ML18061A168

2017-12 Proposed Outline Comments

ML18061A168
Person / Time
Site:	Grand Gulf
Issue date:	12/11/2017
From:	Vincent Gaddy Operations Branch IV
To:	Entergy Operations
References
Download: ML18061A168 (10)

Text

Rev 01 INTEGRATED OUTLINE COMMENTS Facility: GG-2017-12 First Exam Date: December 4, 2017 General Comments (August 10, 2017)

Comment Resolution Integrated outline submittal (dtd 7-5-2017) was signed by Acting- Resolved. Submittal cover letter was signed by Management member 1 Regulatory Assurance Mgr who is not on the Exam Security but did not have access to exam materials. Future cover letters will be Agreement. signed by members of Exam Team only.

ES-301, D.1.f requires

• facility-specific and industry-generic operating experience be incorporated into the op test whenever possible.

• PRA and IPE be used to evaluate dominant accident sequences to determine if they are suitable for testing PRA and IPE information to be added to scenarios.

• PRA and IPE be used to identify risk-important operator PRA and IPE information has been added to JPM Summary document actions that may be appropriate for evaluation on the op test. and JPMs themselves.

2 5 JPMs are associated with PRA systems or actions and one JPM is Were these requirements met, and how are they documented on associated with plant Operating Experience.

JPMs?

Written exam questions will be reviewed and PRA/IPE will be denoted.

While this paragraph is specific to the op test, the same could apply to written exam questions to some extent. If a question addresses the spirit of D.1.f, is the reference to Op E or PRA/IPE documented in the written exam question worksheet?

Does GGNS plan to freeze procedures for the purposes of Procedure freeze will be following Operations Validation on or about operator training and examination? Is so, the details of, and the September 27, 2017. Forms will be sent to Chief Examiner when freeze 3

basis for, the freeze proposal needs to be discussed with Chief is executed. Procedures changed after freeze will be tracked and Examiner IAW ES-201, C.2.c and Attachment 2. reviewed with applicants post NRC Exam as a part of GAP training.

Has GGNS developed Exam Validation and Admin week 4 Submitted with comment resolution schedules that includes JPMs and scenarios? OBDI 202 - IOLE Process

Rev 01 General Comments (August 10, 2017)

Comment Resolution Has it been determined whether or not any of the applicants will 1 applicant Malcolm Smith will have a waiver for GFES > 2 years, require a waiver/excusal/deferment to sit the NRC exam? At the 5 Station will administer an update GFE randomly selected prior to initial facility contact meeting, it was discussed that GGNS would application.

identify waivers by Integrated Outline submittal.

Short summary of each JPM task was not provided with the JPM Summary was provided on 7-13-2017, directly after request.

Integrated Outline submittal as previously discussed with licensee. Summaries are very helpful in evaluating suitability of Discussed comments with Chief Examiner and have added information JPMs prior to development effort, especially for alternate path to summary to clarify JPMs.

6 and modified JPMs.

Review feedback with Chief Examiner during outline comment discussion. Ensure key critical steps are identified in the summary, especially for Alt Path JPMs.

Written Exam Outline Comments (August 10, 2017)

Comment Resolution 1 NRC generated Written Exam outline. N/A Form ES-401-4 file name contains Rev 0 but the document 2 does not contain the revision number. Put the revision number Revision number added to forms on the form itself (applicable to all forms, not just the 401-4).

Revise form ES-401-4 per sample provided for Proposed Exam 3 submittal. Updated form submitted with Comment resolution (GG-2017-12-ES-401-4 Record of Rejected KAs_Rev 1-btl.docx) OBDI 202 - IOLE Process

Rev 01 ES-401-4: At GGNS we are unable to determine Reactor Power at the Remote

• Explanation to reselect 295016 from AA2.01 to AA2.02 Shutdown Panel or external from the main control room. The ability to 4 states Also, having an ATWS during a Control Room determine or interpret reactor power for control room abandonment Abandonment is outside our design bases. Need to would infer ATWS which is outside our design bases. Explanation was explain comment as ATWS is not inferred by initial KA. changed and K/A rejection approved.

At GGNS the use of plant computers to evaluate Containment Temperatures is limited due to the computer indication is an average of ES-401-4: several instruments. Individual instrument indications are on the main

• Explanation to reselect 295027 from 2.1.19 to 2.2.25: not Control Room panels. These indications are used more readily by ROs 5

clear on use of reference materials if indication is only to determine the validity of RPV water level instrumentation by using Control Room panel. Caution 1 of EOPs. Caution 1 uses a table and specific containment temperature instruments to determine RPV water level instrumentation validity. Explanation was changed and K/A rejection approved.

