ML17138A297

Comment (3) of Gregory R. Cameron on Behalf of Nuclear Energy Institute on NUREG-1122, Revision 3, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors and NUREG-1123, Revision 3, Knowledge and Abili

ML17138A297
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/15/2017
From:	Cameron G Nuclear Energy Institute
To:	Cindy Bladey Rules, Announcements, and Directives Branch
References
82FR18018 00003, NRC-2017-0068
Download: ML17138A297 (13)

Text

{{#Wiki_filter:GREGORY R. CAMERON Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004

                                                                                                                                        ~I NUCLEAR ENERGY INSTITUTE P: 202.739.8105 grc@nei.org nei.org
                                                     /f/; ~       /0I 7 "Tl May 15, 2017                                       ff ttP!C /~~! ~                                                 .... -*~..... ,,)

Ms. Cindy K. Bladey  :! ~-C :I:,.- Chief, Rules, Announcements, and Directives Branch c**--

                                                                                                                                                                     --'

Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

NEI Comments on NUREG-1122, Revision 3, "Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors" and NUREG-1123, Revision 3, "Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors." 82 FR 18018; Docket ID NRC-2017-0068 Project Number: 689

Dear Ms:

Bladey: On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments on the subject NUREG-1122, Revision 3, "Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors" and NUREG-1123, Revision 3, "Knowledge and Abilities catalog for Nuclear Power Plant Operators: Boiling Water Reactors." NEI's Licensed Operator Focus Group worked cooperatively with NRC staff throughout the revision process for both NUREG-1122 and NUREG-1123. We support the conceptual changes contained therein. Our attached comments recommend improvements in formatting and phrasing which promote consistency and enhance usability. We appreciate the NRC staff's consideration of these comments. If you have any questions concerning this letter or the attached comments, please contact me. 1 The Nuclear Energy Institute (NE!) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry. NUCLEAR. CLEAN AIR ENERGY SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= CY* _d--{J//e.-r <i/-5~)

                                                                                                                                                          - - - - - - - ___ J

Ms. Cindy K. Bladey May 15, 2017 Page 2 Sincerely, Gregory R. Cameron Attachments c: Ms. Nancy Salgado, NRR, NRC NRC Document Control Desk

ATTACHMENT 1 I NE! Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3

• Comment Section/Page Recommendation Justification

1 General/Sections Recommend inserting page headers on all pages Page headers showing the system title/number or 3 and 4. in the systems and EAPE sections. Specifically EAPE title/number have been removed from sections 3 and 4. Sections 5 and 6 are referenced subsequent pages. They are very important for infrequently by the end user and do not necessarily the end user of the catalog. need headers on each page. 2 Section 1.15, Recommend removing "Fuel handling is not an There is no guidance which makes the fuel fourth bullet, RO license activity and will have NIA marked in handling system specific to SROs. As noted Page 1-11 the RO column." below, the fuel handling system K/As should have two sets of!Rs for all K/As. See Comment 14. 3 Summary of Number 6. states" ... replaced with a single IR Fuel Handling system also has single !Rs for all Significant EXCEPT for the A2, G and fuel handling but A2 KAs. Alternately, bring back RO and Changes/xi categories. SRO ratings for each FH topic as noted in Recommend replacing with "EXCEPT for the A2 Comment 14. and G categories." 4 Section 2, Recommend designating the following K/As as During discussions between the industry and Generic KAs "Operating Exam Preferred": 2.1.6, 2.1.9, 2.1.14, NRC regarding changes to the KIA catalogs, one 2.1.17, 2.1.18, 2.1.19, 2.1.21, 2.1.30, 2.1.31, of the points of agreement was that K/As which 2.1.38, 2.2.2, 2.4.47, 2.4.49, 2.4.50 lend themselves to measurement during the scenarios and/or JPMs would be designated as such in the KIA catalogs. 5 General The following KIA stem statements do not match PWR catalog has "and/or" (generally) and BWR between the PWR and BWR catalogs: catalog has "or". For consistency, remove the Systems - Kl, K4, Al, A4 "and/" from these statements in the PWR EAPEs - E/AKI, E/AAI, E/AA2 catalog. Recommend matching 1122 with 1123. 6 Section I/ Recommend changing Kl Stem Statement to Promote consistency between catalogs. The

