ad ~0/1/7-7hii nmp 1 ro exam comments10 52 i"slowly and rapidly" are relative terms....

ad ~0/1/7-7hii NRC RO EXAM Written Comments 0207 For JGC.xls

NMP 1 RO Exam Comments

Previously Provided 1 I1 8/07

NRC Comment Resolution

3 0 2 A and B implausible. Believe D is also correct. U Rewrote for caution tag instead x of danger tag Rewrote choices to be a more appropriate RO level-no

justification for RO exam use.

3 0 3 Consider as no reference? Verify w/ OPS as no reference and acceptable as 'from memory required knowledge". reference question. Added

3 0 5 2nd part of A and B put into C and D. Incorporated the change. X

3 0 6 Choice D recommend "test stopped however I think this change would result x

Suggestion only, if it still makes sense this way.

torus temperature can remain above op limit for next 24 hours".

in another correct answer. Changed to be . . ."stop because EOP entry condition is now met".

3 0 7 Maybe a little too easy. Recommend change Rewrote per suggestion. X

3 0 10 Add "per SOP-5.1'' Also change to 950 psig Incorporated the change. X

3 0 11 C and D plausibility concern. Incorporated changes. X

(See original comment sheet)

during startup.

Developed two new distractors. 3 0 12 3 0 13 Question plausibility of D. With valve in pre- Unable to come up with a better

3 0 18 Change to HCL Changed to HCL. TRAK updated

3 0 20 Is there a way to provide power level instead of Incorporated change. X

x transient mode, why would valve be fully closed? distractor. Replaced question

with new one.

(1/16/07).

Reformatted to include annunciator windows to identify plant conditions. Changed to HCL.

saying IRMs on Range 1 O? Change to HCL.

RO 21 "effects of the power loss" (editorial) Incorporated change. RO 22 List Power/Flow Map as Reference Provided Incorporated change.

during test.

Review Accepted? During Prep

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03/07/2007 2:20 PM of 4

NRC RO EXAM Written Comments 0207 For JGC.xls

NRC Comment Resolution

RO 23 Enhancement suggestion. Change times to 115, 125, 145 and 150 and stem to "when valves start to open".

Changed stem to say "when the ADS valves will open?" Left the times unchanged in the choices. Changing them to the suggested times will result in no correct answers. Incorporated change.

Changed distractor. Moved this to be new SRO 7, to address comments associated with both questions. Discussed with JC NRC. (1/24/07). REPLACED with new question that is SOP related rather than EOP.

RO 24

RO 25

Remove "RB Vent System Channel 11" from question. Distractor C, change "RPV depressurization will continue using....". Check for objective. Is this an SRO question? Will allow reference to be provided (EOP-3 flowchart), for now.

RO 26 Extensive Enhancement. Highly recommend the Rewrote per suggestion. change. Provide copy of original bank question. RO 27 Placed blue page question

Previously Provided

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NRC Comment

Don't like at all. All choices seem implausible anc the concept tested is simplistic. Enhancement. Add "per N1-OP-39". Reword t=l:30 to "receive an auto start signal".

Is this procedurally based?

Change D to be an action based on SOP-16.1 or

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[actual core flow. I"Slowly and rapidly" are relative terms. Choice D 10 52

Added explanation that basis is

Incorporated change.

Incorporated change. Made corrections to the justification section.

SOP-6.1

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RO 61 INeed to correct the EO.

sop-i .5. AS written it isn't an action. Change to HCL. Distractor analysis explanation does not seem correct. Make sure the explanation matches for wrong choices. Enhancement suggestion. 2nd bullet should be after time zero. Stem has leading cues. 0805 change to no actior taken instead of the valve is open. No CAPS for

03/07/2007 2:20 PM

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Resolution

Incorporated change.

Modified choices to eliminate use of the terms and changed original D distractor Provided explanation.

Rewrote for lower power level and use of P/F map.