ES-401-4:

• Explanation to reselect 295037 from EK3.08 to EK3.01:

After discussion and clarification with lead evaluator the K/A rejection 6 briefly explain how GGNS responds to ATWS conditions was approved.

if not circuitry.

ES-401-4:

• Explanation to reselect 262002 from A1.02 to A4.01: a Operations Representative reviewed the other KA and determined that KA with IR of 2.4 is not automatically invalid if there is a 7 the importance factor is below a 2.5, therefore A4 was randomly site-specific reason to include it in the sample. Was the selected. Explanation was changed and K/A rejection approved.

KA evaluated by GGNS and a determination made that it does not have a site-specific IR of 2.5 or higher?

ES-401-4: At GGNS the CRD system is considered to be the hydraulic and

• Explanation to reselect 234000 from A4.02 to A4.01: the mechanism portion. The Control Rod blade is part of the Reactor KA is to manually operate and/or monitor in the control Vessel Internal system, therefore, there is no tie between Fuel Handling 8

room - is there a tie between Fuel Handling Equipment Equipment and the CRD system at GGNS. Explanation was changed and the Neutron Monitoring system in the Control Room and K/A rejection approved.

(other than monitoring)? OBDI 202 - IOLE Process

Rev 01 Administrative JPM Outline Comments (August 10, 2017)

Comment Resolution Revise both form ES-301-1s per sample provided for Proposed Updated revision of ES-301-1 for RO and SRO submitted with Comment 1

Exam submittal. (GG-2017 ES-301-1_RO Rev 1-btl.docx) Resolution Ensure JPM Summary details (titles) match the form ES-301-1. Added Type Codes to JPM Summary document 2 Consider putting JPM Type Codes at the end of each JPM summary.

For Modified JPMs (AR2, AS1, AS4) - ensure a copy of original Original JPMs will be submitted with Modified JPMs 3

JPM is included in Proposed Exam submittal.

Title of surveillance is AC/DC Lineup Surveillance. JPM will only For RA2 - JPM Summary identifies AC Line Surveillance while address the AC portion of the Lineup since it deals with Tech Spec 4 301-1 identifies AC/DC. Which is correct? Ensure JPM Action for degraded AC sources. Changed all titles of JPMs to AC Summary details match the form ES-301-1.

Lineup Surveillance.

For RA2 - from JPM Summary, task appears to have LOD=1. There is no overlap between JPM and scenarios. Scenarios will identify 5 Also, what is the frequency of performance of this surveillance? a need to perform surveillance. The JPM performs the surveillance Is there any overlap with scenarios? which involves indications on multiple panels.

Copies of C size drawings will be available for applicants to request.

For RA3 - How are drawings obtained at GGNS? Full-size paper Additional drawings will be available on stick files and reference library.

6 copies or electronic access? How many drawings are required to Three drawings are required to complete the JPM (2 P&ID and 1 complete this JPM?

Electrical Drawing)

Will use the Computer on the Control Room Supervisor Desk or a 7 For SA1 - will this JPM be performed using laptop program?

separate laptop with program installed.

For SA2 - how many discrepancies are included and are they Number of discrepancies has not been determined as JPM is currently 8

more than LOD=1? Is the JPM based on OE? unwritten.

JPM tests skill of SROs to review relay affects both on plant operation For SA3 - how does this JPM test SRO knowledge? During 9 and Tech Specs. JPM used in May 2017 SRO Upgrade class.

what previous NRC exam was this given?

Randomly selected. OBDI 202 - IOLE Process

Rev 01 Time Critical JPM testing applicant ability to perform duties of For SA5 - the summary description is too general and lacks 10 Emergency Director for Emergency Plan EAL determination. EAL has sufficient information for a quality/applicability review.

not been determined. OBDI 202 - IOLE Process

Rev 01 Control Room / In-Plant System JPM Outline Comments (August 10, 2017)

Comment Resolution Revise both form ES-301-2s per sample provided for Proposed Updated revision of ES-301-2 for RO and SRO submitted with Comment 1

Exam submittal. (GG-2017 ES-301-2_RO Rev 1-btl.docx) Resolution Do any of the JPMs include Time Critical Operator Actions? None of the System JPMs are time critical. Time Critical Operator 2

Does GGNS have a program that identifies these actions? Actions are identified in Operations procedure 02-S-01-44.

Multiple JPMs have actions that are identified in the Station PRA for Core Damage Frequency. The JPMs have the PRA identified in the Do any JPMs include risk-significant operator actions? Does 3 front of the JPM. The JPM Summary identifies which JPMs are GGNS have a program that identifies these actions?

associated with PRA and Station Operating Experience. Also covered by 02-S-01-44, Time Critical Actions.

JPM P2 was used on the 2014 NRC Exam which had RO applicants.

