ML19247D519
| ML19247D519 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/09/2019 |
| From: | Jonathan Haas Detroit Edison, Co |
| To: | NRC/RGN-III/DRS/OLB |
| demarshall j | |
| Shared Package | |
| ML17215A393 | List: |
| References | |
| Download: ML19247D519 (14) | |
Text
Fermi 2019 Initial License Exam Outline Review Comments 1
Simulator Scenario Outline Comments General Comments:
o NRC: Scenario 1, Event 2: What is/are the verifiable/mitigative action(s) for this event (RHR Pump Shaft Shear)? Is the affected RHR Pump Motor secured and other RHR Pump placed in Torus Cooling? Event is listed as a Component Failure for the BOP. Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct. Appears to be a TS-only event for the SRO applicant based on the associated description in the Narrative Summary.
FERMI:
Event 1 is now Place RHR in service to support Torus Cooling.
Event 2 is now A control rod drift alarm will actuate, and rod 26-31 will drift into the core. The crew will perform the Control Rod Drift AOP and disarm the control rod at position 00 and evaluate Technical Specifications 3.1.3.
Event 3 is now RHR Pump A or C Shaft Shear (whichever is running). SRO evaluates LCO 3.5.1.
Note: Event 3 requires the BOP to shutdown the RHR system.
o NRC: Scenario 1, Event 9: Safety-significant boundary conditions have not been clearly defined for CT-2 (Manual ARI actions to insert rods). Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
CTs updated based on Chief examiner feedback.
o NRC: Scenario 2, Event 2: The APRM Flow Unit failure is a TS Tracking LCO.
Tracking LCOs are not permitted. The event must result in entry into an Active LCO.
FERMI:
Credit for TS call removed.
o NRC: Scenario 2, Event 3: First part of the event description on the D1 appears to be truncated, i.e., First division of RHR used for containment, Is the word containment intended to describe a mode of operation (e.g., containment cooling)?
Clarification needed.
In addition, the Narrative Summary for Scenario 2 does not include a description of Event 3.
FERMI:
Fermi 2019 Initial License Exam Outline Review Comments 2
Scenario 2, Event 3 on the submitted D1 should have been listed at the bottom.
This has been corrected.
Updated summary to: Div 1 EECW failed to start, crew will manually start vice a RHR failure.
o NRC: Scenario 2, Event 5: What is/are the verifiable/mitigative action(s) for this event (Loss of Control Power to Bus 72C)? Event is listed as an Instrument Failure for the ATC. Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct. Appears to be a TS-only event for the SRO applicant based on the associated description in the Narrative Summary.
FERMI:
This is now event 4 due to correction of event 3 72CF transfers to alternate source because of this event. This requires LCO 3.0.3.
SRO must enter 3.0.3 and then order actions to restore 72CF to normal source.
After a field role play, the BOP will swap 72CF back to normal using control on the H11P809 and H11P810 (Main control room) to restore 72CF to normal. The SRO will then exit LCO 3.0.3. This event requires actions that cause significant system response and the event requires verifiable operator action to correct.
The Narrative Summary now states:
An electrical short occurs causing the fuses in 2PA2-14 Circuit 2 to fail. This fault will cause a loss of control power to bus 72C. The crew will be alerted by 1D7 &
2D29, which will both come in and clear. The fault will cause an automatic throw-over of 72C-F to 72F. The event makes the 72CF throw-over scheme INOPERABLE and T.S 3.5.1 Condition K applies, which puts them in T.S.3.0.3.
The crew will take action to restore fuses and be able to return 72CF to normal, and then exit T.S. 3.0.3.
o NRC: Scenario 2, Event 6: The North Heater Drain Pump (NHDP) Trip with Recirc Manual Runback Failure (Event 6) and resultant Rapid Power Reduction (Event 7),
constitute one event for the ATC. Credit cannot be given to the same applicant for both an I/C failure and the resultant power change. ES-301, Section D.5.d states:
With the exception of the SRO TS evaluations, each evolution, failure, or transient should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation, and similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.
