ML19239A200
| ML19239A200 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/23/2019 |
| From: | Joseph Demarshall FirstEnergy Nuclear Operating Co |
| To: | NRC/RGN-III/DRS/OLB |
| Demarshall J | |
| Shared Package | |
| ML17215A919 | List: |
| References | |
| Download: ML19239A200 (16) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: PERRY NUCLEAR POWER STATION Exam Date: February 11 - 22, 2019 Admin JPMs 1
2 3
Attributes 4
Job Content 5
6 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.
OT-3701-ADM_033SRO Conduct of Operations 2.1.4 2
X U
S NRC: During walk-through, determined that JPM Steps 2, 3, 5, & 7 should be Critical Steps.
Response: Changed JPM Steps 2, 3, 5, & 7 from Standard Steps to Critical Steps.
OT-3701-ADM_034SRO Conduct of Operations 2.1.2 2
X E
S NRC: Identification that prerequisite 4.2 was incorrectly checked as NO for Position Indication verification is not a Critical Step since the data was subsequently correctly recorded for all valves tested in compliance with the Technical Specifications. This appears to be purely identification of an administrative error and missing this error would not result in a failure to collect Technical Specification required data.
Response: Changed JPM Step 1 to a Standard vs.
Critical Step.
OT-3701-ADM_026SRO Equipment Control 2.2.41 3
X U
S NRC: Critical Step to determine which Fire Protection Functional Specifications the plant is in should not indicate applicants may enter a specification. Answer key should indicate the specifications that are appropriately entered for the plant condition. If it is appropriate to enter conditions 4a and 6a then that should be a part of the expected answer.
Response: Perrys position is that Spec 4.D.1 (Mains & Headers) is entered but is modified by a Note (Page 73) that states the impaired system (in this case both Fire Pumps) shall be properly compensated per the individual system requirements identified in Spec 3.
Spec 6.D.2 (Hydrants) is entered since Hydrant-25 is within the isolation boundary. The Facility Reviewer agrees that Spec 4 should be a Standard Step and Spec 6 should be a Critical Step. The validator that made the original comment agrees. Added new JPM Step 5 for Spec 4 as a "Standard Step and new JPM Step 6 for Spec 6 as a Critical Step. Revised Standard for JPM Step 5 to better define why entry into Spec 4 is not a Critical Step.
ES-301 Operating Test Review Worksheet Form ES-301-7 OT-3701-ADM_019SRO Radiation Control 2.3.4 2
S PERRY: During Onsite Validation, enhanced both the Initial Conditions and the Initiating Cue, added Instructor Cue information to JPM Step 2, and specified a range for the calculated value of Dose Level Approved in the Notes field of JPM Step 3 and in the Answer Key for Perry Emergency Dose Authorization Form PNPP 10136.
OT-3701-ADM_322SRO Emergency Procedures/Plan 2.4.38 3
S NRC: Licensees EAL thresholds for RU1.1 appear to be higher than RA1.1 for TB/HB Vent Gas Monitor.
Time Critical.
Response: The Action Level setpoint for the UE is based on not having fuel damage and is 2 times the ODCM limit for 60 minutes. The Alert, SA, and GE thresholds are based on having damaged fuel (assumes a source term) and dose received at the site boundary.
OT-3701-ADM_001_RO Conduct of Operations 2.1.7 3
X E
S NRC: How will references be made available to the applicants? Will they be allowed to perform a computer search for correct procedures, or will hardcopies be provided for the applicants to work through in order to determine the appropriate actions / correct answers?
Response: For JPMs, we only use hard copies of procedures/drawings. If the JPM is administered in the Simulator, all procedural references will be readily available. If the JPM is administered in a classroom, each applicants will have their own set of procedural references.
OT-3701-ADM_005_RO Conduct of Operations 2.1.25 3
S PERRY: During Onsite Validation, changed Validated Time from 25 to 20 minutes.
OT-3701-ADM_033_RO Equipment Control 2.2.41 1
3 X
U S
NRC: The initial conditions indicating that valve 1N27-F305 is in the Heater Bay greatly reduces the level of difficulty as Drawing 302-243 clearly delineates which Instrument Air piping traverses which building. From that cue, no other drawing is required to quickly identify the isolations for the leaking valve.
Response: Deleted words, in the Heater Bay from Initial Conditions. During Onsite Validation, changed Validated Time from 8 to 15 minutes, and modified JPM Step 2 to allow either or both Instrument Air valves to be isolated.
ES-301 Operating Test Review Worksheet Form ES-301-7 OT-3701-ADM_019_RO Radiation Control 2.3.7 3
X E
S NRC: DR 5 is colored blue unlike the other dose rates on the survey map. Since this is the correct answer for what is the highest general area dose rate level along the path to the victim, its color differentiation stands out and is unnecessary.
Recommend that smear 2 be recorded as the highest in the room. With smear 3 highest, it is too prominent under the Summary of Highest Readings section.
Response: The Survey map will be printed in black and white. The blue color of DR 5 will not be distinguishable.
Swapped locations of smears 2 and 3 (for ease of editing) and changed JPM Step 1 to identify smear 2 at 2000 dpm.