ATTACHMENT 1 I NE! Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

Page 1-S match NUREG-2103: "Knowledge of the physical "new" catalogs capture the idea of interaction or control/protection logic relationship between between systems better than the "old catalogs. the [SYSTEM] and the following systems:" 7 Section I/ Recommend changing K 1 Basis statement to The basis statement currently provided provides Page 1-S read: historical data without providing a helpful basis "K 1 contains the systems that have a connection to to the end user trying to author questions. The the [SYSTEM]. The selected (systems) listed basis statements should simply provide an have either a plant protection/logic relationship or explanation for what is in the KIA. physical piping relationship to the [SYSTEM]. Electrical systems are addressed in K2. Controls and interlocks are addressed in K4. Cause and effect relationships from system interactions may be tested in K 1, as appropriate. The operational implications of these relationships are addressed in KS." 8 Section 1/ Recommend changing KS basis statement to read: Proposed basis statement contains historical Page 1-6 "KS.contains theoretical concepts related to the information which is not relevant to its operation of the system and resulting operational application. Historical information should be put implications." in the revision log if desired. 9 Section I/ Recommend changing K6 basis statement to read: Proposed basis statement contains historical Page 1-6 "K6 includes systems listed in Kl and K2 which information which is not relevant to its will have an effect on the (SYSTEM) ifthe K6 application. Historical information should be put listed system or component is not operating in the revision log if desired. according to design. K6 also contains (SYSTEM) components whose failure can affect the operation of the (SYSTEM). 2

ATTACHMENT I I NE! Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

JO Section I/ Recommend changing Al basis statement to read: Proposed basis statement contains historical Page 1-6 "A I includes parameters monitored to verify information which is not relevant to its proper operation of the system or indications that application. Historical information should be put "the system is outside of normal operating bands." in the revision log if desired. II Section I/ Recommend adding the (SYSTEM) name to the Maintain consistency with all other stem Page 1-6 A4 statement: statements which include the system name.

                             "A4. Ability to manually operate or monitor the (SYSTEM) in the control room.

12 Section I.I 0/ Recommend adding the following to the Supports the changes to the basis stateme11ts Page 1-7 paragraph begins "Section 4 of the ... " listed below. Add: "Note that an EAPE is a condition, event or symptom and not the procedure itself." 13 Section I, Table Recommend changing the basis statements for To avoid any confusion about what is allowed to 4, Page 1-9 and E/AKl, E/AK2, E/AK3, E/AAI and E/AA2 as be tested for EAPEs, clarification should be 1-10 follows: added to this section. E/AK I Basis - Tests the operationally-based As noted in section 1.10, EPEs are conditions, theoretical concepts applicable to the [EVENT]. events or symptoms which leads to entry into an These items may be addressed by procedure bases, EOP. APEs are conditions, events or symptoms PRA, operating experience, procedure notes, which lead to AOP entry. Note that definition of cautions or integrated system response. "evolution" in this context is "condition/ event/symptom" as opposed to "procedure". E/AK2 Basis -Tests how listed systems are impacted by the [EVENT]. The basis statements all contain the word "procedure" and most EAPE KAs do lend E/AK3 Basis - Tests the reasons for taking the themselves to testing information contained listed action/response during the [EVENT]. within the related procedure but NOT all of the EAPE KAs allow for an item to be written to test procedure knowledge to meet the plain meaning 3

ATTACHMENT I I NE! Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

E/AA I Basis - Tests the ability to operate or of the KA. monitor systems or components during the [EVENT]. This includes monitoring plant system For example, there are many operator actions response during all phases of the [EVENT]. and many plant automatic responses which occur during the initial phases of an "emergency plant E/AA2 Basis - Tests the ability to monitor the evolution" where "conditions/events/symptoms" listed condition or parameter and interpret its are present but the procedure has not yet been importance to the [EVENT] or the [EVENT] entered. response. Rather than create a situation where entire classes of questions are systematically excluded (diagnostics, plant response to transients, basis for design features), guidance should allow questions which address all phases of emergency/abnormal conditions not just those which are contained in procedural guidance. For example, consider APE 056 Loss of Offsite Power and the AA I KAs which test the ability to operate or monitor many, many different systems and components. If only the items listed in the "Loss of Offsite Power" procedure can be tested, then many of these AA! KAs will be untestable and untested. This is, clearly, not the intent. The intent is to test as broadly as possible, testing knowledge within the procedures and also ensuring understanding of other impacts which may not be explicitly addressed therein. 4

