ML13169A434
| ML13169A434 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/15/2013 |
| From: | NRC/RGN-III |
| To: | Exelon Generation Co |
| Zoia, C. | |
| Shared Package | |
| ML11354A318 | List: |
| References | |
| Download: ML13169A434 (11) | |
Text
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response OPERATING TEST Operating Test JPMs RO Admin JPMs RO #1 (R-120) a) Step #2 should have acceptance criteria a) Verified the range was acceptable at of +/- 10 psig. A range of 2225-2300 psig the Onsite Validation (OV).
in not acceptable. We want to know if the guy can read the gauge accurately.
b) Step #5 I think the examinee will b) The typo was corrected (should be determine that containment water level inches instead of percent).
differs by 7.2 inches not by 7.2%.
Need to change the units.
c) Might want to add a correctly filled out c) Verified acceptable at the OV.
data sheet to the examiners portion of the package.
d) How has this been (M)odified from the d) Added scope to original JPM original Bank question? Please provide (Containment water level).
original bank question.
RO #2 (R-104) a) Unable to verify this JPM is accurate. I a) Verified acceptable at the OV.
could not find BwCB-1 fig. 2, fig 17A, table 2-1, or table 4-1. Need to verify that the range of values is acceptable.
In step #3, I think that a 0-25 pcm range for the remaining rod worth is pretty wide, based on my memory of that graph. Also, if the applicants use data from tables there shouldnt be any range on these values. They either pick the right value or they dont.
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NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response b) Whatever the determined + or - b) Ranges found acceptable at the OV.
values from step #3 are, these values should be correctly carried forward for the allowable value ranges given in the steps going forward. (Bank question has incorrect values for the subsequent steps.)
RO #4 (R-402) a) Step #5 - Not sure why we would a) Answered at the OV. SAT provide the Outside Phone Number, shouldnt they know it??? Applicant should find the required phone number in the ERF Telephone Directory.
b) How has this been (M)odified from the b) Verified differences at the OV.
original Bank question? Please provide original bank question.
SRO Admin JPMs SRO #1 (S-111a) a) I think we need another mistake on the a) Verified acceptable at the OV.
reactivity change determination form. I suggest circling Unit 2 instead. If applicants dont realize the error they need to be able to find something else wrong. They will continue looking if they cant find anything wrong.
SRO #2 (S-107) a) I dont think step #2 is a critical step. a) Agreed. Made step 2 NOT critical.
This step just transfers data provided in the cue to the procedure.
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NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response SRO #3 (S-205) a) Step #8 - The cue for the examiner a) Verified acceptable at the OV.
limits the applicants response to just b) Added parenthetic description to the the first action requirement of the LCO standard.
Condition, which is less discriminating.
b) Also, the STANDARD is incorrect; it should be 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the RO stopped work 30+ minutes ago.
SRO #4 (S-302) a) If step #3 is the critical step put what the a) Step 3 is now critical release window results are in step #3.
Or you could make step #5 the critical step.
SRO #5 (S-409) a) This JPM appears to have a very low a) It is critical to brief the volunteer on all level of difficulty. Is the critical step on three bulleted items.
step #4 to brief the volunteer on all Examiners will sign for the emergency three bulleted items? Also, will the worker and radiation protection examiners sign for the emergency manager when requested.
worker and radiation protection manager when signatures are requested?
b) The initiating cue , (2.) should read . . . b) Corrected the cue.
completed authorization for rescue of . .
Simulator JPMs Sim JPM a (SIM-102) a) How is this JPM significantly different a) SIM-111 was alternate path, and SIM-from the required actions of Sim-111, 102 is not.
other than using a different shutdown bank? (Sim-111 was on the 2009 NRC Exam.)
Sim JPM b (SIM-223) a) Is this an alternate path JPM? Should a) Yes - Alternate Path. No DEQUIP log 3 of 11
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response we have them enter 1SI8806 into the is needed for this JPM.
DEQUIP Log???
b) If the procedure tells the applicant to b) The cue originally allowed for the perform an OPEN and CLOSED stroke examiner to address an errant test of the valve (F3.2), and Step #4 is operation of the stop watch. Changed Critical, why would we Cue the cues at the OV to eliminate this applicant to perform Step #4? concern.
Sim JPM c (SIM-305A) a) This JPM should have a step #7 to re- a) Manual control of the Master Pzr take manual control of the Master Pzr Pressure Controller is part of step #6.
Pressure Controller. That is really the The critical step begins after step 5 -
critical step for the alternate path. Step agreed.
- 6 is critical because you have to If the pressure drops below 2185 psig, recognize that the controller doesnt the applicant fails the JPM.
work in AUTO before you can take manual control to correct/respond to the failure. Actually, the alternate path does not really begin until Step #6 (not Step
- 5) when the applicant places 1PK-455A back in AUTO. Also, if pressure drop below 2209 does the applicant fail the JPM?
b) How has this been (M)odified from the b) The original bank JPM had a different original Bank question? Please provide fault.
original bank question.
