ML19238A333
| ML19238A333 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/23/2019 |
| From: | Joseph Demarshall AmerGen Energy Co |
| To: | NRC/RGN-III/DRS/OLB |
| Demarshall J | |
| Shared Package | |
| ML17164A361 | List: |
| References | |
| Download: ML19238A333 (24) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Exam Date: August 27 - September 7, 2018 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
RO-A1.1 Conduct of Operations G2.1.20 Prepare a Request to Alter the CX/CZ Database 2
S RO-A1.2 Conduct of Operations G2.1.19 Perform CPS 9820.01 Core Thermal Limits 3
X S
NRC: Provide answer key for CPS 9820.01D001.
Response: Answer key added.
RO-A2 Equipment Control G2.2.37 Complete CPS 3506.01C005 Diesel Generator Start Log 3
S RO-A3 Radiation Control G2.3.13 RT Pump Shutdown 1
2 U
S NRC:
(1) LOD=1. As written, JPM is a direct lookup.
Applicant is required to determine the highest dose rate that will be encountered when isolating and venting the idle RWCU Pump. Dose rates for individual RWCU valves are provided on Survey Maps given to the applicant. The highest dose rate is read directly from Survey Map RP-1137-04.
(2) Step 1 (Critical Step) performance standard states:
Examinee chooses correct survey maps:
RP-1126-04 (Aux Building - 737 El Reactor Water Cleanup Pump B)
- and, RP-1137-04 (Aux Building - 750 El RT Mezzanine)
As scripted, there does not appear to be a critical element associated with the selection of Survey
ES-301 Operating Test Review Worksheet Form ES-301-7 Map RP-1126-04. If RP-1126-04 were inadvertently omitted from the materials provided, applicants would still be able to successfully complete the JPM because the highest dose rate can only be obtained from RP-1137-04.
Accordingly, only the selection of Survey Map RP-1137-04 should be designated as critical.
(3) Suggest modifying the JPM to have the applicants perform a total dose calculation for (a) the entire task (i.e., all of Section 8.1.4.4 to isolate and vent the pump), or (b) manual operation of a valve inside containment that would require interpretation of multiple survey maps to account for dose received not only at the valve, but also during transit to and from the valve, depending on the route taken (if applicable).
Response
Modified the JPM as follows:
Changed the initiating cue for the examinee to determine total dose for two field operators performing RT pump isolation and venting activities, making Survey Map RP-1126-04 a critical aspect of the JPM.
Changed critical tasks to 1) performing total dose calculations, and 2) determining margin to the annual admin dose limit for operator #1. Revised JPM SAT.
SRO-A1.1 Conduct of Operations G2.1.34 Evaluate Plant Chemistry 3
S
ES-301 Operating Test Review Worksheet Form ES-301-7 SRO-A1.2 Conduct of Operations G2.1.5 Determine Minimum Crew Complement 3
S SRO-A2 Equipment Control G2.2.12 Review CPS 9071.01 Diesel Driven Fire Pumps Operability Test 3
S SRO-A3 Radiation Control G2.3.15 Review CPS 9038.70 Radiation Monitoring Source Check Surveillance 3
S SRO-A4 Emergency Procedures/Plan G2.4.30 Determine Reporting Requirements 3
U S
NRC: JPM does not test / evaluate the applicants knowledge of the facilitys Emergency Plan. JPM only requires the applicant to determine Tech Spec actions and reportability requirements associated with inoperability of the HPCS system. K/A G2.4.30 is linked to CFR 45.11, which states:
Demonstrate knowledge of the emergency plan for the facility, including, as appropriate, the operators or senior operators responsibility to decide whether the plan should be executed and the duties under the plan assigned.
Reference NUREG-1021, ES-301, Section D.3.d discussion on Emergency Plan (Page 12 of 33),
and Section B.1 discussion on the Emergency Plan (Page 3 of 33). Section B.1 provides examples of the types of information that could be evaluated under the Emergency Plan topic.
