ML081190701

NRC Comments to the Proposed Operating Test for the Fermi Initial Exam - January 2008

ML081190701
Person / Time
Site:	Fermi
Issue date:	03/25/2008
From:	Hironori Peterson Operations Branch III
To:	Davis J M Detroit Edison
Shared Package
ML080860174	List: ML081190547 ML081190699 ML081190701 ML081190704 ML081190707 ML081200422 ML081200435 ML081200448 ML081200455
References
50-341/08-301
Download: ML081190701 (4)

Text

NRC COMMENTS TO THE PROPOSED OPERATING TEST FOR THE FERMI INITIAL EXAM - JANUARY 2008 Operating Test Comments rdmin JPMs (ES-301-1):

Comment (-1) ADMlN 1. EC I HPCl Surveillance Procedure

/ ro,sro (Generic 2.2.12): 1) JPM does not match referenced KA ('2.2.12 Knowledge of Surveillance procedures")

because it only requires knowledge of location of HPCl System control room indications.

(-1) ADMlN 2. CO1 /Core Thermal Limit Verification

/ ro,sro (Generic 2.1.7): 1) JPM Steps 4 and 5 are not critical.

If applicant does not place a "check" in the box, or identify the correct date and time it is only an errata type problem. There is no safety significance associated with the mistake.

2) Only one critical step for RO. Need at least one more RO critical item (ie. JPM Steps 1, 2, or 3?) or replace JPM. ADMlN 3. RC / Dose Limit / ro (Generic 2.3.4): 1) Wording of KA Generic 2.3.4 is from NUREG 1123, Revision 2. NUREG 1123, Revision 2. Supplement Final, has slightly different wording for the KA. 2) The following JPM Steps are not critical:

Step 3 (applicant doesn't have to use procedure, and is being given copy of form); Step 4 (applicant's name and SSN); Step 6, examiner will cue the applicant with correct answer; Steps 7 and 8 are not critical (signatures are errata). There is no safety significance associated with anv of these stem. ADMlN 4. C02 / Complete NPTD Form / ro (Generic 2.4.39): 1) On Form ES-301.1, this JPM is listed as Conduct of Operations, but it should be under Emergency Plan because KA Generics for Section 2.4 is Emergency Procedures

/ Plan; Generics Section 2.1. Move this JPM to Emergency Plan on RO Form ES-301-1.

2) JPM Step 6 is not critical (ED signature is errata, not safety signifcant)

3) JPM Step 3, will the meteorological data be the same for all applicants (ie. is it actual data that may change depending on current conditions?).

4) 5) JPM Steps 7-9, why are these at discretion of the examiner?

Title says '...complete and communicate

..." Make steps part of JPM. 5) Is this JPM time critical? Task Standard mentions 30 minutes. 6) Provide an answer KEY with the examiner's JPM. Resolution

1) KA changed to 2.2.14 which matches the JPM as written. 1) Steps 4 and 5 are not critical 2) Identified the following steps as critical for the RO: -identify MAPRAT greater than 1 and inform CRS; -applicant does not initial acceptance criteria (ie. indicates understanding that surveillance is not SAT). 1) Verified and corrected KA wording 2) Steps 3,4,6, 7, and 8 are not critical.

1) Moved this JPM to the Emergency Procedures

/ Plan section of ES-301-1. 2) JPM steps 1 and 6 are not critical 3) Meteorological data comes from the simulator computer, so it will be same for all applicants.

4) JPM steps 7-9 are part of the JPM and identified as critical.

5) No, procedure is not critical, procedure says "should." 6) Key will be provided to examiner.

Page 1 of 3 Operating Test Comments (-1) ADMlN 6. RC / Dose Limit and Extension I sro (Generic 2.3.4): 1) KA Generic 2.3.4 wording on SRO Form ES-301-1 does not match KA wording on ADMIN 6 JPM. Make KA wording for the RO and SRO Forms ES-301-1, ADMlN 3, and ADMlN 6 consistent with NUREG 1123, Revision 2, Supplement Final, Generic 2.3.4. 2) Don't give area dose rate in the Initial Cue because it is a critical step, should be determined from the survey. Also, Smith's accumulated dose is given in the Initial Cue, so it does not have to be given again by the examiner.

3) "Obtain Procedure MRP 12 and form MRP12001 is considered a critical step, so it cannot be provided until the applicant determines which procedure is needed and locates a copy. 4) The following JPM Steps are not critical: Step 3 (applicant doesn't have to use procedure, and is being given copy of form); Step 4 (applicant's name and SSN); Steps 7 - 10 are not critical (signatures are errata, and are identified on the form, there is no safety significance associated with anv of these stem). ADMlN 7. EP / PARS and Classification

/ sro (Generic 2.4.40): 1) JPM is time critical.

2) Have "restricted procedure" available for exam, need to control. 3) Redact JPM from ADAMS? ystem JPMs (ES-301-2):

Comment JPM b. Refuel Floor High Rad (P,D,A,L,S):

1) Since multiple procedural steps are referenced in this JPM, denote the applicable procedure number with each of the JPM steps.

JPM c. Manuallyhlnltiate SRV LLS (D,S): 1) Remove the 4 bullet of the Initial Conditions and incorporate into the Initiating Cue. JPM f. Multiple Rod Drifts (D,A,S): 1) JPM Step 7 is not critical because placing the RMS will not cause a plant scram. As a result, the JPM only has one critical step. (-1) JPM i. Restore SDC (N,EN,A,S):

1) SRO-U Form ES-301-2 and JPM list multiple KAs, select onlv A4.05 (3 'A4s" are listed). JPM 1. Defeat ARI Logic Trips (D,R,E): 1) Add KAs 295037 to Form ES-301-1, and 216000 to JPM. 1) KA wording corrected.

2) Will remove dose cue from Initiating Cue 3) Intent was for applicant to identify and locate necessary procedures

/forms. Will clarify in JPM 4) JPM steps 4, and 7-10 are not critical.

1) JPM is time critical.

2) Will have restricted procedure available for exam 3) NRC redact JPM from ADAMS. Resolution

1) This technique is currently being incorporated into the licensee's program. 1) Moved bullet to Initiating Cue. 1) Additional critical step is to recognize multiple rod drifts; and depressing RPS Manual Scram PES.

1) Only referenced one KA on ES-301-2 and JPM. 1) KAs 295037 added to Form ES-301-1, and 216000 to JPM. Page 2 of 3 Operating Test Comments JPM I. Shift IAS Dryers (D,R,E): 1) Move the last 4 bullets of the Initiating Cue to the Initial Conditions.

1) Last 4 bullets of the Initiating Cue moved to Initial Conditions.

cenarios:

Comment SCENARIO 1: (-1) Event 7 -is SBFW required for RWL restoration?

If not, what is the significance if it is not started? If no significance, can't use as an event. SCENARIO 2: Event 3 -include East Condenser Alr Leak, label it as "M (All)" SCENARIO 3: SCENARIO 4 (spare): (-1) Event 2 -not an instrument failure "I 6ROY for SRO. but is a TS. Resolution -Delete credit for SBFW 'C -Incornorated comment on D-I sheet. -Deleted loss of RWL indication as an "1(1 failure Page 3 of 3