ML22250A446
| ML22250A446 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/08/2022 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | South Texas |
| References | |
| Download: ML22250A446 (1) | |
Text
Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE COMMENTS Facility:
STP First Exam Date:
8/22/22 Written Exam Outline Comment Resolution 1 NRC Generated Site Generated Administrative JPM Outline Comment Resolution 1 JPM A1 - No comments Bank (2019 NRC)
N/A 2 JPM A2 - No comments Bank (2017 NRC)
N/A 3
JPM A3
- 1) K/A 2.2.2 is not an appropriate match. This JPM does not require an applicant to demonstrate an ability to manipulate controls. JPM appears to be a better Conduct of Ops JPM, with a K/A 2.1.25 (used on A2 JPM above). Must ensure the JPM fits within the Equipment Control to meet the requirements of the outline.
Modified (2019 NRC)
Agree with comment. Will replace JPM with a more appropriate JPM for Equipment Control.
4 JPM A4 - No comments Bank (2020 NRC - Previous 2)
N/A 5 JPM A5 - No comments Bank (2019 NRC)
N/A 6 JPM A6 - No comments Bank (2018 NRC)
N/A 7 JPM A7 - No comments Bank (2019 Audit)
N/A 8
JPM A8 -
Bank (2020 NRC - Previous 2)
Agree with comment. Will replace JPM.
9 JPM A9 -
Modification will need to include changing PARS determination from initial PARS to follow-up PARS or change to rapidly progressing severe accident, rather than simply changing wind speed and direction to include a Agree with comment. Will write JPM to be a rapidly progressing severe accident
OBDI 202 - IOLE Process Rev 3 different sector. Modification should be substantial.
Modified (2019 NRC) 10 General comment
- 1) 5 of 9 JPMs are from 2018 or 2019 NRC exams, with 2 of those 5 JPMs being modified for this exam. While the sampling was done using a random selection, we must ensure that JPMs A3 and A9 are modified, as presented in the outline, to prevent an oversampling of such recent NRC exams.
Agree with comment. Changing A3 and A9 as listed above in comments.
Control Room / In-Plant System JPM Outline Comment Resolution 1
JPM S1
- 1) JPM has an E designation. E is for emergency or abnormal in-plant tasks. While this is an emergency/abnormal event, it is not an in-plant task and should not have the E designator. (ES-3.4 Page 15)
Modified (2019 NRC)
Agree with comment. Will remove E designation.
2 JPM S2
Agree with comment. I made titles match.
3 JPM S3
- 1) K/A does not fit with this JPM. K/A listed is for pressure/temp/flow of RCS. K/A 003 A1.03 (2.6/2.6) is a more accurate fit.
Bank (2018 NRC)
Changed to 003 A1.03:
4 JPM S4 - No comments Bank (2019 NRC)
N/A 5
JPM S5
- 1) JPM has an E designation. E is for emergency or abnormal in-plant tasks. While this is an emergency/abnormal event, it is not an in-plant task and should not have the E designator (ES-3.4 Page 15)
Agree with comment 1. Removed E designation.
Agree with comment 2. I made titles match.
6 JPM S6 - No comments Modified (2019 NRC)
N/A
OBDI 202 - IOLE Process Rev 3 7 JPM S7 - No comments Bank (2017 NRC)
N/A 8
JPM S8
- 1) Typo on plant system K/A - should be 008 and not 0084 Bank (2018 NRC)
Agree with comment. Corrected Typo.
9 JPM P1 - No comments New N/A 10 JPM P2 -
Bank (2020 NRC - Previous 2)
Agree with comment. Will replace JPM.
11 JPM P3
- 1) K/A selected is to operator and/or monitor from the control room. With this being an in-plant JPM, consider A2.04 or A3.02.
Bank (2001 NRC)
Agree with comment. I will change to A3.02.
12 General comment
- 1) 7 of 11 JPMs are from 2018 or 2019 NRC exams, with 3 of those 7 JPMs being modified for this exam. While the sampling was done using a random selection, we must ensure that JPMs S1, S5, and S6 are modified, as presented in the outline, to prevent an oversampling of such recent NRC exams.
