ML042950368

NRC Comments to Initial Examination Submittal Including ES-401-9 and Operating Test Comments for the Dresden Initial Examination - August 2004

ML042950368
Person / Time
Site:	Dresden
Issue date:	08/16/2004
From:	Lanksbury R NRC/RGN-III/DRS/OLB
To:	Crane C Exelon Generation Co, Exelon Nuclear
Shared Package
ML042540508	List: ML042950289 ML042950301 ML042950318 ML042950338 ML042950356 ML042950368 ML042950386
References
50-237/04-301, 50-249/04-301 50-237/04-301, 50-249/04-301
Download: ML042950368 (16)

Text

NRC COMMENTS TO INITIAL EXAMINATION SUBMITTAL INCLUDING ES-401-9 AND OPERATING TEST COMMENTS FOR THE DRESDEN INITIAL EXAMINATION - AUGUST 2004

1.

2.

3. Psychometric Flaws

4. Job Content Flaws

5. Other

6.

LOK LOD -

(FH)

UIEIS Stem Cues T/F Cred. Partial Job-Minutia Back-Q= SRO Focus Dist.

Link units ward KIA Only F

3 S

ES-401 Written Examination Form ES-401-9 Review Worksheet Dresden August 2004 Exam

7.

Explanation Modified. Need to see original question to veriv Modified.

RESOLUTION: NRC reviewed original question, verified new question moditied.

H 3

E New. LOK=H, since one needs to review nitrogen accumulator pressures and Reactor ressure to obtain the correct answer.

RESOLUTIJN: Licensee agreed, LOK=H. In addition: 1 Added fully to answer/distractors; 2) Bolded work SAME in distractor k.

I I

I I

I I

I I

I I

I I

I I

H 3

S E New. Licensee changed moved to inserted in stem.

H 3

S Bank.

f S

~~

Instructions

[Refer to Section D of ES-402 and Appendix B for additional information regarding each of the following concepts.]

1,

2.

3.

Enter the level of knowledge (LOK) of each question as either (F)undamental or (H)igher cognitive level.

Enter the level of difficulty (LOD) of each question using a 1 - 5 (easy - difficult) rating scale (questions in the 2 - 4 range are acceptable).

Check the a propriate box if a sychometric flaw is identified:

TRe stem lacks sufzient focus to elicit the correct answer (e.g., unclear intent, more information is needed, or too much needless information).

The stem or distractors contain cues (i.e., clues, specific determiners, phrasing, length, etc).

The answer choices are a collection of unrelated true/false statements.

One or more distractors is not credible.

One or more distractors is (are) partially correct (e.g., if the applicant can make unstated assumptions that are not contradicted by stem).

Check the a propriate box if a.ob content error is identified:

TRe question is not linked to the job requirements (Le., the question has a valid KIA but, as written, is not operational in content).

The question requires the recall of knowledge that is too specific for the closed reference test mode (i.e., it is not required to be known from memory).

The question contains data with an unrealistic level of accuracy or inconsistent units (e.g., panel meter in percent with question in gallons).

The question requires reverse logic or application compared to the job requirements.

4.

New. Do the SDC pum s auto tri when the SDC system is isolated whether they are aligneffor shutd30wn cooling or mixing? More than one correct answer (ie A,)?

RESOLUTION: Licensee clarified reference: Both pumps will trip on low suction pressure when isolated. There is only one correct answer.

11 5.

Check questions that are sampled for conformance with the approved WA and those that are designated SRO-only (KIA and license level mismatches are unacceptable).

11 6.

Based on the reviewers judgment, is the question as written (U)nacceptable (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

7.

At a minimum, explain any U ratings (e.g., how the Appendix B psychometric attributes are not being met).

Page 1 of 9

ES-401 E

Written Examination Review Worksheet Dresden August 2004 Exam New. 1) The third condition in the stem states: SBLC Pump Discharge Pressure sliqhtly ABOVE Reactor Pressure, while on page 13, Section 6.a.b) of the Lesson Plan provided states that when 2 pumps are running, discharge pressure can be up to 235 psi above reactor pressure due to line losses (which is more than slightly above reactor pressure). If the intent is to show that the SBLC pumps are NOT running deadheaded, then add a condition in the stem to state what reactor pressure is (e.g., 300 psig) and then state in the third condition in the stem what the SBLC discharge pressure is (e.g. some number that is well below the SBLC relief valve setpoint - - 500 psig). 2) On the question worksheet, it gives importance values of 3.813.9 and references A I.04 for the WA. This should be changed to 3.6/3.7 or Al.O6(?) to match ES 401 sheet?

