ML080720478
| ML080720478 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/29/2008 |
| From: | Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, NRC/RGN-II |
| References | |
| 50-327/08-301, 50-328/08-301 ER-08-301 | |
| Download: ML080720478 (9) | |
Text
POST-EXAM COMMENTS (Green Paper)
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Licensee Submitted Post-Exam Comments
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Sequoyah 2008-301 Simulator & Inplant JPM Comments Draft Exam Submittal JPM #
LOD UlE/S SIMULATER JPMs SRO-Upgrade ES-301, Page 14 of 27, states that SRO-U applicants must be evaluated on a Control Room Systems JPM related to ESF. Which JPM is being credited as the Control Room Systems ESF Task?
High Containment Pressure JPM is being credited for the ESF task. MAB 12/10/2007 Systems-"a" What is the success path for this JPM? There must be a success path in order for critical steps to High Ctmt P exist. A critical step is something that must be correctly performed in order to satisfactorily complete the task. If the end result is that neither Train "A" or "B" can be placed in service, then there would not be any critical steps.
JPM revised to include a success path. OK MAB 01/23/2008 Systems-"b" Is placing the HS in PTL critical?
RCP Seal Discussed during JP. PTL is not critical. MAB 01/23/2008 This JPM needs to be enhanced. If possible, add the same indications for the #4 RCP and the steps to secure the #4 RCP and close the FVC for that pump also. Added rx trip aspect. OK MAB 01/23/2008 Systems - "e" My evaluation places this JPM into Safety Function 3 (Pressure Control). This is an SGTR-MSIV Emergency/Abnormal condition procedure, which is related to the SGTR. According to NUREG-Fail to Close 1021, Form ES-401-2, SGTR (038) is linked to Safety Function 3.
Changed to SF 3. MAB 12/10/2007 Resolution to this comment affects having different safety functions represented for the Control Room Systems JPMs.
JPM "h" changed due to this comment. MAB 12/10/2007 Systems-"f' JPM Step 8: Is this critical? Not critical-corrected. OK MAB 01/23/2008 Page 1 of 2
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Sequoyah 2008-301 Simulator & Inplant JPM Comments Draft Exam Submittal Cal PR NI Systems - "h" This JPM, based on the title, deals with Inventory Control. Inventory Control is Safety Function 2.
ECCS - Fill JPM changed. MAS 12/10/2007 CLA Resolution to this comment affects having different safety functions represented for the Control Room Systems JPMs.
JPM changed to ensure different safety functions. MAS 12/10/2007 Systems-"g" For the most part the examiners will not provide cues to the applicants for simulator JPMs. For EDG instance, if the applicant needs to have an AO perform a task, we would expect them to use the phone to call the AO and the simulator booth personnel would correspond with the applicant on the phone. Some of the cues imply that the examiner would provide this kind of feedback, which will not be the case. It is OK for the cues to remain in the JPM with the understanding that the examiner will not use them most of the time. These details can be discussed during prep week. Discussed.
Applicants will use normal communications methods to direct field operations and request information. OK MAS 01/23/2008 IN-PLANT JPMs
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The reviewer has concerns that there is not enough discriminatory value in the in-plant JPMs. If "j" is replaced with a more discriminating JPM, then that may be enough to raise the overall level of the in-plant to something that is more acceptable. Currently there are only 10 steps designated as critical if you add all the in-plant JPMs together (and one of those steps is not critical).
In-plant JPM "j" has been replaced. The In-Plant JPM set is satisfactory for administration. MAS 01/23/2008 Page 2 of 2
Sequoyah 2008*301 Admin JPM Comments Draft Exam Submittal JPM #
LOD UlE/S Comments General All paperwork that is safe to hand to the applicants should be printed on a different color of paper.
This will help the examiners to correctly administer the JPMs and avoid invalidating a JPM due to incorrect administration.
