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{{#Wiki_filter:DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Written Exam Outline 9/29/15 Comment Resolution 1 NRC Generated 2 On the SRO exam, the licensee rejected system 068 2.1.23 (Liquid Radwaste), and replaced it with system 034 A2.01 (Fuel Handling Equipment), "with random selection of new K/A number within Generic or A2 sections." | |||
However, per NUREG 1021 ES-401.D.1.c, "the K/As for the SRO examination will be drawn from those K/A categories (denoted by Columns "A2" and "G" in the SRO-only section of the applicable examination outline) and from all K/A categories related to the fuel handling facilities." Therefore, when 034 "Fuel Handling Equipment" was selected as the new system, the K/A category should have been randomly selected from ALL K/A categories, not just A2 and G. Also see note 8 on Form ES-401-2. Resample within 034. Randomly selected K/A from within system 034 (Fuel Handling Equipment) using all available K/As. K4.02 was selected. Updated Form ES-401-2 and 401-4. Complete Administrative JPM Outline 9/29/15 Comment Resolution 1 Renumber the Admin JPMs A1 through A9. Renumbered the Admin JPMs, A1 thru A9. Complete 2 Ensure SRO A.4 is sufficiently different from the 2013 E-Plan classification JPM. | |||
Last 2 exams have included E-Plan classifications. Consider replacing with PAR. SRO A9 (old number A.4) is sufficiently different than the 2013 E-Plan classification. | |||
2013 JPM resulted in EAL CA3.1. This exam results in EAL HA 1.2. The 2011 NRC Exam JPM was a PAR. Complete 3 For MODIFIED JPMs, specify the modifications that were made, and the last exam that the parent JPM appeared on. Details on the parent JPM and what modifications to the JPM were made have been added to the Admin and System JPM outlines (ES-301-1 and 301-2). Complete DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Control Room / In-Plant System JPM Outline 9/29/15 Comment Resolution 1 ROs and SRO-Is are receiving 4 alt path JPMs, which is the minimum. Add at least one more alt path as a buffer. Modified S4 to be an Alternate Path JPM. Complete 2 Form ES-301-2 does not specify which JPMs the SRO-Us will take. No SRO-Us. No Action needed 3 Is JPM S6 a repeat of 2011 Safety Function 6 JPM? ("f") The JPM was modified from bank JPM URO-AEO-05-C174J(A). It is similar to the JPM used on the 2011 exam. Information added to outline. Complete 4 In-Plant JPMs: Safety Function 4S has been sampled on the last 4 exams (2014 included) and SF 6 on the last 3 exams, while SFs 2, 3, 4P, 5, and 7 have not been sampled in that time. To reduce predictability, replace SF 4S and SF 6 with one of the unused SFs. Replaced with a SF 4P and SF 3 JPMs. Complete Simulator Scenario Outline Comments 9/29/15 Comment Resolution 1 Critical Tasks: When the draft exam is submitted, for each CT specify how it meets the elements of a CT defined by NUREG 1021 App D, Section D.1 (safety significance, cueing, measurable performance indicator, performance feedback). Also explain the justification for the chosen performance limit - i.e., | |||
"X pump must be started before Y time because -". Descriptions of the CTs have been added to ES-D1 outlines. These descriptions include the following: 1. Safety significance (assess that the task is critical to safety) 2. Cueing (indications available to the operators) 3. Measurable performance indicator (actions taken by at least one member of the crew) 4. Performance feedback (information available to the crew about the effect of the actions taken) 5. Justification for the chosen performance limit Complete 2 An event can be counted as a component malfunction or a reactivity manipulation for a given applicant but not both. Corrected the ES-D-1 and ES-301-5 for scenarios 3 and 4. Complete DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Simulator Scenario Outline Comments 9/29/15 3 Scenario 2, Event 4: Main Seal Oil Pump Trip. Event was the subject of an extensive licensing decision appeal on last exam (2013). Replace event. Replaced event. Complete 4 Scenarios 4 and 5 are at the minimum count for events. Add an additional event for margin. Added 1 additional event to scenario 4. Scenario 5 no longer being used. Complete 5 Scenario 4: 5 of the 6 events were on the last two exams (LTDN HX TCV failure was not). Modify scenario to reduce predictability, by modifying the major event to achieve a different response / course of action. Discussed the major event in scenario 4 with the NRC Chief Examiner and explained the difference between the SG tube rupture in 2013 and the 2014 exams. No change to the SG tube rupture event is needed. The normal event to reduce letdown was replaced with a different event. Complete 6 Scenario 5 Event 3 (VCT Level Transmitter Failure) appeared on last two exams (2013 and 2011). Replace with a different event. Scenario 5 no longer being used. 7 Scenario 5: Ensure LOCA is different in some manner from 2013 LOCA. | |||
Consider inter-system LOCA. Discussed the differences between the LOCA on the 2013 and 2014 exams with the NRC Chief Examiner. No change needed to the LOCA event.8 For events where an instrument fails, specify on D-1 which direction it fails. Added instrument failure direction to the applicable D-1s. Complete 9 Only 2 of the 5 scenarios require entry into EOP contingencies - need to be cautious to ensure all applicants are evaluated in at least one contingency. Discussed this with the NRC Chief Examiner. The current schedule ensures all candidates are evaluated in at least one contingency. | |||
Agree that caution is needed if any changes are made to the schedule to ensure all candidates are evaluated in at least one contingency. No Changes needed General Comments 9/29/15 Comment Resolution 1 Identify which plant-specific priorities (including PRA and IPE insights) are being covered. Information pertaining to PRA events and actions has been added to the D-1 for each scenario. Complete}} | |||
Revision as of 05:57, 15 June 2018
| ML15009A180 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/08/2014 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Union Electric Co |
| laura hurley | |
| References | |
| 50-483/14-012 | |
| Download: ML15009A180 (3) | |
Text
DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Written Exam Outline 9/29/15 Comment Resolution 1 NRC Generated 2 On the SRO exam, the licensee rejected system 068 2.1.23 (Liquid Radwaste), and replaced it with system 034 A2.01 (Fuel Handling Equipment), "with random selection of new K/A number within Generic or A2 sections."
However, per NUREG 1021 ES-401.D.1.c, "the K/As for the SRO examination will be drawn from those K/A categories (denoted by Columns "A2" and "G" in the SRO-only section of the applicable examination outline) and from all K/A categories related to the fuel handling facilities." Therefore, when 034 "Fuel Handling Equipment" was selected as the new system, the K/A category should have been randomly selected from ALL K/A categories, not just A2 and G. Also see note 8 on Form ES-401-2. Resample within 034. Randomly selected K/A from within system 034 (Fuel Handling Equipment) using all available K/As. K4.02 was selected. Updated Form ES-401-2 and 401-4. Complete Administrative JPM Outline 9/29/15 Comment Resolution 1 Renumber the Admin JPMs A1 through A9. Renumbered the Admin JPMs, A1 thru A9. Complete 2 Ensure SRO A.4 is sufficiently different from the 2013 E-Plan classification JPM.
Last 2 exams have included E-Plan classifications. Consider replacing with PAR. SRO A9 (old number A.4) is sufficiently different than the 2013 E-Plan classification.