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partially correct, because of use of "rapidly" term

KA mismatch. If possible explain our justification for match. Why this is an "immediate action".

Distractors have limited discrimination because correct answer is the only one that requires a scram. Possible fix to make it at 30% or at lower power to make other choices more plausible.

Choice A is a subset of evacuate the refuel floor. A could be partially correct. Is this "required-from memory knowledge?" Should it be open reference?

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lncorporafed change.

I? Modified the distracter. Provided explanation of intent of objective (from RBO description). These are BASIC operational actions and the candidate should be ablc to select the correct answer from the choices presented without the use of a reference. (1/25/07)

1 Fixed.

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'reviously 'rovided I1 8/07

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111 8/07 Fixed. Rewrote for no EOP use x knowledge.

Added justification.

Fixed.

No changes made. Additional words are not necessary. The opening statement identifes the area as PB102 Room. Licensed operators function as fire brigade leaders and the KA statement asks them to demonstrate some knowledge. It is not specifically a NLO question.

Made corrections to justification section. Setpoints checked.

30 62 Spell out acronyms PCPL and DBA. Don't want to provide EOP-4 to candidates. RO knowledge?

30 65

IO 67

Justify why B is plausible, even if MSlV are closed. Add "if any" and "why"

(ensure correct. IJustification section fix for "El 261 'I. 30 75

30 68

Previously Provided

Check to see if words need to be added with the zone numbers. An NLO question?

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Stem focus. Justification for A should be 5 E5. RB occurs at 1 E5. Check our setpoints to

Lccepted?

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03l07l2007 2:20 PM of 4

SRO 1:

SRO 2:

SRO 3:

SRO 7:

SRO 8:

SRO 9:

SRO 11:

SRO 14:

SRO 15:

SRO 16:

Added a bullet at 0920 that stated the fire damage was limited to the Reactor Building Ventilation System.

In this question the initial conditions have PSP being exceeded. If containment spray has been initiated a blowdown would be required. However, per the TMG all steps up to the blowdown step must be performed before evaluating PSP for a blowdown. It is a knowledge gap with some operators that have the belief that if PSP is ever exceeded a blowdown is required.

C. and D. are plausible because 1375 psig is a Safety Limit. A time line was developed to clarify the sequence of events.

Original comment: On the 2004 SRO exam 3 out of 5 of the SRO candidates missed this question. 4 out of 5 of the candidates got licenses. The candidate that did not get a license missed this question and 2 of the candidates that acquired licenses missed this question. Therefore, 2 out of 4 of the candidates that acquired licenses missed this question. 2 out of the 3 distracters were picked by the candidates that missed this question (1 B and 2 Cs).

Replaced Question with original RO 25.

A. and C. are answers that deal with a Torus overpressure of 0 psig. B and D are answers that deal with a Torus overpressure of 5 psig or the calculated value of 4.72 psig. Even though there are 2 maintains, 1 lower and 1 raise there is still symmetry with the choice due to there relation to Torus overpressure.

Original comment: The temperature controller on the liquid poison tank is a temperature indicator and controller and is used for local readings. Distracter B was changed to match the T.S. 3.1.2.e action statement. Also clarified answer explanations.

Replaced Question

Changed distracter D. from reading any operator to read an operator.

Changed spelling error (Tours -> Torus).

Original comment: Changed distracter C. and D. to make them more plausible. Concept is SRO related because SRO directs operations on the Refuel floor.

Replaced Question

Question deals with Technical Specifications and the difference between an isolated RRP loor> and an unisolated RRP loop.

SRO 17: This question deals with how a degraded line-up for the core spray system is affected by partial loss of AC power.

SRO 18: Changed distracters C. and D. to say HOT SHUTDOWN to better match the wording in T.S. 3.6.11.

SRO 20: Changed the word “should” to “required”.

SRO 22: Original comment: Question deals with the SRO direction of the SOPS.