RESOLUTION: 1 ) Intent is NOT to show not running deadheaded but rather that pressure is high enough to inject. 2) WA reference changed from AI.04 to AI.06.

Form ES-40 1-9 H

F H -

I__

H 2

3 3 -

3

3. Psychometric Flaws

4. Job Content Flaws X

X

5. Other I 6. I Explanation New.

New. Question asks for function of HPCI-8 valve, but reference describes HPCl485.

RESOLUTION: Licensee clarified reference. The injection valve is the HPCl 8 valve, and the HPCl turbine does not spin until the 4 and 5 valves are open.

New.

New. 1) In the stem it is stated that UZ3 DG jacket water temperature is 205 deg F and increasing. This could only be the case if the U2/3 DG was NOT tripped (and thus provides a Cue that the bus associated with the UZ3 DG is still energized). Delete the phrase and going up 1 deg F every 5 minutes. 2) Distractor D is NOT plausible, since one would NOT expect both Core Spray pumps to be fed from the same bus. To make distractor D plausible, suggest adding another condition in the stem that the alarm Generator Differential Current is present on the U2 DG, which would imply that the U2 DG is tripped. Then change the correct answer to distractor B.

RESOLUTION: Licensee incorporated NRC comments as stated.

Page 2 of 9

ES-401 Dresden August 2004 Exam E

f S f

U Written Examination Review Worksheet

1) There was NO question uestion indicating the WA (?WA 212000 A2.14?); question source, LOK, original question, etc. 2) Is the Hi Level Scram setpoint above the Hi Level alarm setpoint? If so, then just because the alarm is in does NOT mean that a manual reactor scram is required The alarm response only places the mode switch in SHUTDOWN if a reactor scram occurs.

. 1) Added question reference sheet, NRC verified question

WA 212000 A2.14. 2) A-I4 alarm is the scram setpoint.

New 1) This question IS at the SRO level, since an RO would NOT be expected to know from memory Tech Specs requirements that require actions at greater than one hour (IO CFR 55.43.b (2)). 2) Is there a Tech Spec associated with Control Rod Position indication while at power that could be applicable instead of TS 3.1 3?

RESOLUTION. 1) Question asking TS entry condition. ROs are required to recognize TS applicability. Added explanation that TS 3.1.3 is applicable to Modes 1 and 2, removed last two sentences from reference on LCO information 2) No.

New To make the wording between distractors B and D consistent, change the word "halt" in distractor B to "stop".

RESOLUTION. Upon further review by the licensee, they identified a procedure compliance issue that resulted in no correct answer. Licensee revised the question Form ES-401-9 Psychometric Flaws I

4. Job Content Flaws Z q T units

5. Other x

6.

U/E/S

7.

Explanation

~

~~

~~

New Channel 3 is failed downscale and is NOT bypassed."

RESOLUTION' Licensee incorporated comment.

Change the wording of the last condition in the stem to "APRM S

INew.

f E New. Licensee replaced distractor "Toggle switch above the recorder" I with "enter Program 22 on Process Computer to select SRM 21."

Page 3 of 9

ES-401 Dresden August 2004 Exam E

17 18 19 -

20+ -

21 22 23 24

_I Written Examination Review Worksheet S

Form ES-401-9 New.

1.

LOK (FIH) -

F H

H -

H

~~

~

3. Psychometric Flaws

4. Job Content Flaws I 5. Other

7.

Explanation

6.

U/E/S

_I_

red.

Dist.

X -

Stem OCUS -

increased regarding the High Voltage power supply.

RESOLUTION: Licensee identified that the requested change would result in two correct answers per the reference, Change not incorporated.

3 3 -

3 f S Bank. 1) Add the following to the timeline in the stem of the question(ie, make two Div II items in stem): - 17:15:15, Division 11, 2 psig High Drywell Pressure; - 17:17:15, Division II, ECCS =. 100 psig Discharge Permissive

2) Change the times for the following: -17:17:45, Division I, ECCS > 100 psig Discharge Permissive. With the above changes to the time line, the correct answer becomes distractor B.

RESOLUTION: Licensee justified testing applicant knowledge of concepts associated with each of the question distractors and answer. Proposed changes would narrow the focus and test fewer concepts. NRC will leave as written.

S -

U S

S I_

Modified. Need to see original question to verify Modified.