During Onsite Validation, specified acceptable range for 2-people in the Notes field of JPM Step
- 4.
ES-301 Operating Test Review Worksheet Form ES-301-7 1
Simulator/In-Plant Safety Function and K/A JPMs S1 C71_501_RO 1
295006 AA1.01 2
S PERRY: During Onsite Validation, moved RPS alternate path starting point to Section 5.1.2, Manual Scram Switch Channel C, and deleted JPM Steps for Section 5.1.3, Manual Scram Switch Channel B.
S2 E51_501_RO 2
217000 K3.01 3
S PERRY: During Onsite Validation, corrected typo on JPM Step 1.
S3 B21_003_RO 3
218000 A4.03 2
S PERRY: During Onsite Validation, corrected typo on JPM Step 3.
S4 G33_001_RO 4
295021 AK2.02 2
S S5 B21_507_RO 5
223002 A2.03 2
S PERRY: During Onsite Validation, changed Validated Time from 10 to 15 minutes.
S6 R10_006_RO 6
295003 AA1.01 3
S PERRY: During Onsite Validation, changed Validated Time from 16 to 20 minutes.
S7 C51_005_RO 7
215005 A1.07 3
S PERRY: During Onsite Validation, deleted unnecessary wording from Instructor Cue in JPM Step 7 S8 M14_501_RO 9
288000 A4.01 2
X E
S NRC: JPM Step 10 should indicate procedure Step 4.1.15 not 4.1.13.
Response: Revised JPM Step 10 to specify the correct procedural step.
During Onsite Validation, enhanced the Initial Condition by adding the statement: An NLO is in the field to support startup.
P1 R43_017_RO 6
264000 K4.07 2
S PERRY: During Onsite Validation, corrected typo on JPM Step 8.
P2 P54_503_RO 8
286000 A2.08 3
X E
S NRC: Coversheet indicates that this is not an Alternate Path JPM. This is an Alternate Path JPM as indicated on the ES-301-2 forms.
Response: Corrected cover sheet to show Alternate Path.
During Onsite Validation, determined JPM should be terminated after JPM Step 4. (Deleted JPM Step 5).
P3 M49_001_RO 9
288000 K5.03 2
S
ES-301 4
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 5
Form ES-301-7 Facility: PERRY Scenario: 1 Exam Date: February 11 - 22, 2019 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
S Normal Operations 2
S Reactivity Event 3
S 4
X X
E S
NRC:
Why is RCIC auto starting on a failed low CST level signal? RCIC pump should only auto start on a low RPV level indication. RCIC auto suction swap to the Suppression Pool would be expected to occur for this event. If RCIC does not start, would not expect the operator to take the system out of service, therefore would not expect to enter TS 3.5.3. Is TS 3.5.3 entry made because TS 3.3.5.2, Action D.1, states Declare RCIC System inoperable? The scripted actions for this event on Page 6 of 20, and the TS Evaluations /
Associated Evaluator notes on Page 7 of 20 are confusing.
D-1 document refers to TS 3.3.6.1. This appears to be associated with Event 5. Need to be clear on exactly (a) which TSs require entry, and (b) which TS Conditions and Required Actions are applicable.
Narrative Summary conflicts with the D-1 and D-2 as it indicates the RCIC suction swap is caused by a failed high SP level instead of a failed low CST level.
Response
RCIC was started in Event 1 in CST to CST mode. TS 3.5.3 is entered when RCIC is tripped in response to the malfunction and will be rendered unavailable for the duration of the scenario.
TS 3.3.6.1 was incorrectly listed under Event 4 on D-1. It has been moved to Event 5 on the D-1.
Corrected Narrative Summary to show correct failure on Event 4 and correct TSs for Events 4 and 5.
5 X
X E
S NRC:
D-1 does not list TS 3.3.6.1 which conflicts with the D-2 for this event.
Response: Corrected the D-1 to list TS 3.3.6.1.
6 S
7 X1 E
S NRC:
Clearly define bounding condition for CT. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
Response
Worked with Chief Examiner during Onsite Validation to evaluate and appropriately bound all CTs.
ES-301 6
Form ES-301-7 8
X X2 E
S NRC:
It seems exceptionally unlikely that HPCS will be in any condition other than overridden following Event 5. Therefore, this failure will more than likely not be observable to the applicants. If RCIC is still available from the Suppression Pool, do not expect to need HPCS without a LOCA condition present. Starting HPCS would not be a Critical Task.
Clearly define bounding condition for CT. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
Response
Over-ridding HPCS in Event 5 does not prevent its use. It is expected that the crew would manually start and inject with HPCS. RCIC was tripped in Event 4 and would not be readily available for use.
Worked with Chief Examiner during Onsite Validation to evaluate and appropriately bound all CTs.
9 X3 S
9 1
1 0
0 2
3 8
E S
NRC:
See above comments.
Response
Individual responses to NRC comments are provided above.
ES-301 7
Form ES-301-7 Facility: PERRY Scenario: 2 Exam Date: February 11 - 22, 2019 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 Explanati on 1
E S
Normal Operations.
NRC:
SOI M-40, Revision 11 does not include step to turn on the oncoming exhaust electrical heater.