Form ES-301-2 (RO) contains a Type Code of P for JPM P2 -

The previous 2 NRC exams for SRO candidates did not include the 4 but the form for SRO-I does not. Was JPM P2 used on previous 2014 exam. (2015 and May 2017) The May 2017 had no RO 2 NRC exams? Update appropriate form.

applicants.

Given 9 JPMs were Direct from bank (maximum allowed) - how The standard GGNS JPM bank has 196 JPMs and there are additional 5

large is the JPM bank at GGNS? JPMs contained in the NRC JPM bank that have not been transferred.

Do not any other JPMs (besides S3) qualify as Low-Identified additional JPMs that are performed during conditions for which 6 Power/Shutdown? Having only the minimum number of L the plant would have been scrammed or during startup conditions.

JPMs contains some risk. Discuss with Chief Examiner.

Neither of the NEW JPMs are Alt Path - per form ES-301-2, at Changed one of the alternate path JPMs to modified and changed 7

least one NEW or MOD JPMs must be Alt Path. actions in the JPM.

For all JPMs identified as P - identify the NRC exam they were JPMs used in previous 2 NRC exams are identified in the JPM and in 8 used on. Where all lessons learned from previous use the JPM Summary.

incorporated into current revision?

9 Ensure JPM Task Standards match-up with Critical Steps. done OBDI 202 - IOLE Process

Rev 01 Simulator Scenario Outline Comments (August 10, 2017)

Comment Resolution All scenario D-1s have in the Event Type blocks an A (CREW) 1 - apparently this is an identification for the crew using an AOP? Discussed with Chief Examiner. Designation is for crew use of AOPs.

Discuss with Chief Examiner.

In Scenario Activities (summary), it would be helpful to add 2 name of the event. These titles will be used on D-2s in Proposed Titles were added to Event summaries.

Exam submittal.

All Critical Tasks (CTs) must have as references licensing bases Critical Tasks are referenced to BWR Owners Group EPG/SAGs steps 3 documents and specific procedures identified for all required and site specific Emergency Procedure Basis procedure.

operator actions and performance limits.

If possible, provide the Chief Examiner an electronic copy of the Provided Chief Examiner with electronic copy of BWR Owners Group 4

BWR Owners Group Appendix for Critical Tasks. EPGs/SAGs.

OE from multiple NRC exams in Region IV: All Tech Spec Tech Spec entries for all scenarios have been validated by the 5 entries must be validated by Operations management (Shift Operations Representative, who is Shift Manager qualified.

Manager qualified individual).

Forms ES-301-5, Transient and Event Checklist, and ES-301-6, Revision number added to Forms ES-301-5, Transient and Event 6 Competencies Checklist, need to have a revision number in Checklist, and ES-301-6, Competencies Checklist.

header or footer (Rev 0)

Review each scenario from the perspective of leading the Discussed comment with Chief Examiner. Verified that the actions of applicants before Critical Tasks. Example: Scenario 3 - there is the applicant are different. One event requires the applicant to a Division 2 inadvertent actuation. The applicants will implement implement procedure to secure equipment actuated by the spurious 7

procedure and verify the actions. The Critical Task is to manually ECCS initiation. The Critical Task is to recognize that one division of actuate Div 1 when it fails to actuate - has the crew been cued ECCS did not actuate when the initiation signal is present and take for this action? action to manually initiate the respective division of ECCS. OBDI 202 - IOLE Process

Rev 01 Simulator Scenario Outline Comments (August 10, 2017)

Comment Resolution Verified that all Critical Tasks are measurable by the examiners.

All scenario CTs - need to verify they are distinctly measurable Operations Representative has reviewed the CTs and concurs that the by examiners with sufficient guidance provided in the D-2s. Also 8 CTs are sufficiently challenging to determine competency for the need to ensure each CT provides sufficient challenges to the applicants. Scenarios are designed that the applicants can fail the CTs applicants such that competence can be determined.

if action is not taken.

Scenario 1: Is CT-1 a Critical Task given the crew can Discussed with Chief Examiner. Comment resolved. CT-1 is a valid essentially operate indefinitely is the condition? CT.

Discussed with Chief Examiner. Recognition of failure of RCIC to isolate is not required for CT-3. CT-3 required recognition of two areas Scenario 1: With 3 failures to isolate a system on a signal, are exceeding their max safe temperature levels. Even if the candidate we leading the crew to check more frequently for the failure of recognizes the failure to isolate of RCIC, the CT is still valid because the isolation before it is important to recognize in CT-3? leak cannot be isolated due to power loss of the isolation valves.

Additionally, no applicant action is credited for the failure of RCIC to isolate.