K/A G2.4.30 has direct applicability to the Emergency Director function during execution of the Emergency Plan.
ES-301 Operating Test Review Worksheet Form ES-301-7 Response: Replaced with new A4 JPM476; Classify an Emergency Event and Determine PARS. New JPM SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 1
Simulator/In-Plant Safety Function and K/A JPMs S1 (jpm a)
Transfer RR to Slow with Trip of One Pump (Alternate Path)
SF1 202001 A2.03 3
E S
NRC: Performance standards have been specified in the JPM, however, the individual procedure steps / numbers that correspond to these performance standards have not been provided. Instead, the JPM identifies sections /
portions of the procedure (by number or description in the ELEMENT column).
Accordingly, critical step asterisks have been assigned to sections / portions of the procedure, rather than to individual steps within the procedure. As written, all performance standard items within a section / portion of the procedure denoted with an asterisk, are assumed to be critical step items, given that no differentiation has been made between what is critical and non-critical.
Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
NOTE: In addition to JPM S1, comment applies to CR Systems JPMs S2, S3, S4, S5, S7, and S8.
Response: Added procedure step numbers to the performance standard as requested.
S2 ( jpm b)
MDRFP Shutdown SF2 259001 A4.01 2
E S
NRC: Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical
ES-301 Operating Test Review Worksheet Form ES-301-7 steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
Response: Added step numbers as requested.
JPM steps 1-4 are all critical in their entirety; bolded all actions in steps 1-4 performance standards.
S3 ( jpm c)
Main Turbine Control Valve Tests SF3 241000 A1.08 3
E S
NRC:
(1) Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
(2) Suggest testing only the first two CVs (i.e.,
CV-1 and CV-2) to cut the performance time of the JPM in half. Steps associated with testing the first two CVs will be sufficient to evaluate the applicants performance on this JPM, given that the remaining steps are essentially the same.
Response
Added step numbers as requested.
Added evaluator note that the JPM can be terminated after step 4 and remaining steps N/Ad.
S4 (jpm d)
Restore RPV Water Level Using Low Pressure ECCS (Alternate Path)
SF4 209001 A4.01 3
E S
NRC: Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
ES-301 Operating Test Review Worksheet Form ES-301-7 Response: Added step numbers as requested.
Bolded critical performance standards.
S5 (jpm e)
CNMT Pool Makeup From Suppression Pool SF5 223001 G2.1.23 3
E S
NRC: Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
Response: Added step numbers as requested.
Bolded critical performance standards.
S6 (jpm f)
Energize 4160V Bus (Alternate Path)
SF6 262001 A4.01 3
U S
NRC: Critical Steps 7, 10, and 13 do not contain verifiable actions. NUREG-1021, ES-301,, Verifiable Action Guidelines, second paragraph states:
Section D.5.d of this examination standard specifies that an applicant should only be given credit for those scenario events that require the applicant to perform verifiable actions that provide insight to the applicants competence. This means that the applicant must perform some action, not just make a telephone call to an operator to take some action in the field. An applicant on the telephone directing an operator to take some action in the field while he or she is observing control room indications is NOT performing a verifiable action; instead, the applicant is directing. Although it may provide insight as to whether the applicant understands the system, it does not provide insight for the examiner to be able to determine whether the applicant is capable of actually operating the equipment/equipment controls and controlling the system response.
JPM will either have to be replaced or modified.
One possible option may involve use of the italicized information in Step 4.2.4 of CPS 4200.01, which states:
If DG fails to start due to active trip signals, a manually initiated LOCA signal should be
ES-301 Operating Test Review Worksheet Form ES-301-7 considered which will bypass most DG trip signals.
Response: Revised the JPM to make manually initiating Div 2 LPCI logic the verifiable action that results in the re-energization of the bus. Revised JPM SAT.