Replaced Question

SRO 24: Changed “what must be done to satisfy Technical Specifications” to “what operator actions are required.” Taking away Technical Specifications reference in the stem leaves the operator with more procedures to think about and makes the question more difficult.

SRO 25: Changed the question to ask about containment spray operability and the necessary operator actions given the conditions.

Form ES-401-9 ES-401 Nine Mile Point Unit 1 Written Examination 3/07 Review Worksheet

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Licensee verified minimum overlap of written exam questions for last 2 NRC administered exams at this site. J. Caruso and P. Presby reviewed this exam. Completed review and consolidating comments on November 2, 2006. Comments provided to licensee on November 3, 2006. Verified resolutions of comments validation week 2/26-28. NOTE 1 : Reviewed all questions against WA statements specified in the question. NOTE 2: Resolution of comments in bold and italics print.

Rewrote answer choices to be more appropriate for RO level and made it no reference. H

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4. Job Content Flaws I 5. Other I 7. 6. I GI “/E/S I Explanation

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Q is not at the license level, really only a plant operator knowledge level. Distractors “aJJ & “ b are not plausible. Would not remove red clearance tag without authorization. “ D could be correct also to notify management. Rewrote question caution tag instead of danger tag and revised “D” distractor.

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Recommend repeating the information in part 2 of choices A & B into part 2 of C & D. Change made.

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Distractor “d” is not plausible. Also looks like fundamental level of knowledge. Recommend changing “ d to ”Test must be stopped”, however torus water temperature can remain above the power operation limit for the following 24 hours.” Revised “D” - okay.

3. Psychometric Flaws

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4. Job Content Flaws - lack- & -

5. Other 7.

Explanation

Enhance. Too easy. Very simple question. Might as well ask “what is the annual limit for TEDE?” Recommend posing a situation requiring more detailed evaluation and application of knowledge limits. Below is an example from a recent NRC exam at another site:

Examde Q#1: An Equipment Operator (EO) is required to enter an area in the Main Condenser wit1 a general area radiation level of 3 Rem/hr in order to investigate an EHC leak.

The EO’S radiation history is as follows:

D 1760 mrem cumulative exposure for the

19 Rem lifetime exposure to this date (TEDE NRC form 4 completed and on file No dose extensions have been obtained

current year (TEDE) D

D

b

The surveillance test will take 45 minutes to complete WHICH ONE of the following radiation exposure limits, if any, would be exceeded if the EO performs the surveillance test?

A. No limits are exceeded B. C. Exposure Limit ONLY D. Exposure Limit, AND Emergency Exposure Limit Revised question as suggested.

Administrative Dose Control Level ONLY Administrative Dose control Level AND NRC

Administrative Dose Control Level, NRC

3. Psychometric Flaws 4. Job Content Flaws 5. Other 7.

Explanation - Stem -0cus - -

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Raised some concern over plausibility of c&d and stem focus and possibly 2 correct answers a&b Revised stem to add per SOP 5.1 and to put in a s/u at 900# to make c&d more plausible having tc evaluate in light of the 900# limit.

Distractors “c” and “ d not credible. SDC HX will not overheat. Still have cooling flow unaffected. APRM Developed 2 new distractors.

Note: 13 FWP will coastdown and provide substantial flow for approx. 3 minutes allowing in this case allowing FWP 1 1 recovers.

Distractor “ d is non-credible. If valve was in manual before transient and is still in pre-transient mode (manual), why would it close? Also A&B both look partially correct ” A more correct but concerned “ B may be partially correct.

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Also, why would valve throttle to maintain 4.9. In HPCl mode, shouldn’t it try to control level at 65, via 72 inches? Both valves have different setpoints 65” for FWP 11 and 72” for FWP12 Replaced question with a new one.

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Explanation

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Level of knowledge appears to be higher order. Re- designated higher order.

