ML081190701
| ML081190701 | |
| Person / Time | |
|---|---|
| Site: | Fermi  (NPF-043) |
| 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) | |
Text
NRC COMMENTS TO THE PROPOSED OPERATING TEST FOR THE FERMI INITIAL EXAM - JANUARY 2008
Operating Test Comments rdmin JPMs (ES-301-1):
Comment
(-1)
ADMlN 1. EC I HPCl Surveillance Procedure / ro,sro (Generic 2.2.12):
- 1) JPM does not match referenced KA ('2.2.12 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 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 RO critical item (ie. JPM Steps 1, 2, or 3?) or replace JPM.
ADMlN 3. RC / Dose Limit / ro (Generic 2.3.4):
- 1) Wording of KA Generic 2.3.4 is from NUREG 1123, 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 (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 / ro (Generic 2.4.39):
- 1) On Form ES-301.1, this JPM is listed as Conduct of Operations, but it should be under Emergency Plan 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.
- 3) JPM Step 3, will the meteorological data be the same for all applicants (ie. is it actual data that may change depending on current conditions?).
- 4) 5) JPM Steps 7-9, why are these at discretion of the examiner? Title says '...complete and communicate..."
Make steps part of JPM.
- 5) Is this JPM time critical? Task Standard mentions 30 minutes.
- 6) Provide an answer KEY with the examiner's JPM.
Resolution
- 1) Steps 4 and 5 are not critical
- 2) Identified the following steps as critical for the RO:
-identify MAPRAT greater than 1 and inform CRS;
-applicant does not initial acceptance criteria (ie. indicates understanding that surveillance is not SAT).
- 1) Verified and corrected KA wording
- 2) Steps 3,4,6, 7, and 8 are not critical.
- 2) JPM steps 1 and 6 are not critical
- 3) Meteorological data comes from the simulator computer, so it will be same for all applicants.
- 5) No, procedure is not critical, procedure says "should."
- 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 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 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 considered a critical step, so it cannot be provided until the applicant determines which procedure is needed and locates a copy.
- 4) The following JPM Steps are not critical: Step 3 (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.
- 2) Have "restricted procedure" available for exam, need to control.
Comment JPM b. Refuel Floor High Rad (P,D,A,L,S):
- 1) Since multiple procedural steps are referenced in this JPM, denote the applicable procedure number with each of the JPM steps.
JPM c. Manuallyhlnltiate SRV LLS (D,S):
- 1) Remove the 4 bullet of the Initial Conditions and incorporate into the Initiating Cue.
JPM f. Multiple Rod Drifts (D,A,S):
- 1) JPM Step 7 is not critical because placing the RMS will not cause a plant scram. As a result, the JPM only has one critical step.
(-1)
JPM i. Restore SDC (N,EN,A,S):
JPM 1. Defeat ARI Logic Trips (D,R,E):
- 1) KA wording corrected.
- 2) Will remove dose cue from Initiating Cue
- 3) Intent was for applicant to identify and locate necessary procedures /forms. Will clarify in JPM
- 4) JPM steps 4, and 7-10 are not critical.
- 1) JPM is time critical.
- 2) Will have restricted procedure available for exam
Resolution
- 1) This technique is currently being incorporated into the licensee's program.
- 1) Moved bullet to Initiating Cue.
- 1) Additional critical step is to recognize multiple rod drifts; and depressing RPS Manual Scram PES.
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 Initial Conditions.
- 1) Last 4 bullets of the Initiating Cue moved to Initial Conditions.
cenarios:
Comment SCENARIO 1:
(-1)
Event 7
-is SBFW required for RWL restoration? If not, what is 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)"
SCENARIO 3:
SCENARIO 4 (spare):
(-1)
Event 2
-not an instrument failure "I 6ROY for SRO. but is a TS.
Resolution
-Delete credit for SBFW ' C
-Incornorated comment on D-I sheet.
-Deleted loss of RWL indication as an "1(1 failure Page 3 of 3