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