Discussed with licensee. They agreed to incorporate. MAS 01/23/2008 COO #1 It is difficult to determine the discriminatory value of this JPM. The JPM must be designed to (RO&SRO) evaluate the process of arriving at the correct answer. In other words, the JPM cannot be designed License such that the applicant can have a 50-50 chance of performing the JPM correctly by stating that the Status license is Inactive. JPM requires more than a 50% chance of satisfactory completion. OK MAS 12/10/2007 JPM will be reviewed with exam team during prep week. Exam team may have ideas for enhancement. One more enhancement was made during IP. JPM OK. MAS 01/23/2008 EP Will the stated task match the KIA? How is an RO's role for a medical emergency related to (RO) emergency plan implementation? KIA is OK. The task is driven by Emergency Plan procedures.
MAS 12/10/2007 This JPM does not have the minimum level of discriminatory value for an NRC exam. This JPM must be replaced or significantly enhanced or if the EC task is conducive for RO performance, then consider using that for the 4th RO JPM. After the audit process, the licensee is not allowing any ROs to sit for the exam. This comment is resolved. MAS 01/23/2008 COO #2 In progress procedures should be a part of the JPM package. All parts of the operating test needs to (RO&SRO) be in a "ready to be administered" condition for prep week. In progress procedures have been Surveillance included in package. MAS 01/23/2008 Any paper work that the applicants are required to complete should be included as an answer key with all critical aspects of the key designated. Critical steps clearly marked in JPM. The only exception is that we agreed on prep week to add a statement to the Task Standard that identification Page 1 of 4
Sequoyah 2008-301 Admin JPM Comments Draft Exam Submittal EC (SRO)
Ctmt Closure A3 (RO&SRO)
Rad Con of TS Actions that are not actually required, would constitute unsat performance. This statement is not in JPM, but we will grade as if statement were included. MAS 01/23/2008 Reviewer has concerns that the surveillance is too specific as to which parameters need to be reviewed. The JPM may not contain the appropriate amount of discriminatory value if the applicant is only required to look at a small subset of parameters which is specifically directed by the initiating cue. JPM was expanded slightly. OK MAS 01/23/2008 Tech Specs were not provided with the draft submittal; therefore, they will need to be reviewed in detail during prep week. Reviewed during IP. OK MAS 01/23/2008 Initiating cue must be worded to elicit the correct answer and not an answer that is overly conservative. For instance, the table provided in step 2 could be used to develop an answer of 28 minutes. This would be correct with the information that I have to review. The RCS is Open, the closure will occur Inside Containment, and decay heat is less than 15 MWth. The JPM Initiating Cue must be very specific as to not allow alternate, unintended answers to be successfully argued as correct. The exam team must address this during prep week, if not before.
The Initiating Cue has been revised to ask for the "maximum" time. OK MAS 01/23/2008 Answer keys should be included with the JPM with critical steps marked.
Answer key included. MAS 01/23/2008 Any paperwork for this JPM must be ready for prep week. The examiners must see the JPM exactly as it will be administered during the exam. JPM is ready in as-to-be-given format. MAS 01/23/2008 Ensure that the maps and RWPs are clear enough that it will elicit only one correct answer. For instance, is there any way the applicant could perform the stay time calculation without using 10 mrem/hr for the calculation?
JPM enhanced to specify work between the #3 RCP and SG. OK MAS 01/23/2008 Have the licensee walk the exam team through the RWP to determine clothing requirements.
Performed during IP. OK MAS 01/23/2008 The cue must be worded such that to get the JPM correct, applicants cannot list additional clothing Page 2 of 4
Sequoyah 2008-301 Admin JPM Comments Draft Exam Submittal A4 (SRO)
EP requirements and then argue that it was conservative to where the extra protection.
Cue now worded to ask for "minimum" required clothing. OK MAS 01/23/2008 Will this be performed in the simulator? Will the simulator be representative of the scenario? Wind Speeds? RCS Pressure? Etc.
It will be performed in Simulator. Computer screen printouts have been included in the package and can be handed to applicant when the correct screen is accessed. Simulator conditions will not be representative of JPM. OK MAS 01/23/2008 Task standard should be more descriptive of what needs to be accomplished to satisfactorily complete the JPM. Time critical aspects, etc.