Any normal evolution, component failure, or abnormal event (other than a reactor trip or power reduction) that requires the operator to perform a controlled power or reactivity change will qualify as a reactivity manipulation.
FERMI:
The HDP trip drives Immediate Action reducing power by pressing the Manual Runback Pushbutton, this fails to lower power. The ATC will manually lower flow.
This is being counted only as a component failure. A separate event to insert the
Fermi 2019 Initial License Exam Outline Review Comments 3
CRAM array due to being in the EXIT region for power to flow map, is being counted as the Reactivity.
o NRC: Scenario 2, Event 6: Appears that the NHDP Trip should be classified as a Component Failure rather than an Instrument Failure. Appendix D, Section C.2.b, Total Malfunctions, states: Total malfunctions are the number of instrument (e.g., nuclear, control, or process) and component failures (e.g., pump, motor, valve, or pipe) The NHDP Trip is a pump failure.
FERMI:
Updated to Component for the Manual Runback Pushbutton. See previous comment.
o NRC: Scenario 2, Event 8: What is/are the verifiable/mitigative action(s) for this event (Jet Pump Failure)? Event is listed as a Component Failure for the ATC.
Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct.
FERMI:
Execution of Condition A of 20.138.02, Jet Pump Failure requires the ATC to act to Monitor core for thermal-hydraulic instability (24.000.01 Att. 34B). The ATC will place Rod Select Power to ON (H11-P603) and select different rods as required using the rod matrix. This is now event #7.
o NRC: Scenario 2, Event 8: Is there an applicable TS associated with failure of the Jet Pump? Is entry into an Active LCO required? No reference to TSs have been provided in either the D1 or Narrative Summary.
FERMI:
Technical Specifications:
3.4.2, Jet Pumps 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to hot shutdown with a jet pump failure.
3.3.1.1 Instrumentation, 2b and 2f, Action A, F and J Event leads to EOP entry and provides little time for T.S. evaluation. TS has been added to the D1, already listed in the D2.
o NRC: Scenario 2, Event 11: Safety-significant boundary conditions have not been clearly defined for CT-2 (RPV Flooding). Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
See response Scenario 1, Event 9 o
NRC: Scenario 3: Events 4 and 5 should be listed as one event. No operator actions appear to be scripted for Event 4. The only operator action in response to the 4D53 AVR General Alarm is the Power Reduction specified in Event 5.
Fermi 2019 Initial License Exam Outline Review Comments 4
FERMI: Event is now only credited with the power reduction for Reactivity (Events combined in the D1) o NRC: Scenario 3: Events 6, 7, and 9 together constitute the Major Event. Event 7 should not be listed as a stand-alone post EOP entry component malfunction. ATC actions to insert control rods per 29.ESP.03, under what is presently scripted as the Event 7 post EOP entry component malfunction, are directly associated with a mitigative strategy that the crew would normally be expected to implement in response to an ATWS, and as such, do not test the crews ability to separately recognize/diagnose and respond to a component malfunction that meets the intent of the Malfunctions after EOP entry metric specified in the Target Quantitative Attribute per Scenario Table on Form ES-301-4 of NUREG-1021.
Similarly, the actions taken in Event 9 to T&P and control level during an ATWS do not, in and of themselves, constitute a stand-alone Event. There is no Event 9 malfunction. T&P actions and level control are an inherent element of the mitigative strategy that the crew would normally be expected to implement in response to an ATWS, and are therefore part of the Major Event.
FERMI:
D1 events now as follows:
6 NHAIALARM_U T554497REV R (ATC)
R (SRO) 4D53 - AVR General Alarm. The crew will diagnose that there is a failure of one thyristor bank. The ARP requires reducing reactor power so generator output<2400 Field amps.
7 N30MF0020 C71MF0006 C11MF0001 M (All)
CT1 CT2 AVR Trip of Turbine, the crew will place Mode Switch to Shut down.