2013 JPM resulted in EAL CA3.1. This exam results in EAL HA 1.2. The 2011 NRC Exam JPM was a PAR. Complete 3 For MODIFIED JPMs, specify the modifications that were made, and the last exam that the parent JPM appeared on. Details on the parent JPM and what modifications to the JPM were made have been added to the Admin and System JPM outlines (ES-301-1 and 301-2). Complete DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Control Room / In-Plant System JPM Outline 9/29/15 Comment Resolution 1 ROs and SRO-Is are receiving 4 alt path JPMs, which is the minimum. Add at least one more alt path as a buffer. Modified S4 to be an Alternate Path JPM. Complete 2 Form ES-301-2 does not specify which JPMs the SRO-Us will take. No SRO-Us. No Action needed 3 Is JPM S6 a repeat of 2011 Safety Function 6 JPM? ("f") The JPM was modified from bank JPM URO-AEO-05-C174J(A). It is similar to the JPM used on the 2011 exam. Information added to outline. Complete 4 In-Plant JPMs: Safety Function 4S has been sampled on the last 4 exams (2014 included) and SF 6 on the last 3 exams, while SFs 2, 3, 4P, 5, and 7 have not been sampled in that time. To reduce predictability, replace SF 4S and SF 6 with one of the unused SFs. Replaced with a SF 4P and SF 3 JPMs. Complete Simulator Scenario Outline Comments 9/29/15 Comment Resolution 1 Critical Tasks: When the draft exam is submitted, for each CT specify how it meets the elements of a CT defined by NUREG 1021 App D, Section D.1 (safety significance, cueing, measurable performance indicator, performance feedback). Also explain the justification for the chosen performance limit - i.e.,
"X pump must be started before Y time because -". Descriptions of the CTs have been added to ES-D1 outlines. These descriptions include the following: 1. Safety significance (assess that the task is critical to safety) 2. Cueing (indications available to the operators) 3. Measurable performance indicator (actions taken by at least one member of the crew) 4. Performance feedback (information available to the crew about the effect of the actions taken) 5. Justification for the chosen performance limit Complete 2 An event can be counted as a component malfunction or a reactivity manipulation for a given applicant but not both. Corrected the ES-D-1 and ES-301-5 for scenarios 3 and 4. Complete DRAFT OUTLINE COMMENTS Facility: CW First Exam Date:12/08/14 Attachment 6 OBDI 202 - IOLE Process Rev 1 Simulator Scenario Outline Comments 9/29/15 3 Scenario 2, Event 4: Main Seal Oil Pump Trip. Event was the subject of an extensive licensing decision appeal on last exam (2013). Replace event. Replaced event. Complete 4 Scenarios 4 and 5 are at the minimum count for events. Add an additional event for margin. Added 1 additional event to scenario 4. Scenario 5 no longer being used. Complete 5 Scenario 4: 5 of the 6 events were on the last two exams (LTDN HX TCV failure was not). Modify scenario to reduce predictability, by modifying the major event to achieve a different response / course of action. Discussed the major event in scenario 4 with the NRC Chief Examiner and explained the difference between the SG tube rupture in 2013 and the 2014 exams. No change to the SG tube rupture event is needed. The normal event to reduce letdown was replaced with a different event. Complete 6 Scenario 5 Event 3 (VCT Level Transmitter Failure) appeared on last two exams (2013 and 2011). Replace with a different event. Scenario 5 no longer being used. 7 Scenario 5: Ensure LOCA is different in some manner from 2013 LOCA.
Consider inter-system LOCA. Discussed the differences between the LOCA on the 2013 and 2014 exams with the NRC Chief Examiner. No change needed to the LOCA event.8 For events where an instrument fails, specify on D-1 which direction it fails. Added instrument failure direction to the applicable D-1s. Complete 9 Only 2 of the 5 scenarios require entry into EOP contingencies - need to be cautious to ensure all applicants are evaluated in at least one contingency. Discussed this with the NRC Chief Examiner. The current schedule ensures all candidates are evaluated in at least one contingency.
Agree that caution is needed if any changes are made to the schedule to ensure all candidates are evaluated in at least one contingency. No Changes needed General Comments 9/29/15 Comment Resolution 1 Identify which plant-specific priorities (including PRA and IPE insights) are being covered. Information pertaining to PRA events and actions has been added to the D-1 for each scenario. Complete