ML19302F560

From kanterella
Jump to navigation Jump to search

NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML19302F560
Person / Time
Site: Beaver Valley
Issue date: 09/27/2019
From: David Silk
FirstEnergy Nuclear Operating Co
To:
NRC Region 1
Shared Package
ML18296A422 List:
References
CAC 000500
Download: ML19302F560 (13)


Text

ES-301 Operating Test Review Worksheet Facility: Beaver Valley 2 (RO JPMs - See Draft Op Test Outlines for Titles) 2 ADMIN Topic I LOD Admin JPMs I aed KIA (1-5) 1 11c J I c,11oa1 Cues Focus Steps r~;

re::;- --- - -.=- --~,,--

1 co 2.1.23 2CO 2.1.7 I

2 3EQ 2.2.12 I

3 4 RC 2.3.4 I

2 I

X Simulator/In-Plant Safety Function and JPMs K/A S1 SF 1 001 A3.05 S2 SF 2 I 004 A4.06 I 3

I X

I X

I S3 SF 3 I 006 A4.05 I 3

I I

X I S4 SF 4P I 003A2.02 I 3 I I I S5 SF 4S I 035 A3.01? I 3

I I

X I S6SF 6 I 057 AA2.12 I 3 I I

I S7 SF 7 I 073 A4.02 I 3

I I

X I 3

Attributes Scope I I Pert.

4 Job Content Overlap I I Key I Minutia Job Link (N/8) I I Std.

  • ---y--

X X

I I

I I

I I

I I

I X

I I

I I I I I I I

I I

I I

I I

I X

I I

X I

I I

I I

I X

I X I I

I I

I I

I I

5 U/E/S s

E s

E E

E s

E u

E Form ES-301-7 Exam Date: 10/7/19 -10/11/19 6

Explanation Task standard was made more specific that QPTR is oreater than 1.02.

Cue should be R vs R/hr. Add ranges to task standard.

Modify initiating cue and applicable step note related I to local field operator energizing an RCS loop drain valve to sueeort elacing excess letdown in service.

Modify task standard to state that the lineup will be done IAW procedure ES-1.5 to account I for only one running charging pump (e.g., JPM steps 9-14). Add to JPM step 8 that applicant recognizes I

that eume is not running.

Assign a KA that fits Safety Function 4S (e.g., 059 is SF4 S whereas 035 is SF4 P). Add evaluator note I regarding long stroke time of 2FWS-FCV478. Add evaluator note what expected MFRV demand position should be when the BFRV is fully closed.

This is not an alternate path JPM. Modify task standard. Specify putting "B" orifice in service vice I "A" & "B". Truncate JPM and end after placing PZR level selector to CH I or CH Ill.

Modify task standard to state that the lineup will be I done IAW procedure 20M-43.4.AEB or based upon component response. Add figure 16-10 to end of JPM so evaluator can visualize final damper

ES-301 Operating Test Review Worksheet Form ES-301-7 alignment. Enhance scripting for generic high rad monitor response. Add evaluator note related to expected ventilation changes and alarms as a result of JPM actions.

S8SF9 068 A4.03 2

u This is not alternate path.

Modify task standard to state that the lineup is done P1 SF 5 022 K2.01 3

X X

E IAW 20M-44C.4.E. Add details for breaker operations.

Modify task standard to state that the lineup is done P2 SF 7 016A2.01 2

X X

E IAW 20M-1.4.ACJ. Add colored picture of cabinet to avoid direct cuing of applicant.

Specify that the throttle valve should be fully open in P3 SF 4S 061A2.05 2

X X

the task standard. Add to initial conditions that the breaker for the valve is open and de-energized.

ES-301 3

Facility: Beaver Valley 2 {SROI/SROU JPMs - See Draft Op Test Outlines for Titles) 1 I

2 3

4 LOO Attributes Job Content Admin JPMs ADMINTopic and KIA (1-5) 1/C Critical Scope Perf.

Job Cues Overlap Key Minutia L" k Focus Steps (NIB)

Std.

in L__

-- --~- *---...-

1 co 2.1.23 3

X 2CO 2.1.37 2

3 EC 2.2.17 3

4 RC 2.3.4 2

5 EP 2.4.40 2

X Simulator/In-Plant I Safety Function and JPMs KIA S1 SF 1 NIA S2 SF 2 004 A4.06 3

  • S3 SF 3 006 A4.05 3
  • S4 SF 4P 003A2.02 3

S5 SF 4S 035 A3.01?