RESOLUTION: NRC reviewed original question, verified new question modified.

Bank. Distractors B and C are NOT plausible (to have a switch associated with the CCSW pumps to be associated with initiation of drywell sprays).

Suggest taking the condition of 316 in MANUAL out of the question stem and having rewording distractors to be associated with various positions/conditions associated with the 31 6 and 31 7 switches.

RESOLUTION: Licensee agreed, and incorporated comment.

Bank.

H 3

F 2

F H - 2 3 -

~

New.

Page 4 of 9

ES-401

2.

LOD (1-5) 2 2

2 3

3 2

3 3

2 2

3 2

Form ES-401-9

3. Psychometric Flaws

4. Job Content Flaws Stem Cues Focus H

H F

H Dresden August 2004 Exam Written Examination Review Worksheet Dist.

Link LqT units

5. Other X

Page 5 of S

f E -

S s

f E S

E S

s S -

f E -

9

7.

Explanation New. 1) Distractor A is NOT plausible (that a bus would be de-energized following a normal Main Turbine trip). 2) The information provided with the question does NOT show that distractor B is the correct answer.

RESOLUTION: 1) Licensee agreed, revised question to incorporate comment. 2) Provided additional reference to support correct answer.

3) Licensee clarified location of voltage indication in MCR. Also added 1 to 2 seconds to distractors C and D.

Bank.

New. Licensee changed stem: replaced...a small leak... with...partial loss of DW cooling... Changed correct answer to C and revised distractor 4 to be incorrect.

New.

New.

~ -~

New. Licensee identified that parallel procedures allowed both original xtions. Revised second part of distractors A and C accordingly.

3ank.

Modified. 1) Need to see original question to verify Modified. 2) WA eferenced by question sheet should be 271 OOO?

IESOLUTION: 1) NRC reviewed original question, verified new question nodified. 2) Licensee corrected question K/A reference. 3) Changed one listractor alarm because Injection Flow Lo may also come in due to nstrument tolerances. 4) Changed unit power level to 91 2 MWe from 750.

5) Changed answer to Off Gas Chimney Flow increasing.

3ank.

vlodified.

dew.

dew. Licensee changed distractor 923-5 panel to 902(3)-6 panel.

ES-401 Q#

37+

38+

39+

4 O

F 41 12+

4 3

F 4

4 H

E+

4 6

F 47 4

8 F

49+

50 51 52 53 Form ES-401-9 1

2 3 Psychometric Flaws 4 Job Content Flaws 5 Other 6

7 LOK LOD (FIH)

(1-5)

Stem Cues T/F Cred Partial Job-Minutia

1. I Back-Q=

SRO UlEIS Explanation Focus Dist Link units ward WA Only H

3 S

New F

2 E

!+bMkd-Bank Question not modified sufficiently, stem was only reworded RESOLUTION Licensee agreed

~

~

F 3

S New 3

S New F

2 S

Bank H

2 E

New LOK=F F

RESOLUTION Licensee agreed, LOK=F Also, added "G-4" as the proper alarm designation 2

S New 2

S New F

2 f E New Licensee added 1) "Per DAN 902-4 D-18 " to stem, 2) Changed

" 28 ERV leaking by " instead of opening " to stem 2

S New H

4 S

New 2

S Modified H

2 S

New H

3 S

New H

3 S

New F

2 s

New F

2 S

2001 NRC exam

~

~- - -

Dresden August 2004 Exam Written Examination Review Worksheet Page 6 of 9

ES-401

ues TIF Cred. Partial Dist.

X Dresden August 2004 Exam Job-Minutia

1. I Back-Q= SRO UIEIS Explanation Link units ward WA Only S

Bank.

S New.

X f

U New. Question sheet references WA K3.06, but ES 401 references A I.05?

RESOLUTION: Licensee identified that K/A question was written for was incorrect. Question was replaced with one that meets randomly selected WA on ES 401.

s New.

f S Modified. SRO only7 RESOLUTION: 1) Not SRO Only, also RO due to EOP basis question. 2)

Licensee clarified question to eliminate possibility of two potential correct answers.

S New.

S New.

S Modified.

S New.

f E 2001 NRC exam. Licensee added DOA 10-2 clarification to stem.

S New.

f E New. Licensee added breaker names.

S New.

S New.

S Bank.

S Bank.

Written Examination Review Worksheet Form ES-401-9 Psychometric Flaws I

4. Job Content Flaws I 5. Other I 6. I

7.

