ML081200366

2008-03 - Draft - Outline Comments

ML081200366
Person / Time
Site:	Waterford
Issue date:	03/24/2008
From:	Division of Reactor Safety IV
To:	Entergy Operations
References
50-382/08-301
Download: ML081200366 (4)

Text

DRAFT Outline Comments Facility: W3 First Exam Date: March 24, 2008 Written Exam Outline January 10, 2008 Comment W3 Response Four Tier 1 KAs were selected (SRO- Technology-specific EPEs and APEs are 1/RO-3) were selected from the generic included in the sample. The issue with them EPE and APEs. It is not clear whether not being as obvious is that in Tier 1 Group 1, the outline generation software included all of the technology specific EPEs for CE technology specific EPEs and APEs in facilities are combined topics with generic the sample. EPEs. This means that if the generic EPE (ie, 040, Main Steam Line Rupture) is picked, it makes the technology-specific topic combined with that (For CE, that would be E05) unavailable until all of the topics have 1 been selected once. Similarly, if the technology-specific part of the combined topic was selected, the generic EPE/APE would be unavailable until all topics were selected once. This selection process is a fairly recent revision. K. Clayton in Region IV received guidance from Headquarters that this is the appropriate selection process. Our software used to treat the generic and technology-specific EPEs as separate items, but have revised our software based upon his advice.

One Tier 1 KA (RO) was selected from Three technology-specific KAs were selected the technology specific EPEs. It is not in Tier 1 Group 2. One EPE, 2 APEs on the clear whether the outline generation RO exam. Not sure what comment #2 is software included generic EPEs and addressing, but the selection is consistent APEs in the sample. with discussion above. The 3 technology-specific KAs selected were not from combined topics. 9 RO items are required for 2

Tier 1 Group 2; 3 of the selected items for W3 were technology-specific; there are 22 topics available to choose from for CE plants in Tier 1 Group 2; 4 of those topics have technology-specific KAs associated with them. Since 3 technology-specific topics were selected, it appears that those KAs are well-represented.

It is not clear whether the outline Our software generates a log file that writes generation software included all data directly from the outline generator as an appropriate items in each group (Tiers 1 outline is produced. We can save that file in 3 & 2) since only those selected were RTF format to allow for audits. One of the included in the outline. This makes the first items in the log file is a counted list of outline not scrutable as required by ES- topics available for outline generation. This 401, D.1.b. feature was recently added to our random Attachment X OBDI 202 - ILE Process

generator. I do have a log file for W3s exam, but since this is a Rev 9 exam, we had not validated the accuracy of the log file. (Our draft versions of logging required some revision, as this was a new feature of the software. We decided to spend the resources on Supplement 1 since Rev 9 exams will no longer be given after 4/15) Rev 9 Supp 1 outlines have the log feature integrated and we have validated the logging process for Supplement 1 exams.

Forwarded Western Technical Services password protected log file for WF3 2008 sampling methodology to Chief Examiner.

The Written Exam Outline Methodology Facility indicated there was no pre-screened states Outline is generated for all topics list of KAs with importance less than 2.5 that with KA importance greater than or equal should be included in the generation process.

to 2.5. However, ES-401, Attachment 2 Therefore, all KAs with values below 2.5 were states a KA with a less than 2.5 excluded, with the exception of Generic importance rating can be kept if there is 2.4.30 for RO, which must be included in the a site-specific priority. Have all screened selection process in accordance with ES-401, 4 KAs been reviewed to determine Attachment 2, and only rejected with whether a site-specific priority exists that justification. (This was the case for an item on justifies keeping it in the sample? the W3 exam)

Provide a list of pre-screened out KAs with indication that they have been Waterford 3 reviewed KA catalog and reviewed against site-specific priorities. determined that screening KAs with less than 2.5 importance value would not preclude adequately examining plant specific priorities.

ES-401-4 states the original KA selected My notes said that the original KA would be for SRO Q87 (012 A2.02) overlapped difficult to develop without overlap given the with RO Q48. However, RO Q48 KA is number of items on the audit and NRC 029 EK2.06. Overlap? exams. #48 is overlapped because the diagnosis and actions that would have been taken for loss of instrument bus effect on RPS would be a rehash of the same components.