3 S6 SF6 057 AA2.12 3

S7 SF 7 073 A4.02 3

  • S8 SF 9 068 A4.03 2

P1 SF 5 022 K2.01 3

  • P2 SF 7 016A2.01 2
  • P3 SF 4S 061A2.05 2

Note: * - indicates SROU JPM 5

U/E/S E

s s

s E

Form ES-301-7 Exam Date: 10/7 /19 - 10/11 /19 6

Explanation

-~--------------- --- ------* -

Specify boron correction factor in task standard to be 0.928 vs 0.912.

Specify EAL (FS1.1 vs SAE)

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

See comments on previous two pages.

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 0.4)

2.

Determine the level of difficulty (LOO) 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:

D The initial conditions and/or initiating cue is clear to ensure the operator understands the task and how to begin. (Appendix C, B.4)

D 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)

D All critical steps (elements) are properly identified.

D The scope of the task is not too narrow (N) or too broad (B).

D 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)

D 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.

D 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:

D Topics are linked to the job content (e.g., not a disguised task, task required in real job).

D 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 reviewer's 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: Beaver Valley 2 (See D-1 Forms for Details)

Scenario: 1 Exam Date: 10/7/19 -10/11/19 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOD TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

X s

2 X

X E

Add note to continue with Event 3 after the SRO determines which B/Ss are required to be triooed vice waitina for l&C to locallv trio the B/Ss.

3 X

X s

4 s

5 s

6 X

X s

7 X

X s

8 X

u This is not a CT because FPB is already lost due to a LOCA. Remove CT from guide.

9 s

9 0

0 0

0 2

3 4

E

ES-301 6

Form ES-301-7 Facility: Beaver Valle, 2 (See D-1 Forms for Details)

Scenario: 2 Exam Date: 10/7/19 -10/14/19 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOO TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

s 2

X X

E Add 30 day action for TS.

3 X

X E

This reauires the ATC to take action. Chanae D-1 & 301-5.

4 X

X s

5 X

s This event may not count as is may not be seen by the crew due to a pre-emptive manual X

u action. Add information on page 10/18 that CNMT intermediate high pressure MSLI is 6

inhibited to solidify CT of manually initiatinq MSLI.

7 X

s 8

s 9

s 9

0 0

2 0

2 3

6 E

ES-301 7

Form ES-301-7 Facility:

Beaver Valley 2 (See D-1 Forms for Details)

Scenario: 3 Exam Date: 10/7/19-10/11/19 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOD TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

X s

2 X

X E

This is a component failure not a reactivity event. Chanqe D-1 & 301-5.

3 s

4 X

X s

5 X

X s

6 s

7 X

X s

8 X

s 8

0 0

0 0

3 3

4 s

ES-301 8

Form ES-301-7 Facility:

Beaver Vallev 2 (See D-1 Forms for Details)

Scenario: 4 Exam Date: 10/7/19 -10/11/19 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOD TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

s 2

X s

3 X

s 4

X X

E Add discussion related to applicability of PT-456 below P-7.

X X

E Alarm state for A12-2G and A12-3G should be ON not OFF. Change Event 5 to instrument 5

fuse failure and add discussion about TS 3.0.3.

6 X

u This is a TS event. Add detail in D-1, D-2, and 301-5 7

s 8

X s

9 X

X s

10 X

X s

11 X

E Paqe 20/23 ensure actions completed before completion of A-0.11 to bound CT-~.

12 X

s 12 0

0 0

0 3

3 5

E

ES-301 9

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 reviewer's 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 LOO 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 10 Form ES-301-7 Facility:

Beaver Valley Unit 2 Exam Date: 10/7/19-10/11/19 1

2 3

4 5

6 7

8 11 Scenario Event Events TS TS CT CT

% Unsat.

Explanation Totals Unsat.

Total Unsat.

Total Unsat.

Scenario U/E/S Elements 1

9 1

2 0

3 1

14.3 E

2 9

1 2

0 3

0 7.1 E

3 8

0 3

0 3

0 0.0 s

4 12 1

3 1

3 0

11.1 E

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 + 5 100%

8 If the value in column 7 is> 20%, mark the scenario as (U)nsatisfactory in column 8. If column 7 is :5 20%, annotate with (E)nhancement or (S)atisfactory.