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1. Recommend enhancing by providing a power lev€ indicative of IRMs on Range 10 rather than directly stating the condition. Statement that IRMs are on Range 10 acts as a cue to indicate there may be an interlock in play. Licensee will speciv that 2 lRMs are on range 10 and the other lRMs on range 9. 2. Simple Q but may be higher order. lncorporafea change to include annuciator window to identify plant conditions and changed to HCL.

The phrasing of the stem is misleading not sure what you mean by “effect of these conditions power loss on ... ”? Revised stem Describe the effect of the power loss..

Should the applicants have a power to flow map? Yes reference will be provided.

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3. Psychometric Flaws 4. Job Content Flaws 5. Other - sack- = - Explanation

Very simple. Suggested modification: Unit is at 90% power and experiencing a decrease in condenser vacuum. Vacuum is at 25.5 in Hg and lowering slowly when Battery Board 12 de-energizes due to a fault. Which of the following describes an immediate consequence of current plant conditions. A. ERV 121 and 122 control on ‘F‘ Panel will not function. B. Bypass Opening Jack Motor control on ‘A’ Panel will not function. C. Mechanical Pressure Regulator control on ‘E’ Panel will not function. D. EC Loop 12 control on ‘K Panel will not function.

A. Correct. Loop control not affected by loss of BBI 1 or BB12. Revised as suggested.

BE. True for BBI 1, not BB12 D. EC

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verified modified adequately

verified modified adequately

Distractors “ b & “d” are not credible. Why would an applicant choose to de-energize a safety board over a non-safety board to reduce load on an emergency diesel generator? Kind of a leading the way the question is phrased. Recommend re-structuring question to give range of response. Modified existing question to give a range of choices and made open reference. ~~ ~

Typo in Choice “c”. Missing an “s”. Should say “UPS loads ..,” How about “ A also S

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3. Psychometric Flaws 4. Job Content Flaws 5. Other 7 6.

J/WS Explanation

WA mismatch. Physical connections / cause-effect relations between RBCLC and ESW. This Q tests understanding that procedure requires use emergency supply (i.e., fire water through ESW

U system to cool RBCLC). Answer explanation seems to indicate that any of the distractor choices could provide cooling water except that only the fire system is used per procedure. Modified question, disfractors and answer to better match WA.

Recommend minor rewording of choices for structural consistency:

A. Control rods can be inserted or withdrawn. RWM has generated an error signal. B. Control rods can be inserted but can NOT be withdrawn. RWM has generated a withdraw block. C. Control rods can NOT be inserted but can be withdrawn. RWM has generated an insert block. D. Control rods can NOT be inserted or withdrawn. RWM has generated insert and withdraw blocks. Incorporated change.

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1. All distractors appear to be not credible. 2. LOD 1. Effect of blocking “cooling water” orifice is no cooling water flow. Since “cooling water” is likely

U for cooling, reasonable assumption is that device will heat up. Can be answered without system knowledge. Developed new question using same WA.

Add “per N1-OP-39“ to stem. Incorporated change.

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Explanation

Cannot identify correct answer without knowing status of RBEVS after the event. Recommend changing “t=O min” RBEVS status report to “t=l min” RBEVS status report.

Suggestion accepted. Changed T=O to T=7

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“Slowly”, “rapidly” and “large” are relative terms. Depending on the perspective of the applicant, coulc distractor “d’ also be correct? It is only considered incorrect by the author because of an assumption that the RPV pressure transient isn’t “large” and the power rise isn’t “rapid”. Modified choices to eliminate use of terms and changed “D ”.

3. Psychometric Flaws 4. Job Content Flaws 5. Other - :red. Dist. - -

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1. Stem has leading cues. 1 .l) Should not state disch valve open, should instead state, no operator action has been taken. Agreed by NMP change made 1.2) Should not ask what is approximate ACTUAL total flow. “Actual” telegraphs that total is not what it seems, No, will leave to differentiate from indicated flow. 1.3) Should not ask “after the pump is tripped, with the disch valve still open”. Rather just ask “which of the following is the approx total core flow [period].’ Agreed by NMP change made.