Manual RPS Fails to Cause a Scram (Total Scram Failure) and All Rods Stuck, inhibit ADS. Manually insert control rods.
Crew will T&P for Level.
8 C41MF0004 C41MF0003 C (ATC)
C (SRO)
SRO directs SLC injection. ATC Injects SLC. Delayed Pump trip.
Start Second pump Crew Injects SLC.
o NRC: Scenario 3: In this scenario, no Abnormal Event Instrument or Component (I/C) failures have been scripted for the ATC before the start of the Major Transient.
The only viable I/C malfunction specified for the ATC is the SLC Pump Trip post EOP entry component malfunction in Event 8. Appendix D, Section C.2.d, Abnormal Events, states: Components or instrument failures that occur following EOP entry do not count toward the recommended total number of abnormal events. This scenario, as presently scripted, reduces the examiners ability to properly evaluate an applicant in the ATC position.
FERMI:
Add event at 603
Fermi 2019 Initial License Exam Outline Review Comments 5
2 C32MF0025 C (ATC)
C (SRO)
FW Flow A Transmitter Failure.
o NRC: Scenario 3, Event 7: Safety-significant boundary conditions have not been clearly defined for CT-1 (Inhibit ADS) and CT-2 (Reduce Power by Manual Control Rod Insertion). Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
See response Scenario 1, Event 9 o
NRC: Scenario 3, Event 8: Safety-significant boundary conditions have not been clearly defined for CT-3 (Reduce Power by SLC Injection). Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
See response Scenario 1, Event 9 o
NRC:
FERMI:
Redacted information.
Redacted information.
Fermi 2019 Initial License Exam Outline Review Comments 6
o NRC:
FERMI:
o NRC:
FERMI:
o NRC:
FERMI:
o NRC:
FERMI:
o NRC: Scenario 5, Event 3: The Reactor Vessel Steam Dome Pressure High failure with resultant single control rod scram (Event 3) and ensuing Power Reduction to recover the rod (Event 4) constitute one event for the ATC. Credit cannot be given Redacted information.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
Fermi 2019 Initial License Exam Outline Review Comments 7
to the same applicant for both the Instrument Failure and the power change. ES-301, Section D.5.d states:
With the exception of the SRO TS evaluations, each evolution, failure, or transient should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation, and similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.
Any normal evolution, component failure, or abnormal event (other than a reactor trip or power reduction) that requires the operator to perform a controlled power or reactivity change will qualify as a reactivity manipulation.
If this instrument malfunction is to serve / qualify as a reactivity manipulation in this scenario, then (1) no Abnormal Event Instrument or Component (I/C) failure would be scripted for the ATC before the start of the Major Transient, and (2) the only viable I/C malfunction specified for the ATC would be the apparent Mode Switch Failure post EOP entry component malfunction in Event 9. Appendix D, Section C.2.d, Abnormal Events, states: Components or instrument failures that occur following EOP entry do not count toward the recommended total number of abnormal events. This scenario, as presently scripted, reduces the examiners ability to properly evaluate an applicant in the ATC position.
FERMI:
Remove all actions for single rod scram. Add Single Rod Scrammed to Turn over.
Reactive event stays for recovery. Add Field report of failing stabilizing valve, that will require Swap of stabilizing valves. Rod recovery dropped as not needed, Remove ALL of event 4, as TS call is not needed and no credit is being given for this event.
NRC Supplemental Comment: SCN 5 D1 appropriately revised to address the NRC's comment, following additional CE feedback to Fermi's response (see AS ADMINISTERED Scenario 5 D1).
o NRC: Scenario 5, Event 7: What is/are the verifiable/mitigative action(s) for this event (HPCI Steam Leak), given that HPCI Area Maximum Safe Operating (MSO)
Temperatures will be exceeded? Event is listed as a Component malfunction for the BOP. Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct.
