ML23191A862

301 Exam ADAMS 2B Administrative Items

ML23191A862
Person / Time
Site:	Turkey Point
Issue date:	07/10/2023
From:	NRC/RGN-II
To:
References
Download: ML23191A862 (17)

Text

Form 2.1-1 Examination Preparation Checklist Facility: _Turkey Point__________________

Date of Examination: __March/April 2023__

Developed by: Written:

Facility x NRC

//

Operating:

Facility x

NRC Target Date*

Task Description Chief Examiners Initials

-240

1. Examination administration date confirmed (A.1-5). For NRC-prepared examinations, arrangements are made for the facility licensee to submit reference materials (B.4, C.4.g and F).

MAB

-210

2. NRC examiners and facility licensee contact assigned (B.1 and C.1-3).

MAB

-210

3. Facility licensee contact briefed on examination security and other requirements (D.4). As applicable, the facility licensee contact submits to the NRC any prescreened K/As for elimination from the written examination outline, with a description of the facility licensees prescreening process (ES-4.1 A.1.a and ES-4.1 B.2).

MAB

-210

4. Reference material due for NRC-prepared examinations (F).

MAB

-210

5. Examination kick-off call held (C.4). The NRC sends the corporate notification letter (A.5).

MAB

-195

6. Written examination outline developed by the NRC and sent to the facility licensee contact (must be on the examination security agreement) (B.2, ES-4.1 A.1.b and ES-4.1 A.2.a).

MAB

-150

7. Operating test outlines and checklists due: Forms 1.3-1, 2.3-1, 3.2-1, 3.2-2, 3.3-1, and 3.4-1, as applicable (B.6). Facility licensee provides a draft operating test administration schedule to the NRC (B.18).

MAB

-136

8. Operating test outlines reviewed by the NRC and feedback provided to the facility licensee (ES-2.3).

MAB

-100

9. NRC-prepared examinations approved by the NRC supervisor and forwarded for facility licensee review (ES-2.3).

MAB

-75

10. Proposed examinations (written, JPMs, and scenarios, as applicable) and outline forms; quality checklists and supporting documentation (including Forms 2.3-2 and 2.3-4 and any Form 2.3-1, 1.3-1, and 3.4-1 updates); and reference materials due.

MAB

-60

11. Preliminary waiver/excusal requests due (ES-2.2 E.1).

MAB

-50

12. Written examination and operating test reviews completed (ES-2.3). The NRC supervisors authorization to proceed with the facility review granted (ES-2.3 D).

MAB

-50

13. Examination review results discussed between the NRC and the facility licensee (B.14).

MAB

-35

14. Examination preparatory week conducted by the NRC and the facility licensee (I).

MAB

-30

15. Preliminary license applications, including any waiver/excusal requests, due (ES-2-2 C.1).

MAB

-14

16. Final license applications, including any waiver/excusal requests, due and Form 2.2-1 prepared (ES-2.2 C and E).

MAB

-7

17. Written examinations and operating tests approved by the NRC supervisor (C.9)

MAB

-7

18. Facility licensee management feedback on the examination requested by the NRC supervisor (C.10).

MAB

-7

19. Final applications reviewed; 10% of applications audited to confirm qualifications/eligibility (ES-2.2 G); and examination approval letter (Letter 2.3-1) and waiver/excusal letters sent.

MAB

-7

20. Written examination administration guidelines reviewed with the facility licensee (D.14).

MAB

-7

21. Approved scenarios and job performance measures distributed to NRC examiners (D.12).

MAB

• Target dates are based on facility licensee-prepared examinations and the examination date identified in the corporate notification letter. These dates are for planning purposes and may be adjusted in coordination with the facility licensee.

ML23191A862

03/07/23 Y

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Y Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:17:32 -05'00' Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:18:40 -05'00' Digitally signed by Thomas A.

Stephen Date: 2023.03.14 15:53:46 -04'00'

Y Y

Y Y

Y Y

Y Y

Y Y

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Y

03/07/23 Y

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Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:28:32 -05'00' Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:29:20 -05'00' Digitally signed by Thomas A.

Stephen Date: 2023.03.14 15:53:06 -04'00'

JM JM JM JM JM JM JM JM JM JM JM Joseph McGuinness 03 / 03 / 2023 Y

Y Y

Y Y

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Y Y

Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:32:10 -05'00' Mark A. Bates Digitally signed by Mark A. Bates Date: 2023.03.08 07:32:42 -05'00' Date: 2023.03 at Digitally signed by Thomas A.