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WA refers to immediate actions w/out procedures. Control of cooldown rate at RSP 11 would be conducted with procedure. Licensee will explain WA match basis Provided explanation for WA match

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1 .Choice “a” look to be at least partially correct. Evacuation of the refuel floor and drywell would effectively keep personnel clear of the transfer canal area. 2. Is this required knowledge from memory? Modified distractor and applicant should be able to answer without reference.

S Is this required knowledge from memory? Licensee states required knowledge from memory and wili corrected LO.

3. Psychometric Flaws I 4. Job Content Flaws 5. Other 7. - dinutia - - Dist. Link

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Non-credible distractors. Distractors have limited discriminatory value because correct answer is only answer which includes a scram action. Common equipment operator knowledge that cannot operate with sustained loss of TBCLC because of loss of cooling to key components (coolers for gen hydrogen, gen stator water, recirc mg sets, and turbine oil). Rewrote for lower power level and use of P/F map.

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4. Job Content Flaws 5. Other

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1. Expand acronyms (PCPL, DBA) in choices. 2. Do not provide EOP-4 flowchart. Flowchart reduces discriminatory value of distractors “c” and “d’, because it would show conditions not met to require those actions. RO exam in general should not need EOP flow charts. 3. I think this question is already asked somewhere else maybe on SRO portion, please verify this not the case. Rewrote for no EOP use.

“ 6 distractor not plausible with MSlVs closed. Licensee that operators have selected this distractor in the past on similar questions will added this to the justifcation.

If the action is important enough to test, it is strongly implied that some action is needed. Could add the words in the stem, ‘Which one of the operator actions should be performed, if any..”

Does the stem need to identify area covered by “DX- 21 23A and B’ (Electrical Power Board Room 102)?

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3. Psychometric Flaws 4. Job Content Flaws 7.

Explanation

Stem focus - Initial condition of all SRMs reading I E5 revise to 1 E4 since would have a rod block at :his level relates to distractor “A’. Revised

5. Other

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Explain answer explanation talks about RB 237 vice 261 ? Revise justification to correct. Revised

Sable Spreading Room fire could have damaged 3quipment needed to establish safe shutdown Zonditions. Recommend providing information in stem about what equipment was affected. Fire is imited some equipment that affects safe s/d. Without the competing - too simple. Added a bulle to clarify.

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Is the first condition meant to be a static power level at 50% with an ATWS or just a short transient? It is not clear whether a safety limit been exceeded. Indicated reactor power at 50% may be a snapshot in time as the rods are inserting on the trip that actuated on the large LOCA? The MCPR c 1 .O at the initiation of the event is intended to ensure protection of the clad integrity if a LOCA occurs (which this question postulates).

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What is meant by the term “MCPR” in choices “a” and “b’? How does MCPR indicate the safety limit has been exceeded? A time-line was added for clarification.

4. Job Content Flaws 3. Psychometric Flaws 5. Other 7.

Explanation - Stem -0cus - - - S

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With EOP-3 provided as an exam reference this would be a direct look-up. Q too easy? EOP-3

level - just stating basis for bypassing MSlV isol for ATWS. Replaced question with original RO 25

U provided for Q#SRO 14 reference. Fundamental

S I 1. Why can you assume that because the LP temp indicating controller and alarm temp switches are +20F in error that the temp of the tank will also be necessarily our of calibration by 20F??

2. In any case this is a very easy spec borderline direct look-up the graph interpretation may be the only saving grace.

3. Distractor “b” is non-credible given TS since spec does not require SD within 1 hour for any condition. Maybe change to initiate SD in an hour for first part of TS. Replaced question

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Change word in choice “ d from “any” to “an” Done E

5. Other I 6. 7. 3. Psychometric Flaws I 4. Job Content Flaws 4 “/“S I Explanation ininutia #I I units

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TrS [fypo in stem - “Tours” rather than “Torus”. Fixed

1. Distractors “c” and “ d non-credible. Pretty obvious guess would be that air is needed to operate a grapple rather than a hoist. Most hoists are motor - cable drum type devices. LOD=l?