Standard enhanced. Time critical is now specified on Cue Sheet. OK MAS 01/23/2008 JPM must state in the Initiating Cue that the task is time critical. There will be two time critical aspects (1) 15 minutes to classify and notify the examiner of that classification and (2) 15 minutes to complete the notification form and hand it to the examiner (15 minutes from when the event is declared). Site procedures restrict them to notifications within 10 minutes (actually 5, but allowance for 10 minutes for communication problems - so we are allowing 10 minutes). All time critical aspects are now incorporated. OK MAS 01/23/2008 JPM Step 2 states that the declaration "should" be made within 15 minutes. This needs to state that it is required that the event is declared within 15 minutes of the JPM starting.
Corrected. OK MAS 01/23/2008 I
How do the applicants determine amount of subcooling? RCS pressure is not provided. Is this relevant? Will applicants want this info?
RCS pressure is not needed. LSLOCA is specified in conditions. OK MAS 01/23/2008 RVLlS levels are specific to certain instruments as indicated in the EPIPs. The JPM simply states "lower range" - is this an issue?
Discussed with licensee - not an issue. OK MAS 01/23/2008 All information that the applicant will need to correctly complete the notification form should be stated in the initial conditions. This is important with a time critical JPM because we do not want the applicant to claim that his notification form was late because the examiner did not provide timely Page 3 of 4
Sequoyah 2008-301 Admin JPM Comments Draft Exam Submittal information. For instance, JPM Step 3: it should not be necessary for the examiner to provide information on no injuries reported. This should be in the initial conditions. Conditions now included.
OK MAS 01/23/2008 Initiating Cue should clearly state to the applicant that they are to formally notify the examiner what their declaration is when they are classifying the event.
Cue does not include this - examiners will have to be diligent to state to them at the beginning of the JPM that they need to notify them when they classify the event. MAS 01/23/2008 This JPM should have an answer key for the notification form with the critical aspects clearly marked.
Answer key now included with critical aspects marked. OK MAS 01/23/2008 During prep week, do a detailed review of critical steps. For instance, correct completion of the notification form is definitely critical. JPM step 7 must be critical and a supporting answer key should be developed. Step 7 Critical pieces are marked as such on the answer key. OK MAS 01/23/2008 Also during prep week, make a determination of how far to take the JPM. It may be OK to terminate the JPM once the notification form is completed. Discuss with exam team and facility.
Mutually agreed upon end point determined during prep week. OK MAS 01/23/2008 Page 4 of 4
Sequoyah 2008*301 Scenario Comments Draft Exam Submittal Sc # I Evt #
LOD UlE/S COMMENTS General On prep week - discuss with the other examiners if they want all the blank lines deleted. This adds many more pages to the scenario than is necessary.
Pages have been reduced. OK MAB 01/23/2008 Sc1 1E5 What are the verifiable actions for the BOP?
Vacuum BOP starts 1B Condenser Vacuum Pump. OK MAB 01/23/2008 Leak Sc21 E3 It may not be possible to credit both the RO and BOP for an (I)nstrument malfunction. For both to get Imp P Trans credit, they each will need to have a separate diagnosis piece of the event. Discuss with licensee.
Fails Low There is the potential for each position to get credit for this malfunction - it depends on how the event plays out during the exam. The exam team is aware that each operator needs to get a diagnosis piece of this event. The scenario sets have more than the minimum number of Clls, therefore, not counting this event will not impact the exam. OK MAB 01/23/2008 Sc21 E4 It is not clear what the diagnosis and verifiable actions, based on that diagnosis, will be for the ATC SGTL and BOP. Discuss with licensee.
Each position has verifiable actions. There is enough substance to allow for competency evaluations on both operators. OK MAB 01/23/2008 Sc3 No comments on outlines.
Evaluate further when draft exam is submitted.
Scenario is OK. MAB 01/23/2008 Sc41 E5&7 Each event is designated as a (C)omponent for ALL. Discuss the diagnosis and verifiable actions with Page 1 of 2
Sequoyah 2008*301 Scenario Comments Draft Exam Submittal Sc # 1Evt #
LOD utEIS COMMENTS the licensee. These events mayor may not be conducive for crediting both board operators.
Event 7 is still listed for "ALL".
Each operator has verifiable actions for this event. Examiners will need to evaluate each applicant to determine if event can be credited for both during the scenario.
The scenario set contains more than the minimum number of ells, therefore not crediting this for both should not impact the exam. OK MAS 01/23/2008 Page 2 of 2