ML081200366

Waterford, Unit 3 - 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

Attachment X OBDI 202 - ILE Process DRAFT Outline Comments Facility: W3 First Exam Date:March 24, 2008

Written Exam Outline January 10, 2008 Comment W3 Response 1 Four Tier 1 KA's were selected (SRO-1/RO-3) were selected from the generic EPE and APE's. It is not clear whether the outline generation software included technology specific EPE's and APE's in the sample.

Technology-specific EPEs and APEs are included in the sample. The issue with them not being as obvious is that in Tier 1 Group 1, all of the technology specific EPEs for CE facilities are combined topics with generic 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 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.

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

combined topics. 9 RO items are required for 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.

3 It is not clear whether the outline generation software included all appropriate items in each group (Tiers 1 & 2) since only those selected were included in the outline. This makes the outline not scrutable as required by ES-

401, D.1.b. Our software generates a log file that writes data directly from the outline generator as an outline is produced. We can save that file in RTF format to allow for audits. One of the first items in the log file is a counted list of topics available for outline generation. This

feature was recently added to our random Attachment X OBDI 202 - ILE Process generator. I do have a log file for W3's 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.

4 The Written Exam Outline Methodology states "Outline is generated for all topics with KA importance greater than or equal to 2.5." However, ES-401, Attachment 2 states a KA with a less than 2.5 importance rating can be kept if there is a site-specific priority. Have all screened

KA's been reviewed to determine whether a site-specific priority exists that justifies keeping it in the sample?

Provide a list of pre-screened out KA's with indication that they have been reviewed against site-specific priorities. Facility indicated there was no pre-screened list of KAs with importance less than 2.5 that should be included in the generation process. Therefore, all KAs with values below 2.5 were excluded, with the exception of Generic 2.4.30 for RO, which must be included in the selection process in accordance with ES-401, , and only rejected with justification. (This was the case for an item on the W3 exam)

Waterford 3 reviewed KA catalog and determined that screening KAs with less than

2.5 importance

value would not preclude adequately examining plant specific priorities.

5 ES-401-4 states the original KA selected for SRO Q87 (012 A2.02) overlapped with RO Q48. However, RO Q48 KA is 029 EK2.06. Overlap? My notes said that the original KA would be difficult to develop without overlap given the number of items on the audit and NRC 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 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.

6 CR WF3-2006-3510 was generated as a result of the 2006 NRC exam. Has this WF3-CR-2006 -3510 summary report sent to

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 1 Are all JPMs unique? If so, number RO JPMs A1-A4 and SRO JPMs A5-A9. JPMs are unique, will number per Chief

examiner preference.

2 When submitting the JPMs, send a copy

of the existing Bank JPM for those classified as Modified so I can review the level of modification. Will submit original JPMs to Chief examiner for JPMs listed as modified.

3 For RO / Equipment Control - is this JPM different than the one on the 2004 NRC exam? Yes this JPM is for a different component.

4 For SRO / Equipment Control - the listed KA is 2.3.1 (Radiation Control)? If the KA is supposed to be 2.2.13, is this JPM different than the one on the 2004 NRC exam? Yes this JPM is a different task on a different

component.

5 For SRO / Conduct of Operations, KA 2.1.25: is this to calculate the SD Margin or REVIEW an already completed calculation? What is the SRO level of knowledge at W3? The SRO is calculating the SDM to verify and

will have to make a TS call for emergency boration. 6 For SRO / Conduct of Operations, KA 2.1.2: the Importance Rating is listed as 4.4 but should be 4.0. Will correct and submit revision to Chief examiner. 7 For SRO / Radiation Control JPM - was

this JPM randomly selected? Yes, this JPM was randomly selected.

Control Room / In-Plant System JPM Outline January 15, 2008 Comment W3 Response 1 Unless you have a strong feeling otherwise, my preference is to number the JPMs as S1-S8 and in-plants P1-P3.

(SRO-I don't 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. will designate JPMs per Chief examiner

preference.

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

S7; SIAS verifications are steps that are Attachment X OBDI 202 - ILE Process different). Same is true for S7 - SIAS automatic actions are likely to be verified in one of the scenarios (unless the alternate path aspect makes it significantly different.) normally completed at procedure steps farther than scenarios normally run to, additionally the alternate paths events are different than events in the scenarios.

3 For the 003-Start Reactor Coolant Pump JPM - was this JPM randomly selected?

This JPM was randomly selected.

Simulator Scenario Outline Comments January 15, 2008 Comment W3 Response 1 Form ES-301-5 is not completed correctly for submitted schedule - wrong crew positions for SRO-I1 and I3. Also, can combine U1 and U2 on one line and RO 1,2,4 on one line. WF3 will resolve ES-301-5 forms and schedule and submit revision to Chief

examiner.

2 Scenarios 1, 2, 3 have too many repeat events from the 2004 and 2006 NRC

exams. Per discussion with Chief Examiner; Scenario 1 is acceptable. Scenario 2,3, and 4 have been revised per discussion. See attached. All scenario ES-D1 forms submitted as outline submittal rev 2 for ease of use.

3 Scenario 4 is low power but does not contain events that affect the low power. Consider events such as inadvertent start of Steam Driven AFW pump or inadvertent opening of steam dumps. Per discussion with Chief Examiner Event 2 revised to inadvertent dilution at low power See attached.