Response
SOI-M40 was recently changed to remove heater operation. Deleted step to start heater and renumbered steps per SOI-M40.
2 X
X E
S NRC:
TS 3.3.6.2, Condition C.1 is applicable, as Function 2 is affected when the second containment pressure transmitter fails. This TS is UNSAT.
D-2 incorrectly indicates that BOP refers to annunciator response procedure ARI-H13-P601-17-B2 instead of B3.
Response
TS 3.3.6.2, Condition C.1 is not applicable since initiation capability has NOT been lost in BOTH trip systems.
Corrected typo on D-2 to show B3 annunciator window.
NRC: Discussed implementation of TS 3.3.6.2, Condition C.1, with the Licensee during the Onsite Validation. Licensee provided the necessary clarification as to why TS 3.3.6.2, Condition C.1 was not applicable. NRC comment sufficiently addressed.
3 X
S 4
X S
5 X1 E
S NRC:
Clearly define bounding condition for CT. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
Response
Worked with Chief Examiner during Onsite Validation to evaluate and appropriately bound all CTs.
6 X2 S
7 S
Reactivity Event 8
X3 X 3 E
S NRC:
Clearly define bounding condition for CTs. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
RPV depressurization is not expected for this scenario, therefore bounding the CTs with depressurization is not appropriate.
Response
Worked with Chief Examiner during Onsite Validation to evaluate and appropriately
ES-301 8
Form ES-301-7 bound all CTs. Event 8 originally contained CTs -3 & -4. Deleted original CT-3 and renumbered the remaining CT (i.e., CT-4) as CT-3.
9 S
10 S
10 0
1 0
0 2
3 9
E S
NRC:
See above comments.
Response
Individual responses to NRC comments are provided above.
ES-301 9
Form ES-301-7 Facility: PERRY Scenario: 3 (Spare)
Exam Date: February 11 - 22, 2019 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
ES-301 11 Form ES-301-7 Facility: PERRY Scenario: 4 (Low Power)
Exam Date: February 11 - 22, 2019 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 Explanat ion 1
S Reactivity Event 2
S Normal operations 3
X E
S NRC:
D-1 should indicate this event is a TS call for the SRO
Response
Corrected D-1 to indicate this event as a TS Call for the SRO.
4 S
New Event:
Incorporated New Component Failure Event for the BOP position: FPCC Pump A Low Discharge Pressure Shift Pumps, during Onsite Validation week.
45 S
56 E
S NRC:
D-2 should include ONI-N32 Immediate Action 3.4 to trip the EXCITER FIELD BRKR and should indicate that ATC/BOP carryout ONI-N32 supplemental actions.
Response
Changed D-2 as requested.
67 X
X E
S NRC:
D-1 should indicate this event is a TS call for the SRO.
Response
Corrected D-1 to indicate this event as a TS Call for the SRO.
8 X2 X3 1 E
S NRC:
For CTs 2 and 3, clearly define bounding condition for CTs. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
Response
Worked with Chief Examiner during Onsite Validation (OV) to evaluate and appropriately bound all CTs. Deleted original CT-2 based on changes incorporated during the OV.
Defined bounding conditions for original CT-3. CT-3 was renumbered as CT-1.
9 X3 1 S
CT-3 was renumbered as CT-1 (see Response comments in Event 8 above).
710 X1 (X 2)*
E S
NRC:
For CTs 1 and 4, clearly define bounding condition for CTs. Per App D - D.1.c, the performance standard for a CT includes two parts: 1) expected actions, 2) safety-significant boundary conditions that clearly identify at what point a CT must be accomplished.
Response
Worked with Chief Examiner during Onsite Validation (OV) to evaluate and appropriately
ES-301 12 Form ES-301-7 bound all CTs. Deleted original CT-1 based on changes incorporated during the OV.
Original CT-4 was changed from a potential CT to a pre-identified Critical Task.
Defined bounding conditions for CT-4, renumbered CT-4 as CT-2, AND
- Re-assigned this CT to New Event 11.
11 X2 S
New Event:
Incorporated New Post-EOP Entry Malfunction Component Failure Event for the BOP position: LPCS Suppression Pool Suction valve E21-F001 loses power, requiring ED, during Onsite Validation week.
9 11 0
0 0
0 2
2 8
10 E
S NRC:
See above comments.
Response
Individual responses to NRC comments are provided above.
ES-301 13 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, pre-identified 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 14 Form ES-301-7 Facility: PERRY Exam Date: February 11 - 22, 2019 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
9 0
2 1
3 0
7.14 E
S 2
10 0
2 0
4 3
0 0
E S
3 4
9 11 0
2 0
4 2
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 pre-identified 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.
2 + 4 + 6 7
In column 7, calculate the percentage of unsatisfactory scenario elements:
(
) 100%
1 + 3 + 5 8
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 15 Form ES-301-7 Facility: PERRY Exam Date: February 11 - 22, 2019 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
3 3
3 Sim/In-Plant JPMs 11 0
2 9
Scenarios 4
0 4
0 Op. Test Totals:
24 3
9 12 12.5 SATISFACTORY 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).