S7 (jpm g)
Perform RPS MSIV Channel Functional (Alternate Path)
SF7 212000 A4.02 3
E S
NRC:
(1) Specify procedure step numbers associated with the performance standards identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
(2) Why is the Examiner providing cues that: (a) computer point B21NC047 indicates tripped and reset in Step 1 of the JPM, and (b) computer point B21NC048 indicates tripped in Step 2 of the JPM? As scripted, the applicant is tasked with observing that computer point B21NC048 does NOT indicate reset in Step 2, the determination of which helps the applicant to confirm that he / she has to respond to the inadvertent MSIV closure. Further, the Initiating Cue states that an operator is stationed to provide computer point status as required. Will the applicant be conditioned to rely on either the examiner or the other operator to provide this critical piece of information, when he / she should actually be the one making this determination?
Response
Cues are provided by the evaluator because the examinee will be holding the MSIV Close Test pushbutton and unable to monitor computer points on a remote computer monitor.
Added step numbers as requested Reformatted JPM table to make evaluating each step easier.
S8 (jpm h)
SF9 288000 A4.01 3
E S
NRC: Specify procedure step numbers associated with the performance standards
ES-301 Operating Test Review Worksheet Form ES-301-7 Startup CCP in Filtered Mode identified in the JPM (see convention utilized on the 2017 NRC Exam; JPM 530). As written, the JPM is a compilation of in-series performance standard items.
If applicable, assign critical step asterisks to individual procedure steps (i.e., when the section
/ portion of the procedure denoted with an asterisk contains both critical and non-critical steps) to differentiate between those that are critical and those that are not.
(See comment in line item S1 above).
Separately, Step 2 of the JPM states:
Examinee opens 1VQ003 and then verifies the Red light ON and the Green light OFF.
Evaluator Note - This step is critical only if 1VQ003 was closed in step 8.1.3.1.2.
Examinee opens 1HS-VR204 and 1HS-VR205 and then verifies the Red light ON and the Green light OFF for 1VR036, 1VR041, 1VR035, and 1VR040.
Evaluator Note - This step is critical only if 1HS-VR204 and 1HS-VR205 were taken to close in step 8.1.3.1.3.
Step 1 of the JPM has been scripted such that these two items are critical steps.
There is no information included in the JPM that would indicate otherwise. Accordingly, is there reason to believe that the applicants will deviate from the script such that the bulleted items referenced above will not be critical steps? Clarification required. Also, while the information pertaining to steps 8.1.3.1.2 and 8.1.3.1.3 of CPS 3408.01 has been provided in Step 1 of the JPM, the associated step numbers have not. As written, the JPM is not user friendly in this regard; goes directly to the point made in prior comments regarding the need to specify the individual procedure step numbers for associated performance standard items.
Response: The portion of step 1 that is critical is placing the joystick in the center position.
ES-301 Operating Test Review Worksheet Form ES-301-7 Closing 1VQ003, 1HS-VR204, and 1HS-VR205 is not critical since they will be re-opened in JPM Step 2. If closed in step 1, reopening them in step 2 becomes critical.
Added step numbers to JPM performance standards.
P1 (jpm i)
RSP - Div 2 LPCI Operation SF7 295016 A1.07 3
S P2 (jpm j)
Manual and Redundant Initiation of the DG Rooms CO2 System (Alternate Path)
SF8 286000 A2.08 3
S P3 (jpm k)
Startup the Fuel Building HVAC VF System to Support Emergency Containment Venting SF9 288000 A2.03 3
E S
NRC: The start of Supply Fan 1VF03CA (when Fuel Building Average Pressure reaches -0.5 H2O), is performed at Step 8.1.8.2 of CPS 3404.01. The JPM is scripted such that both the Supply (1VF03CA) and Exhaust (1VF04CA) Fans are started at Step 8.1.8.1. Revise accordingly.
Response: Added 8.1.8.1 and 8.1.8.2 for the start of the supply and exhaust fans.
ES-301 11 Form ES-301-7 Instructions for Completing This Table:
Check or mark any item(s) requiring a comment and explain the issue in the space provided using the guide below.
- 1.