Stephen Date: 2023.03.15 15:55:22 -04'00'

Form 5.1-1 Postexamination Check Sheet Postexamination Check Sheet Facility: Turkey Poiint Dates of Examination: Spring 2023 Activity Description Date Complete

1. *Received postexamination package from facility licensee and verified complete. (ES-4.4) 4/14/23

2. *Reviewed and incorporated any necessary facility and applicant written examination comments. NRC grading of written examination completed. (ES-4.4) 5/1/23

3. *Reviewed and incorporated any necessary facility and applicant operating test comments. NRC grading of operating test completed.

(ES-3.6) 5/1/23

4. *Completed NRC chief examiner review of operating test and written examination grading. (ES-3.6 and ES-4.4) 5/9/23

5. Completed licensing official review.

5/10/23

6. Mailed licenses, preliminary results, and pass letters.

5/12/23

7. Notified facility licensee of results.

5/10/23

8. Issued the examination report (refer to Operator Licensing Manual Chapter (OLMC) 510, Operator Licensing Examination Reports).

5/17/23

9. Returned reference material after final resolution of any informal NRC staff reviews, hearing demands, or both.

5/17/23

10. Performed examination recordkeeping activities (refer to OLMC 520, Operator Licensing Examination Records and Documentation, and Management Directive 3.53, NRC Records and Document Management Program).

5/23/2023

• Activity may not be applicable for a retake examination. If this activity does not apply, place an N/A in the Date Complete column.

NRC Comments on 150 Day Outline Submittal General Comments Admin JPMs Acceptability of the Admin JPMs are difficult to fully analyze with only the outlines and supporting descriptions. The topics appear to be satisfactory.

Systems JPMs Systems JPMs appear to meet the requirements.

Scenario Content The minimum amount of items for each operator appears to be reflected in the outlines.

Scenario Critical Tasks Critical Task (CT) Requirements have changed significantly in Rev 12 of NUREG-1021. The majority of CTs in the scenarios are no longer CTs for a Rev 12 exam, although they would have been for a Rev 11 exam. For example, avoiding a reactor trip is no longer a CT, it is now a Significant Performance Deficiency (SPD). Also, a couple of the proposed CTs have arbitrary Alternative Boundary Criteria, which are not acceptable. See detailed comments below. Also please review Rev 12 for all aspects related to CTs and SPD.

Scenario Critical Tasks Also attached to this email are some excerpts from Rev 12 that I have been using as a quick reference. I have attached it for you to use as you see fit, but being familiar with the actual NUREG text is also recommended.

Scenario Critical Tasks I will try to provide some ideas for CTs at the end of this document. In some cases you may also want to consider that 2 major events are allowed in each scenario - you may want to consider adding a second major event if that helps provide the conditions needed for attaining the minimum number of CTs.

Admin JPMs The ideas described in the outlines and supporting paragraphs indicate that the tasks may be appropriate for an NRC exam. As long as nuclear power plant knowledge is needed for successful performance, then there is a high likelihood that the submitted JPM topics will work. Recall my earlier reminder to help guide JPM development: If someone who can read and do math will get the correct answer when given the JPM, then it may not be appropriate to be used for a licensing decision. I often use my wife as the example - she has never set foot on a nuclear site, but she can read and do math - if she will get the right answer with the materials provided, then the task likely does not test nuclear power plant knowledge and is likely not acceptable.

Systems JPMs No significant comments on Systems JPMs. It appears that requirements are met, pending further evaluation of the draft submittal.

Scenarios Scenario 1 / CT 1 ES-3.3 (page 12 of 17) states that CTs must significantly impact the safety of the plant or public. ES-3.3 (page 13 of 17) states that a CT must meet one of the four listed criteria. Operator actions with the plant still at power are unlikely to meet any of these four criteria. This CT would have met the Rev 11 criteria, but in Rev 12 if a crews inadequate response resulted in an RPS actuation, it would generally be graded as a post-scenario Significant Performance Deficiency (SDP). ES-3.5 (page 9 of 13) provides guidance on how an unnecessary reactor trip would be graded.

Scenario 1 / CT 2 This CT appears to be acceptable with Preferred Boundary Criteria (PBC).