FERMI:
Leak Isolation activities. The panel operator will successfully close some isolation valves. Furthermore, there are required verifiable actions in 20.000.02 Abnormal Release of Radioactive Material.
NRC Supplemental Comment: SCN 5 D1 appropriately revised to address the NRC's comment, following additional CE feedback to Fermi's response (see AS ADMINISTERED Scenario 5 D1).
o NRC: Scenario 5, Event 8: Events 7, 8, and 10 together constitute the Major Event. The HPCI Steam Leak (Event 7) is the initiating event, and the mitigative actions taken in Events 8 (One Area > MSO Temp) and 10 (Two Areas > MSO Temp) are the direct result of event progression and continued degradation of Secondary Containment Areas. Accordingly, Events 8 and 10 do not, in and of themselves, constitute separate stand-alone Events. Actions performed in accordance with EOP 29.100.01, Sheet 5, and EOP 29.100.01, Sheet 1A, comprise
Fermi 2019 Initial License Exam Outline Review Comments 8
5 TACLFU_TR1CC C (BOP)
C (SRO)
Failure of North Steam tunnel cooler. The crew will start the South Steam tunnel cooler.
6 E4AHFU_01CC TS A rigging event results in damage to the power supply to E4150-F600 HPCI Steam Supply Outboard Isolation 7
E51MF0014 E51MF0010 E41MF0007 C (BOP)
C (SRO)
RCIC Steam Leak. AOP 20.000.02 Abnormal Release of Radioactive Material 8
E501E5150F00 MTFASIS E501E5150F00 MTFASIS M (All)
CT1 EOP 29.100.01 Sheet 5, Secondary Containment -
>MSO Temperature - RCIC exceeds Max Safe ->
Mode Switch to Shutdown 9 C11MF0001 TA20TEN207TFS TA20TEN207ZST C (ATC)
C (SRO)
CT2 10 Rods Out ATWS EOP entry required.
EOP 29.100.01 Sheet 1A RPV Control Two Areas > MSO Temperature due to RCIC line leak in steam tunnel - EOP 29.100.01 Sheet 3A - ED ATWS o
NRC:
FERMI:
o NRC: Scenario 7, Event 3: What is/are the verifiable/mitigative action(s) for this event (Loss of Bus 65E)? Event 3 is listed as a Component malfunction for the BOP and TS evaluation for the SRO. Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct.
Associated description in the Narrative Summary does not provide any insight into the applicants response, other than to state that the crew will perform the AOP actions for the Loss of Bus 65E.
the mitigative strategy that the crew would normally be expected to implement in response to degrading conditions resulting from an un-isolable Primary System discharging into Secondary Containment Areas, and are therefore part of the Major Event.
FERMI:
Events are now:
Redacted information.
Redacted information.
NRC Supplemental Comment: Above sequence of events in SCN 5 D1 has been further revised to address the NRC's comment, following additional CE feedback to Fermi's response (see AS ADMINISTERED Scenario 5 D1).
Fermi 2019 Initial License Exam Outline Review Comments 9
FERMI:
The BOP will perform 20.300.65E Condition E:
Verify Div 2 RPS Pwr Source Sel switch red TRANS AVAIL light on (H11-P810).
Place Div 2 RPS Pwr Source Sel switch in ALTERNATE.
Cycle Scram Reset Switch.
Depress Inboard MSIV Isolation RESET pushbutton (H11-P601).
Depress Outboard MSIV Isolation RESET pushbutton (H11-P602).
Verify proper isolations and actuations (23.316, Enc B, RPS Bus B - Affected Equipment).
3 R11RF0978 C
(All)
TS A spurious trip of 65E-E6 will result in a loss of Bus 65E. The crew will perform actions for 20.300.65E Loss of Bus 65E.
SRO will evaluate TS.
4 B31RF0015 C (ATC)
C (SRO)
TS A RR pump speed will increase requiring the crew to trip A RR pump. Actions for single loop will be taken.