This was a concern on the last exam in the same topic area, and we ended up having to 5

shuffle KAs during development. Rejecting 87 on this exam provided balance without excessive overlap on the audit and NRC exams.

Per phone conversation with chief examiner original SRO question 87 KA will be put back into written outline and revised outline will be sent to chief examiner.

CR WF3-2006-3510 was generated as a WF3-CR-2006 -3510 summary report sent to 6

result of the 2006 NRC exam. Has this chief examiner.

Attachment X OBDI 202 - ILE Process

CR been closed? If so, provide a copy.

Administrative JPM Outline January 15, 2008 Comment W3 Response Are all JPMs unique? If so, number RO JPMs are unique, will number per Chief 1

JPMs A1-A4 and SRO JPMs A5-A9. examiner preference.

When submitting the JPMs, send a copy Will submit original JPMs to Chief examiner of the existing Bank JPM for those for JPMs listed as modified.

2 classified as Modified so I can review the level of modification.

For RO / Equipment Control - is this Yes this JPM is for a different component.

3 JPM different than the one on the 2004 NRC exam?

For SRO / Equipment Control - the listed Yes this JPM is a different task on a different KA is 2.3.1 (Radiation Control)? If the component.

4 KA is supposed to be 2.2.13, is this JPM different than the one on the 2004 NRC exam?

For SRO / Conduct of Operations, KA The SRO is calculating the SDM to verify and 2.1.25: is this to calculate the SD Margin will have to make a TS call for emergency 5 or REVIEW an already completed boration.

calculation? What is the SRO level of knowledge at W3?

For SRO / Conduct of Operations, KA Will correct and submit revision to Chief 6 2.1.2: the Importance Rating is listed as examiner.

4.4 but should be 4.0.

For SRO / Radiation Control JPM - was Yes, this JPM was randomly selected.

7 this JPM randomly selected?

Control Room / In-Plant System JPM Outline January 15, 2008 Comment W3 Response Unless you have a strong feeling will designate JPMs per Chief examiner otherwise, my preference is to number preference.

the JPMs as S1-S8 and in-plants P1-P3.

1 (SRO-I dont do S2, SRO-U only do S1, S7, S8, P1 and P2.) You can delete the a, b, c, etc from the form and insert S1, S2, etc.

Need to ensure the Control Room EDG JPM deals with paralleling operations, System JPM for starting/loading an EDG scenarios deal with failure to start or output 2 (S3) doesnt overlap with actions in any breaker failure to close, these tasks are of the scenarios (unless the Alternate different in nature and should not overlap.

Path aspect makes it significantly S7; SIAS verifications are steps that are Attachment X OBDI 202 - ILE Process

different). Same is true for S7 - SIAS normally completed at procedure steps automatic actions are likely to be verified farther than scenarios normally run to, in one of the scenarios (unless the additionally the alternate paths events are alternate path aspect makes it different than events in the scenarios.

significantly different.)

For the 003-Start Reactor Coolant Pump This JPM was randomly selected.

3 JPM - was this JPM randomly selected?

Simulator Scenario Outline Comments January 15, 2008 Comment W3 Response Form ES-301-5 is not completed WF3 will resolve ES-301-5 forms and correctly for submitted schedule - wrong schedule and submit revision to Chief 1 crew positions for SRO-I1 and I3. Also, examiner.

can combine U1 and U2 on one line and RO 1,2,4 on one line.

Scenarios 1, 2, 3 have too many repeat Per discussion with Chief Examiner; Scenario events from the 2004 and 2006 NRC 1 is acceptable. Scenario 2,3, and 4 have 2 exams. been revised per discussion. See attached.

All scenario ES-D1 forms submitted as outline submittal rev 2 for ease of use.

Scenario 4 is low power but does not Per discussion with Chief Examiner Event 2 contain events that affect the low power. revised to inadvertent dilution at low power 3 Consider events such as inadvertent See attached.

start of Steam Driven AFW pump or inadvertent opening of steam dumps.

Attachment X OBDI 202 - ILE Process