ATTACHMENT I [ NEI Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

14 Section 3.8/ Recommend maintaining separate !Rs for ALL All Fuel Handling system KAs are individually Pages 3.8-13 Fuel Handling System KAs selectable on either RO or SRO outline. As through 3.8-15 such, each individual KA should have its own importance rating. This is especially important where some KAs might be <2.5 for one type of license but::=:: 2.5 for the other type. (If this recommendation is implemented, Comment #2 above should NOT be implemented.) 15 Sections 5 and 6 Recommend using a single IR for GFE KAs. Since the same GFE exam is given to all, there is no benefit for maintaining two sets of IR for GFE KAs. 16 KA 007.K5.08 Recommend adding the word "safety valves". Currently states Page 3.5-4 "Recognition of leaking PO RVs/code" 17 Throughout Evaluate use of ESAS and other vendor-specific To eliminate confusion, correlating systems from terms and systems and determine applicability to different vendors should be added to the other vendors or the equivalent systems from the applicable KAs to ensure the catalog is applied other vendors. For example, ifthe ESAS system consistently. One Westinghouse plant could at BW performs the same function as the ESFAS receive an "ESAS" KA and ask for it to be system for Westinghouse, then the ESAS KAs replaced because they do not have ESAS. should say ESAS/ESFAS. This is just one Another could write a question for ESFAS, potential example. Others are EFIC, CEA, JCS, assuming that the systems do the same thing only BWST, RWST, CFT, QSPDS, SPDS, CFT, SIT. to have their question rejected as not meeting the Recommend adding a comprehensive list of KA. A third could ask for a replacement and be equivalent systems to the catalog. told to write an ESF AS question by their chief. Providing clear, concise, complete KAs helps ensure consistency in application. Recognizing that guidance is included on Page 1-12 that addresses this concern, it would still be helpful to have a more complete list of equivalent 5

ATTACHMENT 1 I NEI Comments on NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

systems since exam authors with knowledge of a single vendor may not have sufficient knowledge to know what systems are called elsewhere. 18 KA 012.K4.0l Recommend spelling out OOC (presumably out OOC is not defined in the Acronym list and not Page 3.7-3 of commission? or out of calibration?) used elsewhere in the catalog. 19 Pages Recommend designating the 053 system NUREG-1021, Form ES-401-2 does NOT 3.1-1, 3.1-23, (Integrated Control System) as BW only in the KA indicate that !CS is limited to BW only. In order 3.4-1, 3.4-15 catalog system section to ensure that CE and W plants do not get !CS KAs on their sample plans, this system should be designated at BW only in the KA catalog and in the next revision ofNUREG-1021. This will help ensure consistency in application. 6

ATTACHMENT 2 NEI Comments on NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

1 General/Sections Recommend placing page headers on all pages in Page headers showing the system title/number or 3 and 4 the systems and E/APE sections (like Rev. 2). EAPE title/number have been removed from Specifically sections 3 and 4. Sections 5 and 6 are subsequent pages. They are very important for referenced infrequently by the end user and do not the end user of the catalog. necessarily need headers on each page. 2 General/Sections Recommend using Title Case for all system and Greatly improves readability. 3 and 4 E/APE names in Sections 3 and 4. 3 Summary of Number 6. states " ... replaced with a single IR Fuel Handling system also has single IRs for all Significant EXCEPT for the A2, G and fuel handling but A2 K/As. Alternately, bring back RO and Changes/xi categories." SRO ratings for each FH topic as noted in Recommend replacing with "EXCEPT for the A2 Comment 14 below. and G categories." 4 Section 2, Recommend designating the following K/As as During discussions between the industry and Generic KAs "Operating Exam Preferred": 2.1.6, 2.1.9, 2.1.14, NRC regarding changes to the KIA catalogs, one 2.1.17, 2.1.18, 2.1.19, 2.1.21, 2.1.30, 2.1.31, of the points of agreement was that K/As which 2.1.38, 2.2.2, 2.4.47, 2.4.49, 2.4.50 lend themselves to measurement during the scenarios and/or JPMs would be designated as such in the KIA catalogs. 5 General The following Kl A stem statements do not match Improve consistency among all catalogs. between the PWR and BWR catalogs: Systems - Kl, K4, Al, A4 EAPEs - E/AKI, E/AAI, E/AA2 Recommend matching 1122 (PWR) with 1123 (this catalog). Alternately, change the KIA stems here to match the PWR catalog.

ATTACHMENT 2 NE! Comments on NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

1. I 6 Section 11 Recommend changing Kl Stem Statement to Promote consistency among all catalogs. The Page 1-6 match NUREG-2103: "Knowledge of the physical "new" catalogs capture the idea of interaction or control/protection logic relationship between between systems better than the "old" catalogs.