Check each JPM for appropriate administrative topic requirements (COO, EC, Rad, and EP) or safety function requirements and corresponding K/A. Mark in column 1.
(ES-301, D.3 and D.4)
- 2.
Determine the level of difficulty (LOD) using an established 1-5 rating scale. Levels 1 and 5 represent an inappropriate (low or high) discriminatory level for the license that is being tested. Mark in column 2 (Appendix D, C.1.f)
- 3.
In column 3, Attributes, check the appropriate box when an attribute is not met:
The initial conditions and/or initiating cue is clear to ensure the operator understands the task and how to begin. (Appendix C, B.4)
The JPM contains appropriate cues that clearly indicate when they should be provided to the examinee. Cues are objective and not leading. (Appendix C, D.1)
All critical steps (elements) are properly identified.
The scope of the task is not too narrow (N) or too broad (B).
Excessive overlap does not occur with other parts of the operating test or written examination. (ES-301, D.1.a, and ES-301, D.2.a)
The task performance standard clearly describes the expected outcome (i.e., end state). Each performance step identifies a standard for successful completion of the step.
A valid marked up key was provided (e.g., graph interpretation, initialed steps for handouts).
- 4.
For column 4, Job Content, check the appropriate box if the job content flaw does not meet the following elements:
Topics are linked to the job content (e.g., not a disguised task, task required in real job).
The JPM has meaningful performance requirements that will provide a legitimate basis for evaluating the applicant's understanding and ability to safely operate the plant. (ES-301, D.2.c)
- 5.
Based on the reviewers judgment, is the JPM as written (U)nacceptable (requiring repair or replacement), in need of (E)nhancement, or (S)atisfactory? Mark the answer in column 5.
- 6.
In column 6, provide a brief description of any (U)nacceptable or (E)nhancement rating from column 5.
Save initial review comments and detail subsequent comment resolution so that each exam-bound JPM is marked by a (S)atisfactory resolution on this form.
ES-301 12 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Scenario: 1 Exam Date: August 27 - September 7, 2018 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1-N-BOP S
2-R-OATC S
3-C-OATC S
4-C-BOP (TS)
X S
5-C-OATC S2-E2 (2015)
S 6-C-BOP (TS)
X S
7-M-ALL CT-1 E
S NRC:
(1) CT Bases information has not been provided for any of the CTs in this scenario.
Provide CT Bases information.
(2) Number the CTs and include them with the corresponding Event numbers on Form ES-D-1.
Response: Numbered the CTs on the D-1 and D-2 forms and included them with the corresponding event numbers on the D-1 as requested. Added CT Bases information page in the back of the D-2.
8-C-BOP CT-2 E
S NRC:
(1) CT for failure of HPCS to automatically start requires the crew to manually start the HPCS Pump before RPV water level reaches TAF. Revise the CT to also include the action to manually open the HPCS injection valve (1E22F004).
(2) See Event 7 comments above regarding the inclusion of CT Bases information and CT numbering.
Response: Revised CT-2 to include manually opening 1E22F004 in E-8.
8 0
0 0
0 2
2 7
E S
ES-301 13 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Scenario: 2 Exam Date: August 27 - September 7, 2018 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1-N-BOP S2-E1 (2017)
S 2-TS-SRO X
S NRC: SRO script specifies ITS LCO 3.3.4.1, EOC - RPT Instrumentation, Required Actions (RA) A.1 and B.1. Appears that only Condition A, RA A.1, is applicable. Condition B (RA B.1) is for One or more Functions with two channels inoperable. Clarification required.
Response: Verified correct ITS actions are A.1 and B.1.
3-TS-SRO X
S 4-R-OATC S
5-C-OATC S1-E3 (2017);
S2-E4 (2015)
S NRC: Form ES-301-5 incorrectly lists Event 5 as a TS item for SRO-I4. No impact to minimum TS count total for SRO-I4.
Response: Revised Form ES-301-5 for I4.