5 C11MF0001 C71MF0006 NB02F403_A TV ILSP C (ATC)
C (SRO)
CT1 Trip of East CRD pump. Place Mode S/W in SHUTDOWN per IA 20.106.01 CRD Hydraulic System Failure.
o NRC: Scenario 7, Event 4: The CRD Pump Trip with HCU accumulator low pressure alarm is listed as a Component malfunction for the ATC. There do not appear to be any verifiable/mitigative operator actions associated with this event as presently scripted, given that the action to place the Mode Switch in shutdown is unsuccessful due to the failure of Manual RPS to cause a scram. Appendix D, Section C.2.b, Total Malfunctions, states: To count as a separate malfunction, they must involve a significant system response and require operator action to correct. Associated description in the Narrative Summary does not provide any insight into the applicants response, other than to state that the crew will enter the AOP for CRD Hydraulic System Failure and implement the override contained therein to insert a manual scram. If there is no operator action to correct the Event 4 malfunction, then no Abnormal Event Instrument or Component (I/C) failure will be scripted for the ATC before the start of the Major Transient. This scenario, as presently scripted, reduces the examiners ability to properly evaluate an applicant in the ATC position.
FERMI:
Removed C(ATC), C(BOP) from event 4 NRC Supplemental Comment: SCN 7 D1 appropriately revised to address the NRC's comment, following additional CE feedback to Fermi's response (see AS ADMINISTERED Scenario 7 D1).
o NRC: Scenario 7, Event 5: Event 5 lists the Manual Scram as the Major Event.
Appendix D, Section C.2.e, Major Transients, states: A major transient is one that has a significant effect on plant safety and leads to an automatic (or manual, if initiated by an operator) protective system actuation, such as a reactor trip or an engineered safety system actuation. Based on this description, the manual scram action would be the operator response to a major transient, rather than the major transient itself.
FERMI:
Event 4 added M(All) Removed M(All) from Event 5:
Events are now:
Fermi 2019 Initial License Exam Outline Review Comments 10 Manual RPS Fails All Rods Stuck - LOW POWER ATWS. ATC will be able to insert rods with ARI.
6 B31MF0066 M (All)
Small LOCA.
7 E51MF0006 N20MF0018 N20MF0019 N20MF0020 E41MF0009 C (BOP)
C (SRO)
CT2 Trip of all condenser pumps, RCIC/HPCI autostart failure, BOP will start an alternate source of feed to maintain level (HPCI/RCIC/SBFW) o NRC: Scenario 7, Event 6: Safety-significant boundary conditions have not been clearly defined for CT-1 (Insert control rods with ARI). Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
CT update per comment.
o NRC: Scenario 7, Event 7: Safety-significant boundary conditions have not been clearly defined for CT-2 (Injection with available systems to maintain RPV level).
Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
FERMI:
See response Scenario 7, Event 6 Duplication/Overlap Concerns:
o NRC: Scenario 1, Event 2, and Scenario 2, Event 3, both have an RHR pump shear (Malfunction codes E11MF0029 & E11MF0034 are the same in both events).
FERMI:
On development of D2, Scenario 2 was change to EECW failure.
o NRC:
FERMI:
o NRC:
FERMI:
Redacted information.
Redacted information.
Redacted information.
NRC Supplemental Comment: Above sequence of events in SCN 7 D1 has been further revised to address the NRC's comment, following additional CE feedback to Fermi's response (see AS ADMINISTERED Scenario 7 D1).
Fermi 2019 Initial License Exam Outline Review Comments 11 o
NRC:
FERMI:
o NRC:
FERMI:
o NRC: Scenario 3, Events 1 and 3, are essentially the same event and are therefore not discriminating. Both events exercise the applicants ability to shift TBCCW Pumps. The only difference is that Event 3 includes the additional step(s) to effect leak isolation on the pump which has been removed from service.
