ML21334A018

GG-2021-10-DRAFT Outline Comments

ML21334A018
Person / Time
Site:	Grand Gulf
Issue date:	10/25/2021
From:	Heather Gepford Operations Branch IV
To:	Entergy Operations
References
50-416/21-10 50-416/OL-21
Download: ML21334A018 (4)

Text

PROPOSED OUTLINE COMMENTS

Facility: GG First Exam Date: 10/18/2021

Retake Written Exam Outline

( 5 /12 /2021 )

Comment Resolution 1 NRC Generated N/A

Retake Administrative JPM Outline

( 5 /12 /2021 )

Comment Resolution Need to provide info on ALL Direct Licensee sent updated outlines on June 2, (Bank) JPMs as to when they were last 2021.

used on an NRC exam.

Also appears that too much content was pulled from the 2017 -12 exam. Will need to discuss the process for JPM development. Process starts with SF, 1 then system, then KA, then check for a JPM in the bank (randomly from a list of them). For example, you are selecting Safety function 1, then you pick Reactor recirc on an exam, then you pick a topic or KA for that system, then go to bank to see if you have one on that topic. If you dont, then you write a new JP M to cover the topic.

For JPM A 1 - Cant arrive at these topics For this JPM use the 2015 NRC exam JPM 2 from 2020 and 2017 exams using AR1 for Loss of SDC, time to 200F: admin NUREG processes. JPM. Direct from bank.

For JPM A2 - Cant arrive at these topics For this JPM, change to Conduct of from 2020 and 2017 exams using Operations and use the electrical print 3 NUREG processes. reading topic and write a new JPM or a modif y one on electrical print reading. You can use something similar to the fuse JPM from 2015.

For JPM A3-Cant arrive at these topics For this one, you can keep it as is in the 4 from 2020 and 2017 exams using outline, but it is now the A4 JPM.

NUREG processes.

For JPM A4 (RO) Cant arrive at these You can keep this one, but it needs to move topics from 2020 and 2017 exams using up into conduct of Ops and change the KA to 5 NUREG processes. G2.1.25 for using graphs.

Change label to A3-this is now in the A3 slot for the RO outline/ OBDI 202 - IOLE Process Rev 3 6 For JPM A5, A6, and A7 Okay as submitted on June 2, 2021.

For JPM A8 Change this JPM to Review liquid radwaste 7 discharge permit (see 2009 NRC Exam) and change KA to G2.3.6.

8 For JPM A9 Okay as submitted.

Retake Control Room / In-Plant System JPM Outline (5 /12 /2021 )

Comment Resolution Need to provide info on ALL Direct 1 (Bank) JPMs as to when they were last used on an NRC exam.

For JPM on SF1, it will need to be Changed to CRD system. Okay.

replaced with a CRD system or rod 2 control system JPM since reactor recirc has been used too much on the last 4 exams (3 of 4 times). It is usually integrated into scenarios also.

For SF 7, we will need to change that Changed to Control Rod JPM, which is SF1.

JPM to a sim JPM because it is a CR Cant do this since on last years exam. Need JPM and with current COVID risks we to do something with an instrument are being asked to not do those JPMs to (APRM/IRM overlap tests, high flux 3 minimize the risk of exposure to the functional tests, in-core probe, shift RPP crews on -shift. power, place channel in trip or bypass in RPS-one not used on scenarios, RPS trip breakers if modeled in sim, RPS alt power, perform Rod position indication alignment during startup, etc). Licensee corrected.

For SF9, used SBGT system too much Changed to sim JPM on SFP cleaning. Okay.

on last 4 exams (3 of 4 times) so will 4 need to use something else (such as CR ventilation) or anything else in that SF.

For in -plant JPM on SF3 will need to Changed JPM and SF. Okay.

5 pick another JPM since this was also on 2017 -12 exam.

Verify for in -plant JPM on SF 5 that this Changed JPM and SF. Okay.

6 was not the same JPM used on 2017 -

12. If so then we should pick another SF and different JPM.

Simulator Scenario Outline Comments (5/12/2021 )

Comment Resolution 1 Generic comments Licensee updated outlines to correct these comments.

OBDI 202 - IOLE Process Rev 3 Need to improve bounding on some CTs. Before procedure transitions are not usually accepted by the program office and instead the goal is to strive to attach plant parameters to the CT. I will point those out on the specific scenarios below.

Also need to put a Measurable Performance Indicator. block in your CT table for every CT that states the actions that must be done to complete the CT (ie the switch manipulations). As an example, if you must close MSIVs for a CT then you would put all four MSIV switches by name and number in the table in this block entitled Measurable Performance Indicator.

Also, your cueing block is supposed to be how you are cued that you need to do the action of the CT, so these are the items that cue the applicant to take the action (ie scenario 1 power is > 5% with fail to scram in CT1 of scenario1 would be the cueing). The Performance Feedback block in the table would be the white lights lit for ADS inhibit.

CT table should have the CT, the Safety Significance, Cueing, the Measurable Performance Indicator (you dont have this one in your table), and Performance Feedback (you dont have this one in your table either). For the example above, the performance feedback is green light on for each switch (red light off) and decaying main steam pressure, etc.

Generally, inhibit ADS is done on every scenario so it is not usually allowed to be counted as a CT because of this. It could be considered a post scenario CT if they dont do it. Treat it more like a bean in the scenario.

For scenario 1 CT2-have to be definitive in CT 2 language (for example when maintaining control of RPV level and restoring inst air must state that such that MSIVs do not auto close. OBDI 202 - IOLE Process Rev 3 For CT2 and CT4 - need something more solid that before exiting EP-2A.

For scenario 2 3 CTs bounded well. Need other items in CT table as discussed above.

For scenario 3 CTs bounded well. The 15 minutes on 4 CT1 needs slight improvement to state within 15 minutes of what ( when the GRP 1 alarm comes in, or ??).

For scenario 4 CT1 needs more clarification. ED before when? (How long can they wait to decide to ED?). The second part of ED prior to starting reflood is fine.

CT2 needs some clarification - prior to 5 securing injection systems. If they secure any system prior to flood up would that be a failure? They may pull back some systems as they approach the top. Also, how long does it take to flood up? Knowing when to stop to prevent over pressurization could be important too.

OBDI 202 - IOLE Process Rev 3