II Page 7 of 9

ES-40 1 Dresden August 2004 Exam Written Examination Review Worksheet Form ES-401-9 Page 8 of 9

I ES-40 I Dresden August 2004 Exam Written Examination Review Worksheet Form ES-401-9 Page 9 of 9

6 NRC Comments Dresden 2004 ILO Operating Test Exam ADMIN JPMS

a. ANa: Authorization of Overtime IAW GL 82-12

b. ANb: tnitiate a Firewatch Comment:

1) Clarify date for JPM data.

2) Revise cue.

~

~

I)

Change WR to WO in IC.

2) Clarify several XL3 devices are inop.

3) Devices listed will place Aant in LCO condition.

1.) IC does not adequately iescribe desired task.

Licensee Action:

1) Added note at bottom of JPM stating The date listed is today.

2) Change cue from

• Authorize Barney Gumbel to work the overtime in accordance with GL 82-12 overtime guidelines and forward the paperwork, if any, to the Shift Manager. to Authorize Barney Gumbel to work the overtime in accordance with the applicable procedure and forward the paperwork, if any, to the Shift Manager.

I) Incorporated errata change.

2) Add following to JPM cue:

The following XL3 devices are inoperable: Zone 34, device numbers 4, 5, and 29; Zone 33, device 23; Zone 43, device 30; Zone 23, device 29; Zone 13, device 1 I.

3) Add cue that states: If asked, another SRO is looking at the LCO require me nts.

4) Change IC to read:

Authorize, and initiate as necessary, a fire watch IAW applicable procedure.

Page 1 of 6

NRC Comments Dresden 2004 ILO Operating Test Exam

c. ANc: Verify U3 EDG Surveil lance

d. ANd: CCSW Activity Calculation Verification

e. ANe: Complete a NARS Form and Make Required Notifications SYSTEM JPMs

1) Two occurrences of 2/3 EDG; should be Unit 3 E D G?

2) Identify DOS 6600-01, Step l.19.e.(4), as N/A vice initials.

IC does not adequately describe the desired task.

1) JPM step 12 references EP-AA-I 11 Attachment 7, should read Attachment 4.

2) Examinee cue sheet errata.

3) JPM Step 6 not critical.

4) Revise note.

Comment:

~

I ) Change 2/3 EDG to Unit 3 EDG in IC and JPM Step 4.

2) Discussion with SOS indicated that he would accept either initials or N/A, but would question DOS performer as to reason for their initials. Issue Report

1. 00246109 generated to add further procedure clarification as to when to initial or N/A step.

Change IC to read: Verify the A CCSW activity calculation and provide the NSO results of the US review of the surveillance.

1) Change incorporated.

2) Added from PPDS to end of IC 6 and 7.

3) Deleted critical symbol from Step 6.

4) Change note after Step 19 to STOP TIME FOR 15 MINUTE TIME CRITICAL PORTION OF JPM.

Licensee Action:

Page 2 of 6

NRC Comments Dresden 2004 ILO Operating Test Exam

a. SNa: Startup of 2nd RRP w/ Failure of Discharge Valve to Open.

Primary Water via RWCU Following a Gp 3 Isolation.

I ) Add sim setup instruction note about placing DW pressure controllers to MAN and closing the valves.

2) Errata, fix grammar in cue: DOP 0202-01 has been...

3) Licensee requested JPM critical step time change from 2 to 5 minutes for securing RRP when the discharge valve fails to open. DOP 0202-01 directs the operator to trip the RRP within two minutes of starting if the associated RRP discharge valve fails to open after starting.

Based on discussions with manufacturer and verification on the simulator that running the RRP deadheaded for 10 minutes showed no rise in bearing temperatures, the SOS stated that he would consider the step performed unsatisfactorily if the RRP was not secured within 5 minutes.

I ) JPM Step 13 states, Adjust RMC 2-1290-1 3 controller.. ; whereas Step 12 of DOP 1200-02, states

..adjust RMC 2-1290-14...

2) Incorrectly identified as Alternate Path.

3) JPM Step 5 not critical.

I)

Done.

2) Done.

3) The licensees comment was not incorporated because there was no intent to change the procedural guidance. The expectation to trip the RRP within two minutes of the discharge valve failing to open is still valid, and remains a critical JPM step.

1) Change Step 13 to state

...adjust RMC 2-1209-14 controller.,.

2) Removed mark for Alternate Path on JPM attribute page.