Sim JPM d (SIM-305A) a) Low level of difficulty, but probably a) Determined to be acceptable as-is at acceptable. the OV.
b) What is the status (position) of the b) The REMOTE/ LOCAL switch on REMOTE/ LOCAL switch on 1PL04J for 1PL04J is in REMOTE per step #4, 1A SX pump? Will this pump start using and it will start the 1A SX pump.
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NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response only the C/S from the MCR?
Sim JPM e (SIM-508) a) Low level of difficulty, but probably a) Determined to be acceptable as-is at acceptable. the OV.
b) Why are 1A & 1C RCFCs still running in b) This was due to a relay failure.
fast speed? What makes this Alt Path?
Sim JPM f (SIM-601) a) Why is Initiating Cue (2) provided? If a) Initiating Cue (2) is provided to limit cue is provided, why is Step #2 scope. Step #2 was deleted.
considered optional? Actually, if the Step is performed a comment would be required.
b) Is it realistic for one RO to parallel the b) Determined to be acceptable as DG to the SAT and then have another submitted at the OV.
unload the DG? This would be more discriminating if the applicant was required to unload and secure the DG after paralleling with the SAT.
Sim JPM g (SIM-707) a) Again, low level of difficulty; a) Determined to be acceptable at the acceptable? OV.
Sim JPM h (SIM-805) a) We need to include BwOP VQ-6. They a) Agree - will provide BwOP VQ-6.
will need it to perform release.
In Plant JPMs In Plant JPM I (IP-204) a) This JPM would be better if we could a) No spare breaker was available. We open up a spare breaker on MCC will provide a readable picture.
132X4 and not have to use the picture.
b) Need to decide: Outline says open b) There was a typo on the outline. The 2CV112E and the JPM paperwork says JPM paperwork was correct.
1CV112E.
In Plant JPM j (IP-406) a) No Comments. a) N/A In Plant JPM k (IP-804) a) We should not provide BwOP CO-5T2 a) Changed cue for providing BwOP CO-5 of 11
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response until it is asked for. This attachment is 5T2.
referenced in the note prior to step one The originally proposed location was of the procedure. The applicant may determined to be acceptable at the not read this note so we shouldnt just OV. Therefore, we did not determine provide the info. Also we should it was necessary to use the Lower change the location of the fire to the Cable Spreading Room.
Lower Cable Spreading Room (LCSR).
This will require the applicants to really use the procedures and not just get lucky if they go to the 2B AF Pp Room to find the actuation pushbuttons.
Expect pushback to this idea because it makes the JPM more difficult.
Operating Test Scenarios Scenario 1 Event #3 On Page 6 Event #3 doesnt list all Tech Specs No changes were required because the that are specified for the failure of 1C SG NR information was provided on page 12 (page 5 level channel. Must enter Tech Specs. 3.3.1 provided a brief overview, whereas page 12 Cond. A & E for function 14.a for SG level provided a detailed event description).
channels. 4 channels are required to be operable. Must enter Tech Spec 3.3.2 Cond.
A & D for function 6.b.1 also. (This is inconsistent with the write-up for Event #2 on Page 5, but should be OK.) These are listed on page 12 of sim guide.
Event #4 If 1CV-121 fails closed seal injection flows may Agreed - this possibility was noted on the go to zero. If they go outside seal injection detailed event description (p. 14).
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NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response flow limits the applicants must enter Tech Spec 3.5.5 Cond A and restore within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
(Another TS call for US? OK.)
Major Need to find out if the station expectation is to It was not the expectation for this major event isolate AF during step 15 of E-0 or not. It is (ruptured/faulted SG).
currently an open bullet meaning either way is right. The station should have an expectation on how crews will handle AF during faulted and ruptured SG.
Major At the end of the scenario I would recommend Considered continuing scenario during the going until the cooldown step of CA-3.1 it a OV and determined not to be necessary.
little bit further in the procedure but it will give The option is available to continue during the us a much better feeling on how well they exam if crew responses indicate that more know this CA if we go further. It will depend on information is required for evaluation.
time going three or four more steps could take several minutes or 10 minutes.
Would this scenario be more discriminating if The scenario was determined to be adequate the SG PORV failure/ruptured SG/faulted SG at the OV. Rods were left in manual to did not all occur on the B SG? Also, why is necessitate observable action by the crew.
one of the initial conditions that a summing amp failure has occurred requiring the Rod Control to remain in Manual?
Scenario 2 Event #6 Page 15 - Is step 4 of E-0 open bullets or Step 4 of E-0 has open bullets.
closed bullets??? Im used to these being closed bullets.
Event #6 Page 19 - Step 15 of E-0, is the station There is no station expectation to throttle AF expectation to throttle AF flow at this step or at flow at step 15.
a later step???