2. Why specify “new” fuel assembly vice spent fuel probably more appropriate. “Placed in safe location” guidance particularly important for irradiated assemblies . Re vised dis frac tors

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1. Distractors “c” and “ d are non-credible. Both TS 3.6.1 1 and 3.6.1 3 specify actions to go to Hot Shutdown, defined as greater than 212 deg F may want to state hot s/d Revised disfractors

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Re-word stem condition, Per the conditions stated E the CRS is expected to direct what action next?

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Do not give just the detail “A” of EOP-2 give entire flow chart EOP-2 as Dart of Dackaae.

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4. Job Content Flaws 5. Other 7.

Explanation

3. Psychometric Flaws - Stem -0cus =

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1. Distractors “a” and “b” non-credible. Will have to scram. Lowering power would not mitigate the svent. Loss of 13 FWP lose 80% of flow can’t recover.

2. SRO only? RO knowledge should require understanding of need to scram on loss of FW P 13 from full power. Also reasonable to expect an RO to know from memory that SOP-16.1 would not be required post trip.

3. LOD=l

4. 10 CFR 55.43 (b)(5) applies rather than (b)(2). Redaced auestion -~

1. LOD=l direct look-up. Q does not appear to be SRO level. Really RO level to determine cause of isolation. 2. “A & C distrators not plausible for second part of answer. Revised

1. too easy direct look-up with EOP provided. 2. “B&D not plausible. Changed the question

The regional review of the NMP-1 written exam submittal concluded a total of 11 unsat questions.

Nine Mile Point 2007 Exam - Op Test Review Comments

Simulator Scenarios

General

1 . Suggestion to eliminate error-likely situation. Change event trigger numbers in batch file to match event numbers in scenario guide. The lead examiner will cue booth operator for next event based on event numbers in scenario guide. Better human factoring to align trigger numbers with event numbers. Licensee agreed with comment

2. Gil Johnson comment: N1 -SOP-I .2, “Recirc Pump Seal Failure”, directs simultaneous closure of suction and discharge valves. Shouldn’t the guidance be to close the suction valve first (valve dp issue)? Recommended that Ops evaluate the procedure

1. Event #4, “Recirc MG Set Overheat”, cannot be credited as C (ALL) and simultaneously as R (RO) because of double-count and also because no substantial actions required of BOP. Should count only as C (RO). The RO will get credit for reactivity manipulation in Event #6.

2. Event #4 expected actions pages list actions to shutdown and isolate both 13 and 14 recirc loops. Does not appear as if RRP #14 should be shutdown. Typo licensee agrees and wi// fix.

3. Event #6, “Recirc Master Cntrlr Failure”, cannot be credited as C because no substantial actions taken by BOP. Should only be counted as R(R0). Actions to re-adjust steam seal pressure on power reduction really a continuation of hidher response to Event #5 (Stm Seal Regulator Failure).

4. Recommend changing events (trg 6 & 7), currently on Mode Switch to Shutdown, to a single separate trigger, manually actuated from the booth. If applicants trip the plant early in scenario, would be good to have option of regrouping, instead of next event automatically occurring.

5. Event #7, “Loss of Vacuum, Rx Trip”, expected actions page describes RO throttling recirc master flow 25 to 43 Mlbm/hr. Action cannot be performed, cntrlr failed in earlier event.

6. Event #8, “DW Steam Leak”, cannot be credited as C(RO), because no substantial actions listed for RO. All actions taken by SRO/BOP. Credit as C(SRO/BOP) only.

Scenario #I

Page 1 of 4


Scenario #2 1.