3) Leaving the PIC controller in Balance has no effect on JPM outcome as setup.

Page 3 of 6

NRC Comments Dresden 2004 ILO Operating Test Exam

e. SNc: HPCI-Manually Start HPCl for Pressure Control

d. SNd: LPCI-Perform LPCl System Operability Test with Torus Available, Pump Trips

e. SNe: Perform DG Surveillance Testing

f. SNf: Bypass an LPRM.

g. SNg: SBGT Post Maintenance Testing with receipt of an Auto Initiation Signal.

I) JPM Step 6 of JPM not performed by DOA 2300-02 procedural steps; however, it is performed by Step 6 of hard card attachment.

2) Sim setup does not address opening the HPCl 4 valve.

3) JPM Step 5 not critical.

I ) JPM steps 8 & 9 not critical.

2) Insert JPM Step 10 on same page as Note.

3) JPM errata change.

Modify JPM page 6 examiner note to read:

When load is reduced to below 1500 KW, give the cue.

1) JPM IC typos: (LPRMg, Unit Supervisors).

2) Add APRM numbers to sim setup instructions.

3) IC, change action request to Issue Report.

4) Add note to make LPRM 32-25A downscale in sim setup.

1) Remove signature from Step 1.3.b(3) of DOS 7500-

02.

2) Add actions to place DW and Torus purge fans in PTL in sim setup.

~

~~

~

1) Site procedure change will be issued after exam. JPM Step 6 not critical to JPM performance.

2) Place statement in sim setup to open the HPCl4 valve.

3) Per JPM cues, applicant not required to make any flow changes.

1) Agree. Remove critical designation.

2) Done.

3) Change 2-1 540-458 to 2-1 540- 1 5B.

Done.

I)

Done.

2) Done.

3) Done.

4) Done.

~~

1) Done.

2) Done.

Page 4 of 6

NRC Comments Dresden 2004 ILO Operating Test Exam

j. IPNj: Restore Unit 2 125 Vdc Battery System to Operable Following a Failure of One or More Battery Buses JPM Step 6, not 7 is critical.

k. IPNk: Supply U3 RPS Bus B From RPS MG 3A with MG Failure to Start Initially Incorporated.

~

~

~ -~~~

~

~

Add MCR pre-requisites verified to IC.

Statement added.

ILT-N-1; Summary ILT-N-I; C-SRO; Event 1-vacuum breaker stuck 20%

open.

1 SCENARIOS I Comment:

I Licensee Action:

I I

State that 2 rods will rem ai n withdrawn.

Done.

ILT-N-1; U2 Turnover ILT-N-I; C-SRO, -NSO; Event 3-swap 2A CRD Pp.

I 1) Add statement that team 1 is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed time period for dP to equalize.

2) Remove note from all turnovers re: CRD suction filter elevated dP.

Make starting second CRD Done.

pump part of the component failure evaluation.

Done.

ILT-N-1; M-SRO, -NSO; Event 5,6,7-DW small leak, second CRD Pp trip, CRDs stick, increasing DW leak.

Change actions to state Done.

that team will scram on second accumulator alarm.

ILT-N-1; C-SRO, -NSO; Event 2-drifting rod H-01 ILT-N-1; I-SRO, -NSO; Event 4-APRM upscale failure.

Page 5 of 6

Page 23 of 29 lists 3 critical tasks, but quantitative list on page 25, and ES-301-4 only lists 2. How many, and what are the critical ILT-N-2; Pg. 6 of 27, pre-scenario activities, 1.d:

Only took credit for 2 of 3 critical tasks because depending on the path the team takes, may not get to 3rd critical task.

Changed G.60 to G.62 to comply with current revision of procedure.

Add to QNE role play to page 11, Core operating parameters are normal.

Recommend continuing reactor startup.

ILT-N-2; R-SRO; NSO; Event I l-raise power with rods.

Done.

ILT-N-2; C-SRO; Event 2-CR double notch.

What does S indicate in outline?

ILT-N-2; S-SRO; Event 3-CS low pressure.

Change S to C.

ILT-N-2; C-SRO; Event 4-accumulator low pressure.

Add to NLO role play that must depressurize accumulator due to N2 bottle pressure at 800 psig (US required to make TS call on accumulator).

ILT-N-2; I-SRO; NSO; Event 5-FWLC setpoint drifts high.

ILT-N-2; M-SRO; NSO; Event 6,7-RRP seal failure; RRP suction valve fails to close; ATWS.

Done.

Page6 of 6