The PBC wording only requires slight revision. Instead of stating prior to any Cold Leg RCS cold leg temperature cooling down to less than 280 F it needs to state, to prevent any Cold Leg RCS cold leg temperature cooling down to less than 280 F. This may seem like an insignificant change, but I have seen the necessary actions performed prior to but they were done so slowly that they could not prevent from dropping below 280F and they still had to enter FR-P.1.

Scenario 1 / Event 1 I think I know the answer, but I will ask anyway: Is the thermal barrier leakage considered identified and is it less than 10 gpm? Being that no Tech Spec designation appeared on the outline, I am guessing that the leakage is less than 10 gpm and the RCS leakage LCO is still met.

Scenario 2 / CT 1 Similar comment as Scenario 1 / CT 1.

Scenario 2 / CT 2 Similar comment as Scenario 1 / CT 1.

Scenario 2 / CT 3 This does not meet the criteria for a CT. Also, the one-minute criteria to manually trip is arbitrary and is not a PBC. What bad thing happens to the plant if the crew trips the reactor at two minutes? Typically, nothing bad happens on a failure of the reactor to trip unless you pair it with a loss of feedwater. If you pair it with a loss of feedwater, then most plants will be able to reach one of the Tech Spec safety limits if operators do not trip the reactor. Pairing the failure of the reactor to auto trip may be one solution.

2019-302 exam may have paired it with a feedwater isolation similar to what I am suggesting.

Scenario 3 / CT 1 Similar comment as Scenario 1 / CT 1.

Scenario 3 / CT 2 Similar comment as Scenario 1 / CT 1.

Scenario 4 / CT 1 Similar comment as Scenario 1 / CT 1.

Scenario 4 / CT 2 What is the basis for the 30-minute requirement? Is there an analysis to support the 30 minutes? Do the conditions in the scenario match the conditions in the analysis? Another way of looking at this is: If the operators

put their hands in their pockets and do nothing to address this for 30 minutes - what bad thing happens? What bad thing happens if they perform the actions at 31 minutes? If the scenario includes low intake levels and requires high flow, then perhaps this analysis could be used to program the simulator to reflect the adverse consequence? Otherwise, this may not be a good candidate for a CT.

Scenario 5 CTs look like they meet the requirements.

Critical Task Suggestions to Meet Rev 12 Requirements Scenario 1 The CT to throttle AFW to maintain > 280 F appears to be satisfactory.

The following is a suggestion for development of a second CT:

After the MSIVs are closed, then a few minutes later take away all FW and make the operators go to bleed and feed before challenging objective criteria for the Core Cooling Critical Safety Function. As with any CT, it must be possible to reach the criteria given the operators failure to respond appropriately.

Scenario 2 For the first CT: In order to make manually tripping the reactor a CT, consider pairing it with a loss of feedwater. Ensure that one of the Tech Spec Safety Limits is attainable and if so, then tripping the reactor to avoid reaching a Safety Limit would be critical.

For the second CT: A failed open Pzr PORV combined with a failure of SI to auto initiate may be a success path for a valid CT. The CT would be to either isolate the PORV or initiate SI to avoid an Orange Path on Core cooling. As with any of these CT suggestions, you will need to put your hands in your pockets and not take the required actions to ensure that the Orange Path is attainable.

Scenario 3 For the first CT: Consider adding a failure of the turbine to trip. The CT could then be to trip the turbine to avoid an Orange Path on Integrity (<

280F).

For the second CT: Expand the FW issues to a loss of AFW and Main Feed and create a success path to steam down and feed with Condensate Pumps to avoid reaching the criteria requiring bleed and feed.

Scenario 4 Consider deleting the Spurious SI malfunction.

Add a LBLOCA with a failure of some Phase A penitrations to isolate after the auto SI. Also fail containment spray to actuate.

For the first CT: actuate containment spray to avoid Red/Orange Path criteria on the Containment Critical Safety Function.

Many plants would be required to declare a Site Area Emergency if the RCS Barrier is lost (as is with the LBLOCA) coincident with the loss of containment which would occur if they do not get at least one valve in each phase A penetration closed. They have 15 minutes to classify, so as long as they close all of the penetrations within 15 minutes, then an ALERT would be appropriate, versus the higher classification of SAE.

For the second CT: Close containment isolation valves such that at least one valve is closed on each critical Phase A penetration within 15 minutes from the loss of containment barrier. (This CT idea is predicated on your Emergency Plan supporting the avoidance of a SAE being required if penetrations are not isolated within 15 minutes.)

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REFERENCE:

NUREG-1021, ES-3.3, Page 13 of 17]