FERMI:
Event 1 is a normal event using the SOP. Event 3 is alarm response followed by Two AOP entries and actions, involving different system response. For example The pump swap will not stop the event, to mitigate this component failure the leak isolation is required.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
Redacted information.
o NRC: Scenario 1, Event 9, and Scenario 7, Event 6, are both post EOP entry malfunctions with a failure of Manual RPS to cause a scram, followed by successful insertion of rods by Manual ARI initiation.
FERMI:
Four of the seven scenarios have ATWS actions related to the Major event, Furthermore, the audit and the scenarios from the last two years also contain ATWS related actions. Scenario 1 and Scenario 7 have very different ATWS conditions (High Pressure vs Low Pressure) and the major events including the ATWS action are different (Torus Leak vs LOCA). ATWS action are needed due to the requirement of EOP contingency use reequipments App D - C,2.g EOP Contingency Procedures Used Changing this ATWS will result in conflict with ATWS events with another scenario. Recommend the chief examiner accept this overlap and/or the validity of very different major event flow paths as per App D -
C,1.f Scenario Overlap NRC Supplemental Comment: All "AS ADMINISTERED" scenarios meet the intent of Appendix D, Paragraph C.1.f (Scenario Overlap), for large class sizes requiring the generation of more scenarios than normal (7 Fermi Scenarios).
Fermi 2019 Initial License Exam Outline Review Comments 12 o
NRC:
FERMI:
JPM Outline Comments NRC: The same Admin JPM (i.e., Title, K/A Reference, Designator No. 802-4101-431) is listed for the Conduct of Operations (#1) JPM on both the RO and SRO 301-1 Outline Forms. The JPM title includes a parenthetical reference that denotes SRO Only, which does not apply to RO applicants. All SRO Admin JPMs must be written at the SRO License Level (Reference ES-301, Paragraph D.3.c).
FERMI: The two JPMs are the same, but the SROs will be expected to perform additional steps associated with an SRO-only task to evaluate Technical Specifications. The notation SRO Only was removed from the RO outline 301.1 form.
NRC: Type Code P, Previous 2 Exams, is listed for the Conduct of Operations (#1) JPM on both the RO and SRO 301-1 Outline Forms. The assignment of Type Code P appears to be incorrect, as no evidence was found to indicate that the referenced JPM (Designator No. 802-4101-431) was included on either of the two previous NRC Exams.
Redacted information.
Redacted information.
o NRC: 2019 NRC Exam Scenario 3 and 2017 NRC Exam Scenario 2, both have Major Transients involving ATWSs with SLC component malfunctions.
FERMI:
Scenario 3 contain at least two events that were not used on the previous two NRC initial licensing operating tests as required by App D - C,1.f Scenario Overlap.
NRC Supplemental Comment: "AS ADMINISTERED" Scenario 3 meets the intent of Appendix D, Paragraph C.1.f (Scenario Overlap); i.e., different ICs and sequence of events leading up to the major transient, different post-EOP entry malfunction for SLC, and 2017 Exam Scenario 2 contains an additional post-EOP entry malfunction associated with a RCIC malfunction.
o NRC: 2019 NRC Exam Scenario 5, 2018 NRC Exam Scenario 2, and 2017 NRC Exam Scenario 3, each have Major Transients requiring Emergency Depressurization on Two Areas in Secondary Containment Exceeding MSO Temperatures, stemming from the inability to isolate a HPCI Steam Leak.
FERMI:
Scenario 5 contain at least two events that were not used on the previous two NRC initial licensing operating tests as required by App D - C,1.f Scenario Overlap NRC Supplemental Comment: "AS ADMINISTERED" Scenario 5 meets the intent of Appendix D, Paragraph C.1.f (Scenario Overlap); i.e., different ICs and sequence of events leading up to the major transient, and different post-EOP entry malfunctions. In addition, the HPCI steam leak was replaced by a RCIC steam leak.
Fermi 2019 Initial License Exam Outline Review Comments 13 FERMI:
The JPM was used on the 2017 initial exam. The 2017 outline submittal information for Conduct of Operations (#1) JPM is different than what was actually administered in 2017. The JPM administered on the 2017 exam has the same ID No. 802-4101-431.