Agree with comment. Will ensure S1, S5, and S6 are modified.
Simulator Scenario Outline Comments Comment Resolution 1
Scenario 1, Event 1
- 1) Does the crew need to swap back to Train C due to the nonfunctional Train A supply fan?
- 2) Why does the SRO not receive N credit for this event?
Comment 1: Yes Comment 2: In retrospect the SRO will be involved with this event and we will change the outline to reflect.
2 Scenario 1, Event 3
- 1) Will PZR pressure remain in manual during the subsequent downpower in Event 4?
Yes
OBDI 202 - IOLE Process Rev 3 3
Scenario 1, Event 4
- 1) Is there an expected ramp rate for the downpower (none specified in 0POP04-FW-0002)?
- 2) Event credit can be shortened to All (R)
Should be on the order of 2%/min. < 5%/min is required. Timing and reductions in Steam Generator levels will determine rate.
Agree with comment 2. I will change.
4 Scenario 1, Event 5
- 1) If this event has to be triggered prior to Rx power < 90%, can this be put on an auto trigger, at say 94%?
We will write a conditional to make it happen automatically at 94%.
5 Scenario 1, Event 8
- 1) Where does procedural direction for this action exist?
The only guidance here would be Conduct of Ops. We will remove the event and evaluate if we need to replace it with another event.
6 Spare scenario comment - spare scenario removed from ADAMS submittal 7
Spare scenario comment - spare scenario removed from ADAMS submittal 8
Spare scenario comment - spare scenario removed from ADAMS submittal 9
Spare scenario comment - spare scenario removed from ADAMS submittal 10 Spare scenario comment - spare scenario removed from ADAMS submittal 11 Spare scenario comment - spare scenario removed from ADAMS submittal 12 Spare scenario comment - spare scenario removed from ADAMS submittal 13 Scenario 4, Event 2
- 1) The SRO should get C credit for this event (not credited on Form 3.4-1). If SRO is to not receive credit, why?
Agree with comment. We will change to give the SRO credit for a (C)omponent failure.
14 Scenario 4, Event 7
- 1) Are any actions necessary for the inadvertent FWI (manually starting AFW pumps)?
No. The inadvertent FWI deepens the loss of steam generator levels to get to bleed and feed in a timely manual by taking away Main Feedwater capability.
15 Scenario 4, Event 8
- 1) What are the verifiable actions that the RO will take in the event of the bus lockout? Applicant has to take verifiable actions to receive credit for the event.
The RO should pull to lock the Standby Diesel Generator because its output breaker will not close and it is running without Essential Cooling Water cooling.
OBDI 202 - IOLE Process Rev 3 16 Scenario 4, Event 9
- 1) Revise event description to preface with AFW pump 14 trips on overspeed followed by Loss of Heat Sink and entry into FRH1.
Discussed comment with the ChE. We will move Loss of AFW Pumps 13 and 14 to before Loss of Heat Sink and entry into FRH1.
17 General Comment
- 1) The following applicants have 0 normal evolutions, per Form 3.4-1. I-1, I-2, I-3, I-4, I-5, I-6, I-7, I-8, I-9, R-2, R-3, R-4. This is allowed, if an I/C malfunction is substituted on a one for one basis (ES-3.4 Page 6, instruction 9). Each applicant listed above has a minimum of 6 I/C events, exceeding the required number of 5 (4 minimum plus the 1 in lieu of the normal evolution). This is SAT and noted for reference. No action necessary Note - See comment 6 for SRO credit for normal evolution.
Total up RO and SROI N, R, I/C, or MC items that are added to or subtracted from form and ensure that requirements are still met.
18 General comment
- 1) All SRO applicants have minimum number of I/C failure events while in the BOP/ATC role. While this is SAT and noted for reference, we must ensure that events are performed by the applicant credited. No action necessary. *ES-3.4 page 10, instruction 2*
Add up I/C items that are added to or subtracted from form that effect the SROI and ensure the SROI still has at least two I/C events on the boards.