ML041890299

Comments on Draft Operating Test

ML041890299
Person / Time
Site:	Oyster Creek
Issue date:	04/19/2004
From:	Caruso J NRC/RGN-I/DRS/OSB
To:	Hackenberg J AmerGen Energy Co
Conte R
References
50-219/04-301 50-219/04-301
Download: ML041890299 (7)

Text

J. Caruso 3/23/04 OPERATING EXAM COMMENTS Comments provided per telecom to licensee Greg Young for JPMs on 3/1 l/04and for the scenarios on 3/22/04. General Comment Operating Exam QA sheets need to be updated after all revisions incorporated and exams finalized ex. ES-301-6 needs to be redone and each applicant needs to be listed for the scenarios the applicant will actually see to ensure adequate coverage. Greg agreed for security purposes to use color paper for all applicant handout material.

All but one JPM item is new (A.3 SRO JPM - bank item, last NRC exam).

RO/SRO Admin JPM A.l.l (200.01K) - Calculate bulk DW Temp (1) Needs WA number; (2) This is not at SRO level. Should have an additional requirement, for SROs to determine if the calculated value satisfies Tech Specs; (3) typo on data sheet header for column 3 move over above column; (4) Provide key for exam -

attachment filled out properly; (5) Revise initiating cue to delete procedure reference.

RO Admin JPM A.1.2 (200.0F) - Calculate TS log for Unidentified leakage (I) Needs critical tasks (*) noted on page 3; (2) Task #8 should be critical; (3) Revise initiating cue to delete procedure reference, it is referenced on the TS log.

SRO Admin JPM A.1.2 (200.01) - Approve Calculated TS log for Unidentified leakage -

Not sure what part of the JPM is required for SROs provide a separate stand alone JPM

- none provided at this time.

RO/SRO Admin JPM A.2 (200.0J) - Determine CS Surveillance Reqts Recommend changing initiating cue to Determine if it is acceptable to conduct 610.4.002 on Core Spray System 2 - current cue too leading.

RO Admin JPM A.3 (200.OM) - Calculate Stay time, Revise JPM to make more operationally oriented too simplistic. ex. The operator has so much exposure for this quarter, he is asked to enter an area to perform a certain job and have him refer to the RWP map to determine the area he is working in and come up with the stay time.

Applicant should be given a survey map to derive the dose rate in the specified area.

Also dont tell him what his quarterly limit is in the task condition.

SRO Admin JPM A.3 (200.OB) - Approve Rad Discharge - (1)incomplete need to include key - no prepared discharge permit submitted; (2) modify initiating cue to delete procedure reference too leading SRO should know what procedure to use as guidance.

0 SRO Admin JPM A.4 (200.OM) - Very basic EAL as written. Recommend that this JPM be re-written to classify event after scenario based on the administered JPM along with preparing the Emergency Report Form.

JPMs - General Comment - Mark on cover sheet in bold when JPM is Alternate Path.

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Only one generic outline submitted need to have a least one separate outline for the SROUs or at least provide a subset listing of those JPMs that will on the SROU exam.

Reminder 80% limit on bank JPMs.

JPM 218.01- (I) Revise intiating cue too leading You are the BOP operator respond as appropriate ; (2) Several ABN steps not included.

JPM 21 1.01 - (1) Initiating cue too leading dont need to mention procedure #; (2) step 2 is critical; (3) If SLC started for scenario #4 must replace not diverse.

JPM 21 1.Ol - (1) Initiating cue too leading - revise to say, you are assigned as the RO at the controls respond to plant conditions as appropriate; (2) List alarms that the operator should respond to for this JPM; (3) Make Step #I3 critical for SRO applicants to determine applicable LCOs.

JPM 200.00Q - Licensee will replace this JPM - terminate and prevent reqd action for Scenario #2, event #8.

JPM 223.01 - (1) JPM steps #4,# 5, and #6 appear to be critical?

