ML120180212

12 Draft Outline Comments

ML120180212
Person / Time
Site:	Grand Gulf
Issue date:	12/02/2011
From:	NRC Region 4
To:	Entergy Operations
References
50-416/11-301
Download: ML120180212 (4)

Text

Attachment 6 OBDI 202 - IOLE Process DRAFT OUTLINE COMMENTS Facility: GG First Exam Date:

December 5-9, 2011 Written Exam Outline (Date) Comment Resolution 1 Ensure revision numbers at the page level for SRO/RO written exam. Request we do this at the question level (versus page level) 2 SRO- re-sample Tier 3 (Radiation Control) K/A 2.3.4. SROs have had this K/A on the last two exams. Replaced with 2.3.11 3 4 5 Administrative JPM Outline (Date) Comment Resolution 1 SRO - Emergency Procedures/Plan, K/A 2.4.41 used on last two exams. Re-sample this K/A 2 RO - Equipment Control, K/A 2.2.13 used on last two exams. Re-sample this K/A. 3 Was the admin previously used on the RO exam from 2010 randomly selected?

Yes. Selected randomly from all on previous 2 exams. 4 5 Attachment 6 OBDI 202 - IOLE Process Control Room / In-Plant System JPM Outline (Date) Comment Resolution 1 Need K/A and Importance Rating notated for each JPM.

Done 2 Any of the Simulator JPMs to be ran in parallel? Yes. See proposed schedule.

3 288000/Secure Fuel Pool Sweep- this appears to be a ninth Simulator JPM which is unnecessary. Also, this JPM is designed to be administered in the Control Room. No JPMs on this test will be administered in the control room. This was intended as a backup JPM. It has been removed from the outline.

4 Startup Shutdown Cooling B - I assume this is RHR pump B? Correct. 5 Simulator Scenario Outline Comments (Date) Comment Resolution 1 Add Rev number to all D-1s. Revision numbers added 2 Scenario 1, Event 8: Critical Task to place the Mode Switch in Shutdown when the reactor enters the Exclusion Region on the power to flow map - Should this critical task occur before entering this region? Note 1 (at the end of this document) 3 Scenario 1, Event 9: Critical Task to restore RPV level greater than -191" when reactor pressure decreases to 219#. Does this task need to occur before a certain parameter is reached? Define the failure mode of this task. Note 1 4 Scenario 1, Event 10: This is the third major for this scenario and it looks like only the ACRO gets credit. Does the ACRO not have any verifiable actions on the major for loss of AC? The ACRO's actions that result from event 7 (loss of AC) are wrapped up in event 8 (RPS automatic scram does not occur).

Attachment 6 OBDI 202 - IOLE Process 5 Scenario 1, Event 7: Loss of Service Transformer 11. Is this a loss of all AC? It appears the guiding procedure is an Off Normal which leads me to think this should be counted as an Abnormal and not a major unless it is a total loss of AC. This is a partial loss of AC power; however, this loss of AC causes a loss of both RFPT's and a loss of the only remaining Recirc pump, both of which would normally cause an automatic scram. RPS fails to scram in this scenario and a manual scram is inserted by the ACRO.

6 Scenario 1, Event 10: What EP is entered for this major? A FW rupture inside the drywell will result in an entry into EP-3 (containment) 7 Scenario 2, Event 5: Does the ACRO have verifiable actions for failure of two APRM channels in order to constitute an Instrument bean? The ACRO will be directed to bypass an APRM. 8 Scenario 2, Event 6: Critical task for the crew to close MSIVs when MSL annunciators alarm. Define by when this task has to be completed. If the crew closes MSIVs 5 minutes after alarms is this ok? Need drop dead limit to define success. Note 1 9 Scenario 2, Event 8: What is the I/C event and verifiable actions for the ACRO/BOP for the RCIC room unisolable steam leak? This requires the operator to attempt to isolate the leak by placing the E51-F063/F064 handswitches in the closed position. Also, this scenario simulates a motor pinion failure in which the isolation does not complete and the operator must identify and report this failure.

10 Scenario 2, Event 8: Critical Task to emergency depressurize. Is there a pressure limit by when this has to be done? Define by what limit this task must be completed. Note 1 11 Scenario 3, Event 4: Appears to be one of two Abnormals listed for this scenario. What is the other scenario? Event 6 utilizes an ONEP but is a Major and could not be counted as an Abnormal as well. The other abnormal is event 3.

12 Scenario 4, Event 3: No actions taken to restore the 16BB3 bus? This bus is locked out. Operators may attempt to re-shut the breaker once, but this will not restore bus power in this case.

13 Scenario 4, Event 4: Control Rod Drift is categorized as a Major event. Does this event lead to scram? Appears to be an Abnormal. If it is a Major it can't be counted as an Abnormal. This leads to a scram. The crew will reduce power using Recirc flow control valves, but when a second rod begins to drift the ONEP will require a scram.

14 Scenario 4: What are the Abnormal events in this scenario? No component/instrument failure after event 5 (or event 4 if this really is a Major) can be counted as an Abnormal event. Outline revised to reflect 1 Abnormal event.

Attachment 6 OBDI 202 - IOLE Process 15 Scenario 4, Event 4: If event 4 is a Major it can't count as a Reactivity event as well. Prior to the scram, the operator is required to lower reactor power using Recirc flow control valves. 16 Scenario 4, Event 6: Critical Task to re-energize the 17AC bus with an alternate feeder. When does this have to be completed? Define success. Critical task revised to reflect the crew's need for this bus. Note 1 does not apply This CT is per NUREG-1021 App D.

17 Scenario 4, Event 7: This event utilizes an "Ops philosophy" procedure-will cooling water be restored to this DG? Cooling water is not restored to this Diesel Generator.

General Outline Comments (7/20/10)

Comment Resolution 1 Suggested improvement - cross reference of written exam KA's to 55.41/43 and op test KA's to 55.45. This would provide objective evidence for 4.b on Exam Outline Quality Checklist (ES-201-2). Will add specific question KA's used on next outline submittal with the draft exam on 10/14/11. 2 Ensure initial schedule is marked Rev. 0 Done.

3 Suggested improvement - provide summary of safety analysis and industry OE used in op test development (Required by ES-301 D.1.f.) Memorandum of Exam Methodology attached.

4 Add an 'A' to D-1 "Event Type" to specify facility identified "Abnormal Event." This item was added.

5 ES-301-5 "Transient and Event Checklist" - Did not include RO bean counts for Scenario 3. Please revise. ES-301-5 Revised to reflect expected event count based on the proposed exam week schedule.

6 ES-301 Scenario 4 is identified as the "Back-up". Back-up scenario will be identified during validation week. ES-301-5 Revised to reflect expected event count based on the proposed exam week schedule.

7 8 9 Note 1: Critical tasks were standardized (as a result of the 2009 INPO CPO) by GGNS procedure 14-S-02-21, Preparers Guide for Simulator Evaluation Scenarios. Critical tasks have been updated to reflect the specific criteria as defined in 14-S-02-21.