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NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response Page 20 - RCS temp control Step, is the The only requirement was from procedure station expectation to throttle AF flow at this CA-2.1.
step or at an earlier or later step???
Event #7 Our steam leak is big enough to get Cnmt > 20 During the OV, the plant did not cool down psig so why dont we expect to transition to that far. During the exam, evaluating the BwFR- P.1 based on cold leg temps < crews actions to stabilize the plant may 240F??? We shouldnt stop the scenario until require continuing the scenario beyond the they determine how they are going to stabilize point where the validating crew was stopped.
the plant. Probably will need to soak RCS for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to any cooldown.
What actually caused the 1A & 1D MSIVs to The cause was not stated and was not an go closed and what is the purpose of allowing issue at the OV. The MSIVs closure this to happen? provided another evaluation opportunity.
Scenario 3 Event #5 The leak into the CC system from the 1A LD Agreed - this was added to the detailed Hx should exceed the leakage limits event description (p.16).
associated with Tech Spec 3.4.13, therefore this Tech Spec should be entered not evaluated. Change page 18 to add the Tech Spec entry being required.
Event #7 The dropped rod requires that a shutdown A shutdown margin calculation was not margin calculation be completed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. performed in the time allotted at the OV. The There is a JPM to perform a shutdown margin single dropped rod and corresponding load calc. Not sure this meets the requirement on drop provided a diverse reactivity page 13 of ES-301 which reads The selected manipulation opportunity for evaluation.
tasks are in addition to and shall be different from the events and evolutions conducted during the simulator operating test. We could probably drop the next rod before anybody 8 of 11
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response starts working on this surv though. (Especially since Event #7 is not needed for a reactivity manipulation.)
Consider allowing this scenario going to the Built in this option to the scenario guide.
second depressurization because that should be where the leak is finally stopped.
Why is Critical Task #4 not also a critical task In Scenario 3, neither AFW pump starts.
for Scenario 1?
Scenario 4 Event #3 Page 11 - Only list which Tech Specs need to Deleted TS 3.3.3 and 3.3.4 non-TS entries.
be entered. Do not need to see which ones should be considered. Delete TS 3.3.3 and 3.3.4.
Event #4 What is the temp limit on re-establishing The expectation would be to call Chemistry Normal LD. That is, above what temp would prior to re-establishing Normal LD.
the station consider it to be unacceptable to re-establish Normal LD??? If temp only gets to 135F then I would expect the correct thing to do would be to re-establish Normal LD.
However, if temps get to high when would it be incorrect to re-establish Normal LD???
Event #7 Page 18 - The CT is to manually actuate SI Need to actuate from one to meet the critical from 1PM05J or 1PM06J but it should be task, but if an applicant only actuates one manually actuate SI from 1PM05J and switch, that would be a competency issue.
1PM06J which reflects the correct Clarified at OV.
procedurally directed action.
Spare Scenario Event #4 Page 13 - The scenario should specify which TS LCO 3.7.10 applies and TS LCO 3.7.11 Tech Specs are required to be entered. may apply (support TS). These are listed on 9 of 11
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response Without the Supply Fan, I would enter both page 13. While it would not be incorrect to 3.7.10 & 3.7.11. They need to tell us which enter TS 3.7.11, per TS 3.0.6 it is not ones to enter. Not May enter LCO 3.7.11 it required to enter both. This was adequately either needs to be entered or it needs to be described in the event description as-is.
removed.
Event #5 Page 18 - Does Tech Spec 3.5.5 also need to Yes, Tech Spec 3.5.5 also needs to be be entered for the loss of seal injection??? entered for the loss of seal injection.
Certification Exam Review
- 1) The cert exam has an EP JPM similar to The Certification Exam was prepared one of the NRC exam JPMs. The cert independently from the NRC exam, and was exam JPM has the SRO applicants fill verified to be adequately different, with some out and transmit a NARS form. The similarities noted. The only overlap which NRC exam has the RO applicant required corrective action was determined to transmit a NARS form via a land line. A be NRC RO Exam question 71, which initially little different but not much. There is was an exact match of a previous NRC exam also a RO JPM on the cert exam to question. The current NRC exam question transmit a NARS form. was modified to resolve this concern (Refer
- 2) The cert exam has a JPM to calculate to Form ES-401-9 for further details). All QPTR and the NRC exam has a JPM remaining similarities were considered for an SRO to review a QPTR calc. adequately different and satisfactory as-is at This may be ok if only ROs had to the OV.
perform the calc on the cert and only SROs have to perform the calc review on the NRC exam. Should probably ask if that was the case.
- 3) The cert exam has a JPM to perform a reactivity calculation. The NRC exam has SROs review/approve a reactivity 10 of 11
NRC Operating Test Comments & Resolutions Braidwood Station Exam Start Date 03/25/2013 Operating Test 2013-301 ITEM Comment Facility Action/Response calculation. Need to make sure that ROs had to do this on the cert exam and SROs have to do this on the NRC exam.
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