ML081190701

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NRC Comments to the Proposed Operating Test for the Fermi Initial Exam - January 2008
ML081190701
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 03/25/2008
From: Hironori Peterson
Operations Branch III
To: Jennifer Davis
Detroit Edison
Shared Package
ML080860174 List:
References
50-341/08-301
Download: ML081190701 (4)
v • d • e


Text

NRC COMMENTS TO THE PROPOSED OPERATING TEST FOR THE FERMI INITIAL EXAM - JANUARY 2008

Operating Test Comments rdmin JPMs (ES-301-1):

Comment Resolution

(-1)

ADMlN 1. EC I HPCl Surveillance Procedure / ro,sro (Generic 2.2.12):

1) KA changed to 2.2.14 which matches the JPM as
1) JPM does not match referenced KA ('2.2.12 written.

Knowledge of Surveillance procedures") because it only requires knowledge of location of HPCl System control room indications.

(-1)

ADMlN 2. CO1 /Core Thermal Limit Verification /

ro,sro (Generic 2.1.7):

1) JPM Steps 4 and 5 are not critical. If applicant does 1) Steps 4 and 5 are not critical not place a "check" in the box, or identify the correct date and time it is only an errata type problem. There is no safety significance associated with the mistake.
2) Only one critical step for RO. Need at least one more 2) Identified the following steps as critical for the RO:

RO critical item (ie. JPM Steps 1, 2, or 3?) or replace -identify MAPRAT greater than 1 and inform JPM. CRS;

-applicant does not initial acceptance criteria (ie. indicates understanding that surveillance is not SAT).

ADMlN 3. RC / Dose Limit / ro (Generic 2.3.4):

1) Wording of KA Generic 2.3.4 is from NUREG 1123, 1) Verified and corrected KA wording Revision 2. NUREG 1123, Revision 2. Supplement Final, has slightly different wording for the KA.
2) The following JPM Steps are not critical: Step 3 2) Steps 3,4,6, 7, and 8 are not critical.

(applicant doesn't have to use procedure, and is being given copy of form); Step 4 (applicant's name and SSN);

Step 6, examiner will cue the applicant with correct answer; Steps 7 and 8 are not critical (signatures are errata). There is no safety significance associated with anv of these stem.

ADMlN 4. C02 / Complete NPTD Form / r o (Generic 2.4.39):

1) On Form ES-301.1, this JPM is listed as Conduct of 1) Moved this JPM to the Emergency Procedures / Plan Operations, but it should be under Emergency Plan section of ES-301-1.

because KA Generics for Section 2.4 is Emergency Procedures / Plan; Generics Section 2.1. Move this JPM to Emergency Plan on RO Form ES-301-1.

2) JPM Step 6 is not critical (ED signature is errata, not 2) JPM steps 1 and 6 are not critical safety signifcant)
3) JPM Step 3, will the meteorological data be the same for all applicants (ie. is it actual data that may change 3) Meteorological data comes from the simulator depending on current conditions?). computer, so it will be same for all applicants.
4) 5) JPM Steps 7-9, why are these at discretion of the examiner? Title says '...complete and communicate..." 4) JPM steps 7-9 are part of the JPM and identified as Make steps part of JPM. critical.
5) Is this JPM time critical? Task Standard mentions 30 minutes. 5) No, procedure is not critical, procedure says "should."
6) Provide an answer KEY with the examiner's JPM.
6) Key will be provided to examiner.

Page 1 of 3

Operating Test Comments

(-1)

ADMlN 6. RC / Dose Limit and Extension I sro (Generic 2.3.4):

1) KA Generic 2.3.4 wording on SRO Form ES-301-1 1) KA wording corrected.

does not match KA wording on ADMIN 6 JPM. Make KA wording for the RO and SRO Forms ES-301-1, ADMlN 3, and ADMlN 6 consistent with NUREG 1123, Revision 2, Supplement Final, Generic 2.3.4.

2) Don't give area dose rate in the Initial Cue because it 2) Will remove dose cue from Initiating Cue is a critical step, should be determined from the survey.

Also, Smith's accumulated dose is given in the Initial Cue, so it does not have to be given again by the examiner.

3) "Obtain Procedure MRP 12 and form MRP12001 is 3) Intent was for applicant to identify and locate considered a critical step, so it cannot be provided until necessary procedures /forms. Will clarify in JPM the applicant determines which procedure is needed and locates a copy.
4) The following JPM Steps are not critical: Step 3 4) JPM steps 4, and 7-10 are not critical.

(applicant doesn't have to use procedure, and is being given copy of form); Step 4 (applicant's name and SSN);

Steps 7 - 10 are not critical (signatures are errata, and are identified on the form, there is no safety significance associated with anv of these stem).

ADMlN 7. EP / PARS and Classification / sro (Generic 2.4.40):

1) JPM is time critical. 1) JPM is time critical.
2) Have "restricted procedure" available for exam, need 2) Will have restricted procedure available for exam to control.
3) Redact JPM from ADAMS? 3) NRC redact JPM from ADAMS.

ystem JPMs (ES-301-2):

Comment Resolution JPM b. Refuel Floor High Rad (P,D,A,L,S):

1) Since multiple procedural steps are referenced in this 1) This technique is currently being incorporated into the JPM, denote the applicable procedure number with each licensee's program.

of the JPM steps.

JPM c. Manuallyhlnltiate SRV LLS (D,S):

1) Remove the 4 bullet of the Initial Conditions and 1) Moved bullet to Initiating Cue.

incorporate into the Initiating Cue.

(-1)

JPM f. Multiple Rod Drifts (D,A,S):

1) JPM Step 7 is not critical because placing the RMS 1) Additional critical step is to recognize multiple rod will not cause a plant scram. As a result, the JPM only drifts; and depressing RPS Manual Scram PES.

has one critical step.

JPM i. Restore SDC (N,EN,A,S):

1) SRO-U Form ES-301-2 and JPM list multiple KAs, 1) Only referenced one KA on ES-301-2 and JPM.

select onlv A4.05 (3 'A4s" are listed).

JPM 1. Defeat ARI Logic Trips (D,R,E):

1) Add KAs 295037 to Form ES-301-1, and 216000 to 1) KAs 295037 added to Form ES-301-1, and 216000 to JPM. JPM.

Page 2 of 3

Operating Test Comments JPM I. Shift IAS Dryers (D,R,E):

1) Move the last 4 bullets of the Initiating Cue to the 1) Last 4 bullets of the Initiating Cue moved to Initial Initial Conditions. Conditions.

cenarios:

Comment Resolution SCENARIO 1:

(-1)

Event 7

-is SBFW required for RWL restoration? If not, what is -Delete credit for SBFW ' C the significance if it is not started? If no significance, can't use as an event.

SCENARIO 2:

Event 3

-include East Condenser Alr Leak, label it as "M (All)" -Incornorated comment on D-I sheet.

SCENARIO 3:

SCENARIO 4 (spare):

(-1)

Event 2

-not an instrument failure "I6ROY for SRO. but is a TS. -Deleted loss of RWL indication as an "1(1 failure Page 3 of 3

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