6-C-OATC S
NRC: Appears that the Auto method for removing a TDRFP from service only involves selection of the TDRFP A Take Pump Offline command. If removal of the TDRFP from service is entirely automated, then it will be necessary to ensure that the OATC uses the Manual method provided for in the script.
Response: It is normal operation for the MCR to use the Auto method when removing RFPs from service. There is a sequence of mouse clicks required to begin the shutdown sequence. The shutdown must be completed before initiating E-9 (major).
7-C-BOP S
8-C-BOP S1-E7 (2015)
S 9-M-ALL CT-1 CT-2 E
S NRC:
(1) An action is scripted for the OATC to stop both RR pumps within 1 minute of receiving a Hi DW Pressure (1.68 psig). Is the one minute a facility imposed time limit to conservatively secure the RR pumps in advance of some vendor specified time limit intended to preserve the integrity of the RR pump seals, or is it the actual time specified by the vendor based on design considerations? What are the implications if the crew does not secure the RR pumps within one minute of receiving the Hi DW Pressure signal and associated isolations?
ES-301 14 Form ES-301-7 (2) A CT has been specified for performing an Emergency Depressurization (ED) in accordance with EOP-3. The CT, as scripted, states that the elapsed time between exceeding Figure N, Pressure Suppression Pressure, and EOP-3 entry is 10 minutes.
CT Bases information has not been provided for any of the CTs in this scenario. Provide CT Bases information.
(3) Number the CTs and include them with the corresponding Event numbers on Form ES-D-1.
Response
The 1-minute shutdown time for RR Pumps on high DW pressure is based on motor protection. 1.68 psig in the DW will cause a Group 8 isolation of Component Cooling Water to the containment, resulting in a loss of motor cooling to the RR Pumps. 1 minute is specified for motor protection. If the crew fails to secure the pumps within the 1 minute, it is a competency hit, not a CT failure.
Added CT Bases information page to the scenario after the D-2 Cue Page and before the D-2 Turnover Page.
Numbered the CTs on the D-1 and D-2 forms and included them with the corresponding event numbers on the D-1 as requested.
10-C-BOP CT-3 E
S NRC:
(1) Form ES-D-2 identifies a CT for ensuring that 7 SRVs are open following the initiation of ADS (3 ADS SRVs fail to open). This CT is not specified on Form ES-D-1. Reconcile the differences between Forms ES-D-1 and ES-D-2.
(2) See Event 9 comments above regarding the inclusion of CT Bases information and CT numbering.
Response: The action to ensure that 7 SRVs are open following the initiation of ADS is no longer specified as a CT on the D-2 form. Revised the CT listing on the D-2 form to reflect the CT listing on the D-1 form. Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
10 0
0 0
0 2
3 2
7 E
S
ES-301 15 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Scenario: 3 Exam Date: August 27 - September 7, 2018 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1-N-BOP S2-E1 (2015)
S 2-C-BOP (TS)
X S
3-C-OATC (TS)
X S
4-I-BOP S
5-C-OATC (TS)
X E
S NRC:
(1) Steps in CPS 3302.01, Section 8.2.4, for isolation of the idle RR loop have not been scripted.
(2) Form ES-301-5 incorrectly excludes Event 5 as a TS item for SRO-I4. No impact to minimum TS count total for SRO-I4.
Response
Removed the reference to RR Loop isolation from the D-1 and D-2 forms. Loop isolation is not required with a single seal failure.
Revised Form ES-301-5 for I4.
6-R-OATC S
7-M-ALL CT-1 CT-2 CT-3 CT-4 E
S NRC:
(1) Why wouldnt Emergency Depressurization on 2 areas above the Max Safe Values for temperature (EOP-8, Table T) be designated as a CT? Four CTs have been specified in this scenario; one associated with a scram action in EOP-8 (Secondary Containment Control), and 3 associated with ATWS actions in EOP-1A (ATWS RPV Control).
Clarification / additional information needed regarding the number and selection of CTs.
(2) CT Bases information has not been provided for any of the CTs in this scenario.
Provide CT Bases information.