Overall Operating Test Comments NRC: The potential for overlap exists between Control Room Systems JPM F, Reset Reactor Scram, and NRC Exam Scenario 3, Event 7, which includes actions for the ATC to manually insert control rods under hydraulic ATWS conditions using procedure 29.ESP.03, Alternate Control Rod Insertion Methods. The K/A associated with JPM F is 212000 (Reactor Protection System), A4.14, Ability to manually operate and/or monitor in the control room: Reset System Following System Activation. It is likely that the ATC will attempt to manually insert control rods per 29.ESP.03 by resetting ARI to enable performance of the Scram-Reset-Scram sequence to drain the Scram Discharge Volume and clear the hydraulic lock.
FERMI:
This was considered during JPM and scenario event development. The tasks are different because Scenario 3, Event 7 is an ATWS whereby RPS fails to actuate. Thus, although the ATC will perform 29.ESP.03 to insert control rods, including Section 4.0, Scram Reset and Manual Scram Re-initiation, he/she will NOT perform 29.ESP.03, Step 4.4 to reset the scram. This is because Step 4.4 is conditional and states If the 8 blue RPS lights are off reset RPS as follows:. For this scenario event, the 8 RPS blue lights will be ON so RPS reset will be unnecessary.
NRC Operating Test Outlines and Audit Operating Test Outlines NRC: Determination of acceptability for the Operating Test Outlines is contingent upon the submittal of Audit Operating Test Scenario D-1 Outline material for NRC review and evaluation.
Note: The 2018 NRC Exam JPM Outlines (i.e., Admin, Control Room Systems, In-Plant) are being used as the outlines for the 2019 Fermi Audit Exam.
NRC Supplemental Comment: Audit Operating Test Scenario D-1 Outline Material received 3/29/2019. CE review confirmed no overlap between the information provided in the Audit D-1 Outline Material and the NRC Operating Test D-1 Outline Material.
Fermi 2019 Initial License Exam Outline Review Comments 14 NRC Written Exam Outline / Audit Written Exam Outline Comments Note: The 2018 NRC Written Exam Outline is being used as the outline for the 2019 Fermi Audit Exam.
NRC: The following K/As have been duplicated between the Written Exam outlines for the NRC and Audit Exams. The Audit Exam questions written for these K/As will require comparison with those written for the NRC Exam in order to check for duplication/overlap.
o 203000 A3.07 (NRC Exam Question #28, Audit Exam Question #XX) o 218000 A2.06 (NRC Exam Question #42, Audit Exam Question #XX) o Tier 3 Generic 2.4.32 (NRC Exam Question #74, Audit Exam Question #XX) o Tier 3 Generic 2.1.37 (NRC Exam Question #95, Audit Exam Question #XX) o Tier 3 Generic 2.2.15 (NRC Exam Question #97, Audit Exam Question #XX)
FERMI:
o 203000 A3.07 (NRC Exam Question #28, Audit Exam Question #28) o Modified question written. Conditions in stem of question were modified so that a previously incorrect distractor is now correct.
o 218000 A2.06 (NRC Exam Question #42, Audit Exam Question #38) o Modified question written. Conditions in stem of question were modified so that a previously incorrect distractor is now correct.
o Tier 3 Generic 2.4.32 (NRC Exam Question #74, Audit Exam Question #75) o Modified question written. Conditions in stem of question were modified so that a previously incorrect distractor is now correct.
o Tier 3 Generic 2.1.37 (NRC Exam Question #95, Audit Exam Question #95) o New Question written for this K/A.
o Tier 3 Generic 2.2.15 (NRC Exam Question #97, Audit Exam Question #70) o New question written at the SRO level. 2018 exam had this K/A on the RO portion of the exam.
NRC Supplemental Comment: CE review confirmed no overlap between the Audit Exam questions and the NRC Exam questions identified above.