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Looks like batch file has ECO9B inserted when scenario set up. Won’t that cause valve to immediately go to 50% position? If so, how will applicant succeed in timing valve open stroke, per the scenario guide?

Recommend associating insertion of ECO9B on occur on 4 second time delay after valve handswitch is taken to CLOSE. Otherwise must rely on booth operator attentiveness to insert malfunction in correct 20 second time window after handswitch taken to close. Licensee indicated that this validated okay and will evaluate furfher during validation.

Event #7, “ATWS” lists RP09 as one of the malfunctions. Cannot find this malfunction listed in the batch file. Validated okay and saved IC should be okay will verify during validation. Critical Tasks 2 & 3 look related and should consider combining into a single task.

Scenario #3

1. Event #lo, “RBEVS Failure” should be credited as C(BOP), not C (A LL) .

2. Cts 1 & 2 typos RWCU & RClC systems also PO-9 & 10 Scenario #4

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Scenario summary mentions “following the power reduction” in reference to raising power. Should say “after raising power, . . .”. Submittal is missing Page 1 of Batch File “n06scen4.bat”. Event #3, “APRM Failure”, should not be credited as I(ALL), unless both RO and BOP take substantial actions. Appears from expected action pages that RO is the operator taking mitigating actions. Event #5, “EPR Failure” is credited to RO. However, in Scenario #1, the BOP was credited for MPWEPR operations. Why do we expect RO to respond this time? Normal evolution for scenario #1 BOP trained to do normals. EPWMPR appears to be tested on all scenarios consider other malunctions. Event #7, “Loss of PB102” is credited at C(B0P). Should be C(R0) instead, based on expected action pages. Event #8, “MFW Pump 12 Trip”, credited as C(ALL). Should only be credited to station that starts backup injection pumps. Need enough time between Event #8 and Event #9 to ensure this action is taken. Event #lo, “Loss of Core Spray”, credited as C(ALL). Should only be credited as C(BOP), based on expected action pages.

QC Forms Form ES-301-4, Transient and Event Checklist

1. Scenario #2 has 4 CTs, not 3 CTs.

Page 2 of 4


Form ES-301-5 and ES-301-6. Checklists 1. Day 3, Scenario 1 :

BOP loses Events 3 and 4 RO loses Events 4 and 8 RO Event 6 changes from I/C to Reactivity

2. Day 1, Scenario 4: BOP loses Event 7 BOP gains Event 5, Event 10 RO loses Event 5 RO gains Event 7 Who gets credit for Event 8? See Scenario comments.

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JPM COMMENTS - general comment the JPM exam set overall is very simple and doesn't adequately test operator understanding as required by part 55.45. Consider replacing at least JPMs 2 or 3, and 4 or 8 as a minimum.

JPM 1 - Step is only a verification step and is not critical.

JPM 2 - 1) Overly simplistic alternate path doesn't really test operator understanding Start alternate fan train there is a problem and then shift back to other fan. Suggest modifying further or replacing. 2) Consider clarifying the initiating cue shift fan trains from 11 to 12 and then place in fast speed.

JPM 3 - Overly simplistic alternate path doesn't really test operator understanding Start alternate fan train there is a problem and then shift back to other fan. In addition, not really a safety significant task - licensee agreed. Suggest modifying further or replacing.

JPM 4 - Very simple consider modifying or replacing.

JPM 6 - Typo in Initial Conditions "Reactor" in 2nd condition.

JPM 8 - 1) Very simple consider modifying or replacing. 2) Steps #3 and 18 not critical.

ADMIN JPM COMMENTS

RO JPM 2 - Cue and initial conditions are leading. Make the task more operationally oriented by revising the task to review a proposed blocking & tagging permit.

SRO JPM 3 - Step #8 notify RE not critical.

SRO JPM 5 - No key attached for filling out forms.

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ad ~0/1/7-7hii nmp 1 ro exam comments10 52 i"slowly and rapidly" are relative terms....

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