(3) Number the CTs and include them with the corresponding Event numbers on Form ES-D-1.
Response
No barrier criteria exists for an ED on 2 areas above the Max Safe Values.
Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
Numbered the CTs on the D-1 and D-2 forms and included them with the
ES-301 16 Form ES-301-7 corresponding event numbers on the D-1 as requested.
8-C-ALL S
8 0
0 0
0 3
4 7
E S
ES-301 17 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Scenario: 4 Exam Date: August 27 - September 7, 2018 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1-N-BOP S
2-TS-SRO X
S 3-C-OATC S
4-R-OATC S
5-C-BOP (TS)
X CT-1 S1-E6 (2017)
E S
NRC:
(1) CT Bases information has not been provided for any of the CTs in this scenario.
Provide CT Bases information.
(2) Number the CTs and include them with the corresponding Event numbers on Form ES-D-1.
Response
Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
Numbered the CTs on the D-1 and D-2 forms and included them with the corresponding event numbers on the D-1 as requested.
6-C-BOP S
7-C-OATC CT-4 CT-3 S
NRC: See Event 5 comments above regarding the inclusion of CT Basis information and CT numbering.
Response: Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
NRC: Pre-identified CT-3 (Event 9) was invalidated during the last run of Scenario #4.
Accordingly, CTs renumbered CT-1 through CT-3.
8-M-ALL CT-2 E
S NRC:
(1) See Event 5 comments above regarding the inclusion of CT Bases information and CT numbering.
(2) Same comment as Scenario 2, Event 9, regarding the action to secure RR Pumps within 1 minute of DW Pressure reaching 1.68 psig.
Response
Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
The 1-minute shutdown time for RR Pumps on high DW pressure is based on motor
ES-301 18 Form ES-301-7 protection. 1.68 psig in the DW will cause a Group 8 isolation of Component Cooling Water to the containment, resulting in a loss of motor cooling to the RR Pumps. 1 minute is specified for motor protection. If the crew fails to secure the pumps within the 1 minute, it is a competency hit, not a CT failure.
9-C-BOP CT-3 E
S NRC: See Event 5 comments above regarding the inclusion of CT Basis information and CT numbering.
Response: Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
NRC: Pre-identified CT-3 invalidated during the last run of Scenario #4.
9 0
0 0
0 2
(4) 3 8
E S
NRC: Pre-identified CT-3 (Event 9) was invalidated during the last run of Scenario #4.
Accordingly, CTs renumbered CT-1 through CT-3.
ES-301 19 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Scenario: 5 (Low Power)
Exam Date: August 27 - September 7, 2018 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1-N-BOP S
2-R-OATC S
NRC: Will the withdrawal of a single rod (20-25) equate to a significant reactivity manipulation, i.e., produce a clearly observable plant response? What is the expected power change when withdrawing rod 20-25 from position 24 to the full out position? Note the expected power change in the script.
Response: If necessary to produce a clearly observable plant response, Event 2 can be continued after Events 3 and 4 are completed.
3-C-OATC S3-E4 (2017)
S 4-C-OATC (TS)
X S1-E3 (2015);
S3-E3 (2017)
S 5-TS-SRO X
S 6-C-BOP CT-1 S3-E6 (2017)
E S
NRC:
(1) CT Bases information has not been provided for any of the CTs in this scenario.
Provide CT Bases information.
(2) Number the CTs and include them with the corresponding Event numbers on Form ES-D-1.
Response
Added CT Bases information page in the back of the D-2 before the D-2 Turnover page.
Numbered the CTs on the D-1 and D-2 forms and included them with the corresponding event numbers on the D-1 as requested.
