms. Bladey:

Per Reference 1, Lurninant Generation Company LLC (Luminant Power) is submitting comments on the draft NUREG 1021, Rev. 11, "Operator Licensing Examinations Standard for Power Reactors.

If there are any questions concerning this submittal, contact Mr. Garry W. Struble at (254) 897-6628 (office) or (254) 396-6286 (cell). SCD Sincerely, Luminant Generation Company LLC Kenneth J. PeteA /" By: ThomaU. McCool Site Vice President

! SUNSI Review Complete I Template=

ADM-013 E-RIDS= ADM-03 Add= "-n?* b0-5 '7) I /j:'A#-&ek)-

U.S. Nuclear Regulatory Commission TXX-16069 Page2 5/5/2016 Attachment-Comanche Peak Comments on Draft NUREG-1021, Revision 11 c -Marc L. Dapas, Region IV clo Vincent Gaddy, Region IV clo M. Watford, NRR clo Resident Inspectors, CPNPP clo Attachment to TXX-16069 ID Section and Page Appendix D, C.1.f Pages D-7 and D-8 Comanche Peak Comments on Draft NUREG-1021, Revision 11 * "Operator Licensini:i ExaminationStandards for Power Reactors

Comment The new 50% overlap requirement will likely result in less operationally challenging exams. Current scenarios are developed containing a complexity of events to discriminate between a competent and incompetent operator.

The new overlap requirement will lead to use of malfunctions and events that are less discriminating.

Most simulators have hundreds of malfunctions but a small percentage actually leads to observable discriminatory actions. There are also a very small number of major events. It is true that there are variable cause, location and size LOCAs, MSLBs, SGTRs, and Loss of All AC Power malfunctions but the ERGs lead essentially to the same conclusion for these major events. For LOCAs it is either cold leg recirculation, post LOCA cooldown and depressurization or loss of emergency recirculation.

The overlap limitation will also lead to longer than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> scenarios as the path to all but a limited number of contingency procedures and functional restoration guidelines coupled with the minimum number of opportunities for each position takes significantly more time. This .requirement will also challenge validation resources at each station as more time will be required to validate the scenarios with current licensed operators, which in turn challenges the work hour rule regulations.

1 Proposed Resolution This requirement should be excluded from the revision as it will only serve to fatigue the applicants during administration and the examination writers during development.

It will .also challenge federal work hour rule regulations for validation purposes.

With strained validation prior to NRC on site validation this change will also likely lead to more changes during the on-site validation.

Ensure that Form 301-4 is not revised with the 50% overlap requirement.

Attachment to TXX-16069 ES-301, D.5.b The new 50% overlap requirement will likely result in less This requirement should be excluded from Page 15 of 31 operationally challenging exams. Current scenarios are developed the revision as it will only serve to fatigue the containing a complexity of events to discriminate between a applicants during administration and the competent and incompetent operator.

The new overlap requirement examination writers during development.

It will lead to use of malfunctions and events that are less will also challenge federal work hour rule discriminating.

Most simulators have hundreds of malfunctions but a regulations for validation purposes.

With small percentage actually leads to observable discriminatory strained validation prior to NRC on site actions. There are also a very small number of major events. It is validation this change will also likely lead to true that there are variable cause, location and size LOCAs, MSLBs, more changes during the on-site validation.

SGTRs, and Loss of All AC Power malfunctions but the ERGs lead essentially to the same conclusion for these major events. For Ensure that Form 301-4 is not revised with LOCAs it is either cold leg recirculation, post LOCA cooldown and the 50% overlap requirement.

depressurization or loss of emergency recirculation.

The overlap limitation will also lead to longer than 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> scenarios as the path to all but a limited number of contingency procedures and functional restoration guidelines coupled with the minimum number of opportunities for each position takes significantly more time. This requirement will also challenge validation resources at each station as more time will be required to validate the scenarios with current licensed operators, which in turn challenges the work hour rule regulations.

ES-303, D.1.d New method of grading TS evaluation opportunities will result in This requirement should be excluded from Page 3 of 9 unbalance difficulty between exams. Under current guidelines each the revision OR add clarification that a single event can only have 1 TS evaluation for a design target of 2, as that event that requires 2 TS action statements to not all Technical Specification component failures are not equal, the be entered will meet minimum design criteria.

new requirement will result in some applicants having significantly While this solution will not completely more opportunities to fail. eliminate the concern, it makes it much more manageable when designing quality exams. ES-303, D.2.b Changing the lowest rating factor from 1 to 0 is unnecessary and will Retain the guidance in NU REG 1021, Pages 5 & 6 of 19 requires facilities to expend resources aligning current practices and Revision 10 and make it a practice of using procedures to the change. NRC examiners and the NUREG already the guidance in ES-303 Section 2, Page 1-19 recognizes that sometimes the grading does not match the Lines 4-8 to resolve conflicts between the performance and judgment is required for a licensing decision.

See calculated grade and the judgment of the ES-303 Section 2, Page 1-19 Lines 4-8 for further details. This examiner.

change will expend significant resources for what experience has shown is less than a 1 % occurrence.

Ensure that Forms ES-303-1, ES-303-3, and ES-303-4 are not revised with the 0, 1, 2, 3 grading scales. 2 Attachment to TXX-16069 ES-303, D.2.b The proposed language of Revision 11 eliminates the allowance to give Retain the guidance in NU REG 1021, Revision Page 5of19 points back for noncritical errors. This allowance was necessary to 10, "If an applicant makes a single error related provide a candidate who is competent but makes just a few errors to be to a rating factor, circle an "If an applicant penalized without relief. makes two errors related to a rating factor, During a scenario an applicant can have multiple chances to show circle an "RF Score" of "1 "for that rating factor competency in an area. Some scenarios provide more than the unless the applicant correctly performed expected three chances and therefore can fail the applicant who is at another the minimum standard.

The practice of allowing points back can provide activity (or activities) related to the same rating the examiner a better picture of the candidate's ability. Due to the factor, in which case the "RF number ratings being revised to a more stringent criteria, this is even Score" shall remain at "2." In either case, a more important to the rating of the candidate than in previous exams. justification of the "RF Score" shall be documented on the applicant's Form ES-303-2.

For example, a score of "1" shall include documentation such as "the applicant correctly performed no other activities related to this RF during the simulator operating test'; whereas a score of "2" shall include documentation such as 'the applicant correctly performed another activity associated to this rating factor'. As stated above, if an error is related to a critical task then this requires an "RF Score" of "1." ES-303, D.2.b In the proposed revision, a missed critical task (CT} would result in a 3 Retain the guidance in NUREG 1021, Revision Page 6of19 point reduction with a score of 0. This appears to over penalize the 10 with regard to critical errors. applicant.

Revision 10 had a decrease of 2 points for this issue and since a 0 has more consequences on the overall grade, consideration should be given to a 2 point deduction.

If the applicant has more issues past 1 Critical error, they will appear and be graded in other areas, which would then lead to failure of the applicant.

3