JPM 262.07 - Appears to be too simplistic turns sync scope on and close breaker - make more challenging.

JPM 288.02 - Investigate whether step #9 is critical?

JPM 202.1 1 - Step #8 specifies 10.5 +/- 0.5 but the procedure (page 12) specifies 9.5 to 1 1.5.

JPM 274.01 - Typo step #I.

Scenarios Requested that the licensee provide the exam team copies of the Ops standards regarding soft skills such as communications, peer checks, command and control, briefs, etc.

0 Reviewed 3 new scenarios (#s 1,2,4). In general the critical tasks did not include well defined performance/success criteria iaw Appendix D also requested that the text be bolded. Greg said, that he intended to include performance criteria but acknowledged that the critical tasks could be improved.

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0 Scenario #I is more heavily weighted towards BOP required actions (if this scenario is selected as the other one to be used for the exam) consider assigning the SROls to the BOP position rather than the RO position.

Scenario #I, event #3 - (1) typo, actions are assigned to the RO and not the BOP as written also (2) the header for this event is wrong should be for reference leg break and level does not get low enough to initiate core spray as an auto action. (3) List affected alarm responses that should be referenced for this event.

Scenarios #2, event #4 - (I) Rod drifts all the way out but why is this a critical task?

(2) What is the performance/success criteria? (3) Does not appear that the BOP should get credit as shown on the outline only RO. Only actions taken by BOP are communications. Would not consider these as verifiable actions. - Greg did not disagree.

Scenarios #2, event #6 - (I) Does not appear that the BOP should get credit as shown on the outline only RO. Only actions taken by BOP are communications. Would not consider these as verifiable actions - Greg did not disagree.

Scenarios #2, event #8 - terminate and prevent is part of the CT. This is a duplicate of one of the proposed simulator JPMs 200.00Q - JPM should be replaced.

Scenario #2, event 8, if the crew is reqd to inject SLC then need to replace JPM 21 1,Ol.

(Looks like not required by plant conditions expected).

Scenario #4 is the low Dower scenario that must be used and one of the other 2 scenarios will be designated the spar to be decided during validation.

Scenarios #2 and #4 each have 3 events that involve starting the standby unit not very creative. Scenario #4, event 2, is essentially a duplication of scenario #2, event #5 replace with a malfunction that does not involve starting the standby unit -this change should help to resolve this concern.

Scenario #4, event 8, make sure that containment temperature gets high enough on the main steam line breaks that it is possible to exceed 281 F without operator intervention.

ES-301 Simulator Scenario Quality Checklist Form ES-301-4 Facility: @Jb h k Date of Exarn:qdl h#

Scenario Numbers: I I % I 4 Operating Test 11-No.:

I l l Initials QUALITATIVE AITRIBUTES 25 of 27 NUREG-1021. Draft Revision 9

ES-301 Transient and Event Checklist Form ES-301-5 OPERATING TEST NO.: 1LT Is04 g test number and Form ES-D-1 event numbers for Author:

NRC Reviewer:

26 of 27 NUREG-1021, Draft Revision 9

ES-301 Competencies Checklist Form ES-301-6 Comply With and mpliance for an RO.

ense type and enter one or more event numbers that will allow the e every for every applicant.

--pap NRC Reviewer:

27 of 27 NUREG-11021, Draft Revision 9

ES-301 Operating Test Quality Checklist Form ES-30 1-3 I.

' q -

Test Number:

Facility: C?yJh C t d Date of Examination#4?&hkaf Operatin

1. GENERAL CRITERIA rentiate between co

. references and tools, incl

. reasonable and validated designation if deemed to be ti

. specific performance criteria th Date 9 d 4 v

NOTE:

The facility signature is not applicable for NRC-developed tests.

1. Independent NRC reviewer initial items in Column "c;" chief examiner concurrence required.

NUREG-1021, Draft Revision 9 24 of 27