7-C-BOP S
8-M-ALL CT-2 CT-3 E
S NRC:
(1) Form ES-D-1 specifies a CT to enter EOP-3 and perform an Emergency Depressurization prior to suppression pool level lowering to 151. On Form ES-D-2, the anticipatory blowdown (i.e., rapid depressurization of the RPV to the condenser by fully opening the Main Turbine Bypass Valves), is scripted as the means by which to initially commence depressurization of the RPV (designated as a CCT), in addition to the ED critical task (EOP-3). The CCT designation is confusing. What constitutes a CCT and is it
ES-301 20 Form ES-301-7 the equivalent of a CT? Is there a basis for the CCT? Clearly identify the CTs that are incorporated into Event 8 of this scenario. Reconcile the differences between Forms ES-D-1 and ES-D-2.
(2) See Event 6 comments above regarding the inclusion of CT Bases information and CT numbering.
Response
Removed all references to CCT from the D-2. Anticipatory blowdown is no longer designated as a CT.
On the D-2, clearly defined CT-3 as entry into EOP-3 and performance of emergency depressurization prior to suppression pool level lowering to 151 (reconciles the CT information between the D-1 and D-2 forms).
Added CT Bases information page for CTs-1, 2, and 3 in the back of the D-2 before the D-2 Turnover page.
Numbered the CTs on the D-1 and D-2 forms and included them with the corresponding event numbers on the D-1 as requested.
9-C-ALL S
9 0
0 0
0 2
3 6
E S
ES-301 21 Form ES-301-7 Instructions for Completing This Table:
Use this table for each scenario for evaluation.
2 Check this box if the events are not related (e.g., seismic event followed by a pipe rupture) OR if the events do not obey the laws of physics and thermodynamics.
3, 4 In columns 3 and 4, check the box if there is no verifiable or required action, as applicable. Examples of required actions are as follows: (ES-301, D.5f) opening, closing, and throttling valves starting and stopping equipment raising and lowering level, flow, and pressure making decisions and giving directions acknowledging or verifying key alarms and automatic actions (Uncomplicated events that require no operator action beyond this should not be included on the operating test unless they are necessary to set the stage for subsequent events. (Appendix D, B.3))
5 Check this box if the level of difficulty is not appropriate.
6 Check this box if the event has a TS.
7 Check this box if the event has a critical task (CT). If the same CT covers more than one event, check the event where the CT started only.
8 Check this box if the event overlaps with another event on any of the last two NRC examinations. (Appendix D, C.1.f) 9 Based on the reviewers judgment, is the event as written (U)nacceptable (requiring repair or replacement), in need of (E)nhancement, or (S)atisfactory? Mark the answer in column 9.
10 Record any explanations of the events here.
In the shaded boxes, sum the number of check marks in each column.
In column 1, sum the number of events.
In columns 2-4, record the total number of check marks for each column.
In column 5, based on the reviewer's judgement, place a checkmark only if the scenario's LOD is not appropriate.
In column 6, TS are required to be 2 for each scenario. (ES-301, D.5.d)
In column 7, preidentified CTs should be 2 for each scenario. (Appendix D; ES-301, D.5.d; ES-301-4)
In column 8, record the number of events not used on the two previous NRC initial licensing exams. A scenario is considered unsatisfactory if there is < 2 new events. (ES-301, D.5.b; Appendix D, C.1.f)
In column 9, record whether the scenario as written (U)nacceptable, in need of (E)nhancement, or (S)atisfactory from column 11 of the simulator scenario table.
ES-301 22 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Exam Date: August 27 - September 7, 2018 Scenario 1
2 3
4 5
6 7
8 11 Event Totals Events Unsat.
TS Total TS Unsat.
% Unsat.
Scenario Elements U/E/S Explanation 1
8 0
2 0
2 0
0 E
S 2
10 0
2 0
2 0
0 E
S 3
8 0
3 0
4 0
0 E
S 4
9 0
2 0
4 0
1 0
6.7 E
S Pre-identified CT-3 was invalidated during the last run of Scenario #4. The 6.7%
value calculated in Column 7, uses a value of 4 for the Column 5 value input into the Note 7 (below) calculation used to determine the percentage of unsatisfactory scenario elements. Three pre-identified CTs remained valid for Scenario #4 post-exam.
5 9
0 2
0 3
0 0
E S
Instructions for Completing This Table:
Check or mark any item(s) requiring comment and explain the issue in the space provided.