9 In column 9, 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 Site name:

Admin.

JPMs Sim.fin-Plant JPMs Scenarios Op. Test Totals:

Beaver Valley Unit 2 Total Total Unsat.

9 0

11 3

4 0

24 3

11 Form ES-301-7 Exam Date: 10/7/19 -10/11/19 OPERATING TEST TOTALS Total Total Explanation Edits Sat.

4 5

6 1

3 1

13 7

12.5 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.
2.
3.
4.
5.
6.

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.

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.

Enter totals for (E)nhancements needed and (S)atisfactory JPMs and scenarios from the previous tables. This task is for tracking only.

Total each column and enter the amounts in the "Op. Test Totals" row.

Calculate the percentage of the operating test that is (U)nsatisfactory (Op. Test Total Unsat.)/(Op. Test Total) and place this value in the balded "% 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 s 20%

unsatisfactory, if "Op. Test Total""% Unsat." is> 20%

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 postscenario 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.

Beaver Valley 2 Op Test Comments Admin JPMs RO Admin 1 - No comment.

RO Admin 2 - Specify details in task standard for why calculation is unsat.

Use JPM step 5.2 as the criteria.

RO Admin 3 - No comment.

RO Adm in 4 - Put ranges on task standard as appropriate. Fix cue - Rem/hr - should only be dose, not dose rate.

SRO Admin 1 - Specify the correct boron correction factor.

SRO Admin 2 - No comment.

SRO Admin 3 - No comment.

SRO Admin 4 - No comment.

SRO Admin 5 - Specify the EAL in task standard for the declaration.

System JPMs S1 -

Not alternate path as written. Replaced with JPM 2CR-747.

S2 - Modify initiating cue and applicable step note related to local field operator energizing an RCS loop drain valve to support placing excess letdown in service.

S3 - Modify task standard to state that the lineup will be done IAW procedure ES-1.5 to account for only one running charging pump (e.g., JPM steps 9-14). Add to JPM step 8 that applicant recognizes that pump is not running.

S4 - No comment.

S5 -Assign a KA that fits Safety Function 4S (e.g., 059 is SF4 S whereas 035 is SF4 P). Add evaluator note regarding long stroke time of 2FWS-FCV478. Add evaluator note what expected MFRV demand position should be when the BFRV is fully closed.

S6 - This is not an alternate path JPM. Modify task standard. Specify putting "B" orifice in service vice "A" & "B". Truncate JPM and end after placing PZR level selector to CH I or CH Ill.

S7 - Modify task standard to state that the lineup will be done IAW procedure 20M-43.4.AEB or based upon component response. Add figure 16-10 to end of JPM so evaluator can visualize final damper alignment. Enhance scripting for generic high rad monitor response. Add evaluator note related to expected ventilation changes and alarms as a result of JPM actions.

SB - This is not an alternate path JPM.

P1 - Modify task standard to state that the lineup is done IAW 20M-44C.4.E. Add details for breaker operations.

P2 - Modify task standard to state that the lineup is done IAW 20M-1.4.ACJ. Add colored picture of cabinet to avoid direct cuing of applicant.

P3 - Specify that the throttle valve should be fully open in the task standard. Add to initial conditions that the breaker for the valve is open and de-energized.

Simulator Scenarios Scenario 1 Event 2: Add note to continue with Event 3 after the SRO determines which B/Ss are required to be tripped for this event vice actually waiting for l&C to locally trip the B/Ss.

CT-1 is not critical because the FPB is already breached due to the existence of a LOCA.

Remove this CT from the scenario guide.

Scenario 2 Event 2: Add 30 day action for TS.

Event 3: Credit both BOP and ATC on D-1 and 301-5.

Event 6 may disappear if crew manually initiates SI before setpoint is reached. Therefore, there could be one less event and one less CT for this scenario. Add information on page 10/18 that CNMT intermediate high pressure MSLI is inhibited to solidify CT of manually initiating MSLI.

Scenario 3 No comment.

Scenario 4 Event 4: Add discussion related to applicability of PT-456 below P-7.

Event 5: Alarm state for A12-2G and A12-3G should be ON not OFF. Change Event 5 to instrument fuse failure and add discussion about TS 3.0.3.

Page 20/23 ensure actions completed before completion of A-0.11 to bound CT-9.

Event 6: This should be a TS event when a rod drops. Add TS for misaligned rod in D-1 & 2.