Failure of the candidate fails to isolate the low pressure heater string will Scenario 1: Event 5 - What if the applicant fails to isolate? Will not cause a turbine trip, Reactor power will rise due to the loss of this lead to a turbine trip? Will this affect the next event?

feedwater heating, but will not reach reactor scram setpoints.

Scenario 1: Event 7 - Is this a Critical Task? The containment Scenario was revised to remove the fuel failure and use temperatures isn't threatened, the fuel is threatened and they can continue to exceeding their max safe values, resulting from the RCIC steam leak.

depressurize. Depending on how fast they insert control rods, CT-3 is based on a required emergency depressurization when two they could get all rods in, before CT-3. How many control rods areas reach max safe temperature levels. Temperature levels are due have to be inserted vs how long to reach the two max safes? to steam leak and will not be affected by the insertion of control rods.

Scenario 1: Event 8 - HPCS starts on low level, however, is there any value to the action? HPCS will have been terminated Allowing the HPCS Diesel to run with no cooling water, even with no in CT-3 so you have a diesel running, with no cooling water, but load, will result in significant damage to the engine and potential fire.

no load either. What is the significance of failing to secure the diesel? OBDI 202 - IOLE Process

Rev 01 Simulator Scenario Outline Comments (August 10, 2017)

Comment Resolution Scenario 2: Are Events 3 through 6 in the same procedure? The referenced procedure contains multiple sections for different What value is provided to examiners in having the SRO use the failures of a system. SRO will have to implement different sections of same ONEP in 4 successive events? Is there not a wide variety the procedure for most of the events.

of I/C failures available that would require the SRO applicant to Per discussion with Chief Examiner, event sequence of the scenario demonstrate knowledge of more than one ONEP? was modified to required SRO to implement a different procedure between the events.

Is this same issue in other scenarios? (multiple and/or sequential Reviewed remaining scenarios for this issue and found no other events from the same procedure) instances where the same procedure is used in sequential.

The bases for the five groups in CT-1 is to reduce the number of repetitions required for inserting all control rods.

Per discussion with Chief Examiner, the reference to five groups of Scenario 2: Event 7 - CT-1, what is the bases for the five control rods was removed from the CTs and placed in the D-2s as a cue groups being enough? This issue is in multiple scenarios.

to the examiners to allow all control rods to be fully inserted during the scenario after they have observed applicant actions to scram and drive control rods.

Scenario 2: Event 3 - No mention of accumulator faults due to The loss of a CRD pump will not cause a CRD accumulator fault in the the loss of a CRD pump. How frequently do these come in on simulator for approximately 10 minutes, based on simulation of the the simulator? Is it an extra TS call? Will it extend the scenario accumulator check valves. Applicants should have the standby CRD timeline past what is expected? pump restarted before this time.

EOP requires both SLC and control rod insertion if reactor power is >

Scenario 2: For CT-1, does EOP require both SLC and rod 5%. CT-1 of scenario 2 has been edited to remove OR from the CT insertion? Not sure the AND/OR statement is appropriate here. statement.

Is description meant to mean both? Is this in other scenarios? EOP does not require SLC if power is < 5%, so CT-1 in scenario 1 does not have SLC as part of the statement.

Failure criteria for CT-3 in Scenario 2 is failure to restore Scenario 2: For CT-3, what is the lower limit for RPV water Condensate/Feedwater injection before RPV water level lowers to less level that would constitute applicant failure? than -191 Compensated Fuel Zone, with concurrence from Operations Representative. OBDI 202 - IOLE Process

Rev 01 Simulator Scenario Outline Comments (August 10, 2017)

Comment Resolution Scenario 2: Shouldnt this scenario also have a CT for inhibiting ADS (like Scenario 3, CT-1) since RPV water level is CT-2 added to Scenario 2 for inhibiting ADS.

intentionally lowered due to ATWS >5%?

Scenario 3: Another example of cueing the applicants - first an See Scenario Outline Comment #7 inadvertent ECCS, followed by the failure of ECCS to actuate.

CT-3 is a valid task for this scenario. Only Division 1 ECCS systems Scenario 3: Event 6, Respond to a failure of Division 1 ECCS to are available for injection into the RPV due to the failures in the scenario automatically initiate (CT-3) - is this a well-defined Critical Task?

and applicant will be required to manually start Division 1 ECCS pumps Doe it only apply to Div 1 ECCS? What if RPV level is restored and direct manual opening of associated injection valves from locations with something else?

outside the Control Room.

Scenario 3: CT Is HPCS not available to restore level? HPCS pump trips when it receives an initiation signal in Scenario 3.

Scenario 4: Review comments for Scenario 1-3 events and Scenario 4 has been reviewed to ensure identified discrepancies are not Critical Tasks and ensure identified discrepancies are not repeated.

repeated in Scenario 4. OBDI 202 - IOLE Process