1, 3, 5 For each simulator scenario, enter the total number of events (column 1), TS entries/actions (column 3), and CTs (column 5).
This number should match the respective scenario from the event-based scenario tables (the sum from columns 1, 6, and 7, respectively).
2, 4, 6 For each simulator scenario, evaluate each event, TS, and CT as (S)atisfactory, (E)nhance, or (U)nsatisfactory based on the following criteria:
- a.
Events. Each event is described on a Form ES-D-2, including all switch manipulations, pertinent alarms, and verifiable actions. Event actions are balanced between at-the-controls and balance-of-plant applicants during the scenario. All event-related attributes on Form ES-301-4 are met. Enter the total number of unsatisfactory events in column 2.
- b.
TS. A scenario includes at least two TS entries/actions across at least two different events. TS entries and actions are detailed on Form ES-D-2. Enter the total number of unsatisfactory TS entries/actions in column 4. (ES-301, D.5d)
- c.
CT. Check that a scenario includes at least two preidentified CTs. This criterion is a target quantitative attribute, not an absolute minimum requirement. Check that each CT is explicitly bounded on Form ES-D-2 with measurable performance standards (see Appendix D). Enter the total number of unsatisfactory CTs in column 6.
7 In column 7, calculate the percentage of unsatisfactory scenario elements: 2 + 4 + 6 1 + 3 + 5100%
If the value in column 7 is > 20%, mark the scenario as (U)nsatisfactory in column 8. If column 7 is 20%, annotate with (E)nhancement or (S)atisfactory.
9 In column 11, explain each unsatisfactory event, TS, and CT. Editorial comments can also be added here.
Save initial review comments and detail subsequent comment resolution so that each exam-bound scenario is marked by a (S)atisfactory resolution on this form.
ES-301 24 Form ES-301-7 Facility: CLINTON NUCLEAR POWER STATION Exam Date: August 27 - September 7, 2018 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
2 0
7 JPM RO-A3: LOD=1. As written, JPM is a direct lookup.
JPM SRO-A4: JPM does not test / evaluate the applicants knowledge of the facilitys Emergency Plan.
Sim/In-Plant JPMs 11 1
8 2
JPM f (S6): Critical Steps 7, 10, and 13 do not contain verifiable actions.
Scenarios 5
0 5
0 Op. Test Totals:
25 3
13 9
12 Instructions for Completing This Table:
Update data for this table from quality reviews and totals in the previous tables and then calculate the percentage of total items that are unsatisfactory and give an explanation in the space provided.
- 1.
Enter the total number of items submitted for the operating test in the Total column. For example, if nine administrative JPMs were submitted, enter 9 in the Total items column for administrative JPMs.
For scenarios, enter the total number of simulator scenarios.
- 2.
Enter the total number of (U)nsatisfactory JPMs and scenarios from the two JPMs column 5 and simulator scenarios column 8 in the previous tables. Provide an explanation in the space provided.
- 3.
Enter totals for (E)nhancements needed and (S)atisfactory JPMs and scenarios from the previous tables. This task is for tracking only.
- 4.
Total each column and enter the amounts in the Op. Test Totals row.
- 5.
Calculate the percentage of the operating test that is (U)nsatisfactory (Op. Test Total Unsat.)/(Op. Test Total) and place this value in the bolded % Unsat. cell.
Refer to ES-501, E.3.a, to rate the overall operating test as follows:
satisfactory, if the Op. Test Total % Unsat. is 20%
unsatisfactory, if Op. Test Total % Unsat. is > 20%
- 6.
Update this table and the tables above with post-exam changes if the as-administered operating test required content changes, including the following:
The JPM performance standards were incorrect.
The administrative JPM tasks/keys were incorrect.
CTs were incorrect in the scenarios (not including post scenario critical tasks defined in Appendix D).
The EOP strategy was incorrect in a scenario(s).
TS entries/actions were determined to be incorrect in a scenario(s).