the [SYSTEMl and the following systems:" 7 Section 11 Recommend changing KI Basis statement to The basis statement currently provided provides Page 1-6 read: historical data without providing a helpful basis "KI contains the systems that have a connection to to the end user trying to author questions. The the [SYSTEM]. The selected (systems) listed basis statements should simply provide an have either a plant protection/logic relationship or explanation for what is in the KIA and how to physical piping relationship to the [SYSTEM]. match it. Electrical systems are addressed in K2. Controls and interlocks are addressed in K4. Cause and effect relationships from system interactions may be tested in Kl, as appropriate. The operational implications of these relationships are addressed in KS." 8 Section 11 Recommend changing KS basis statement to read: Proposed basis statement contains historical Page 1-6 "KS contains theoretical concepts related to the information which is not relevant to its operation of the system and resulting operational application. Historical information should be put implications." in the revision log if desired. 9 Section I/ Recommend changing K6 basis statement to read: Proposed basis statement contains historical Page 1-6 "K6 includes systems listed in KI and K2 which information which is not relevant to its will have an effect on the (SYSTEM) ifthe K6 application. Historical information should be put listed system or component is not operating in the revision log if desired. according to design. K6 also contains (SYSTEM) components whose failure can affect the operation of the (SYSTEM). 2

ATTACHMENT 2 NE! Comments on NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

IO Section I/ Recommend changing A 1 basis statement to read: Proposed basis statement contains historical Page 1-7 "Al includes parameters monitored to verify information which is not relevant to its proper operation of the system or indications that application. Historical information should be put the system is outside of normal operating bands." in the revision log if desired. II Section II Recommend adding the (SYSTEM) name to the Maintain consistency with all other stem Page 1-7 A4 statement: statements which include the system name.

                           "A4. Ability to manually operate or monitor the (SYSTEM) in the control room.

12 Section I. I 0/ Recommend adding the following to the Supports the changes to the basis statements Page 1-7 paragraph begins "Section 4 of the ... " listed below. Add: "Note that an EAPE is a condition, event or symptom and not the procedure itself." 13 Section I, Table Recommend changing the basis statements for To avoid any confusion about what is. allowed to 4, Page 1-9 and E/AKl, E/AK2, E/AK3, E/AAI and E/AA2 as be tested for EAPEs, clarification should be 1-10 follows: added to this section. E/AKI Basis -Tests the operationally-based As noted in section I. I 0, EPEs are conditions, theoretical concepts applicable to the [EVENT]. events or symptoms which leads to entry into an These items may be addressed by procedure bases, EOP. APEs are conditions, events or symptoms PRA, operating experience, procedure notes, which lead to AOP entry. Note that definition of cautions or integrated system response. "evolution" in this context is "condition/event/symptom" as opposed to E/AK2 Basis -Tests how listed systems are "procedure". impacted by the [EVENT]. The basis statements all contain the word ElAK3 Basis - Tests the reasons for taking the "procedure" and most EAPE KAs do lend listed action/response during the [EVENT]. themselves to testing information contained within the related procedure but NOT all of the EAPE K/As allow for an item to be written to 3

ATTACHMENT 2 NE! Comments on NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

ElAA 1 Basis - Tests the ability to operate or test procedure knowledge to meet the plain monitor systems or components during the meaning of the KA. [EVENT]. This includes monitoring plant system response during all phases of the [EVENT]. For example, there are many operator actions and many plant automatic responses which occur ElAA2 Basis - Tests the ability to monitor the during the initial phases of an "emergency plant listed condition or parameter and interpret its evolution" where "conditions/events/symptoms" importance to the [EVENT] or the [EVENT] are present but the procedure has not yet been response. entered. Rather than create a situation where entire classes of questions are systematically excluded (diagnostics, plant response to transients, basis for design features), guidance should allow questions which address all phases of emergency/abnormal conditions not just those which are contained in procedural guidance. For example, consider APE 295003 "Partial or Complete Loss of AC Power" and the AA! K/As which test the ability to operate or monitor many, many different systems and components. If only the items listed in the "Loss of Offsite Power" procedure can be tested, then many of these AA I KlAs will be untestable and untested. This is, clearly, not the intent. The intent is to test as broadly as possible, testing knowledge within the procedures and also ensuring understanding of other impacts which may not be explicitly addressed therein. 4

ATTACHMENT 2 NEI Comments on NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Boiling Water Reactors, Rev. 3 Comment Section/Page Recommendation Justification

         #

14 Section 3.8/ Recommend maintaining separate !Rs for ALL All Fuel Handling system KAs are individually Pages 3.8-7 Fuel Handling System KAs selectable on either RO or SRO outline. As through 3.8-9 such, each individual KA should have its own importance rating for each license type. This is especially important where some KAs might be

                                                                                 <2.5 for one type of license but 2: 2.5 for the other type. (If this recommendation is implemented, Comment 3 above should NOT be implemented.)

15 Sections 5 and 6 Recommend using a single IR for GFE KAs. Since the same GFE exam is given to all, there is no benefit for maintaining two sets of IR for GFE KAs. 16 Section 3.1, Page Recommend adding A 1.17andA1.18 which are 3.1-20, 202001 missing. Recirculation System. 5 L______ .}}