ML19322B027

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NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML19322B027
Person / Time
Site: Millstone Dominion icon.png
Issue date: 08/22/2019
From:
NRC Region 1
To:
Dominion Nuclear Connecticut
Shared Package
ML19052A319 List:
References
000500, 000956
Download: ML19322B027 (12)


Text

ES-301 Facility: Millstone 3 Admin JPMs ADMIN Topic and K/A 2

LOD (1-5)

=-- ----- --== -=-::::..-=:--

SROADMIN A.1.1 -

Check Refueling Admin Requirements SRO ADMIN A.1.2 -

Perform a Shutdown Margin for MODE 3 with Two Stuck Control Rods.

SRO ADMIN A.2 -

Review a clearance boundary for 3CCl*P1 B.

SRO ADMIN A.3 -

Determine and Perform Actions Required to Remove a Radiation Monitor from Service SRO ADMIN A.4 -

Emergency Plan Classification and Conduct of Operations 2.1.40 Conduct of Operations 2.1.37 Equipment Control 2.2.13 Radiation Control 2.3.5 Emergency Plan 2.4.41/44 Operating Test Review Worksheet 3

Attributes 1/C I

I Critical I Scope Cues I I

I Overlap Focus I I Steps I (N/B)

Exam Date: September 9, 2019 Perf.

Std.

Key 4

Job Content Minutia Job Link 5

U/E/S E

E E

E E

Form ES-301-7 6

Explanation Modified the task standard (pg. 3).

Removed "As the refueling SRO" from the initiating cue (pgs 4,___1_Zl.

Changed task standard and made procedure handout the entire OP 3209B procedure (vice Section 4.2) (pg 3)

Changed Initial Conditions format (bulleted conditions) and changed boron sample time from "0700" to "one hour ago". (pg 4)

Added Note 1 prior to JPM Step 1 and removed JPM Step 1 (re-numbered remaining steps). (pg 5)

Modified to widen band of allowable answers due to readability of the RE curves. The final (Xe corrected) allowable band became -28 to -

100 pcm (vice -32 to -83~

On page 3, modified task standard.

On page 4, 12, added "TRM" to end of initiating cue.

On pages 5, 10, 13 changed 3CCl*V8 to 3CCl*V9.

On page 10, removed yellow tag from key (not a critical tag)

Changed validation time to 30 minutes (pgs 3, 8)

Changed task standard (pg 3)

Changed cue to "... identify the applicable responses related to TS, TRM and the REMODCM requirements.". This deleted many JPM steps that largely related to notification. JPM steps 2, 3, 4, 6, 8, 10, 13, 15, 16 & 17 were deleted. Re-numbered remaining JPM steps Changed (re-numbered) JPM step 3 to non-critical.

Added Comments to JPM steps 5 & 7 relative to Action C requirements. Made JPM step 5 non-critical.

Provided lines on examinee handout (pg

10)

Changed task standard (pg 3)

JPM Step 8 (pg 9) changed Standard 1 from " 2 mile radius" to "evacuate zones A and G"

_(_and added an Examiner Note).

ES-301 Operating Test Review Worksheet Form ES-301-7 Protective Action Changed initial condition (pg 5, 12) to Recommendation remove extraneous information.

RO ADMIN A.1.1 -

Conduct of Determine Reactivity Operations s

Change for Rod 2.1.37 Withdrawal Changed task standard and made procedure handout the entire OP 32098 procedure (vice Section 4.2) (pg 3)

Changed Initial Conditions format RO ADMIN A.1.2 -

(bulleted conditions) and changed boron sample Perform a Shutdown Conduct of time from "0700" to "one hour ago". (pg 4)

Margin for MODE 3 with Operations E

Added Note 1 prior to JPM Step 1 and Two Stuck Control Rods.

2.1.37 removed JPM Step 1 (re-numbered remaining steps). (pg 5)

Modified to widen band of allowable answers due to readability of the RE curves. The final (Xe corrected) allowable band became -28 to -

100 pcm (vice -32 to -83 pcm).

RO ADMIN A.2 -

Equipment Recommend a Clearance Control E

Corrected task standard.

Boundary for 3CCl*P1A.

2.2.13 On page 3, modified the task standard.

On pages 4, 8, corrected spelling of 3CCP-RE31 radmonitor.

On page 5, added comment to JPM step 2 which RO ADMIN A.3 - Perform Radiation details a new Alert value inserted in Attachment 1 Independent Verification Control E

- simulated ORMS screen. The new Attachment 1 Of ORMS Work Station 2.3.15 Alert value is 6.68 E-07 and makes for a new Database critical step (value doesn't comply with temporary setpoint change).

On page 9, changed alert value (as described above) and changed values on bottom of display (YES / NO ) to match current revision of OP 3250.62.

ES-301 Operating Test Review Worksheet Form ES-301-7 Simulator/In-Plant I Safety Function and JPMs KIA 1 - Reactivity This JPM was previously S.3 (replaced previous Control S.1 to better match safety function and correct issues with validation of previous S.1 ). During the SIM JPM A - S.1 /

004.A4.08 KIA validation, identified and corrected the following:

Respond to a Loss of All Rating: 3.8/3.4 X

u Changed the task standard (pg 3)

Charging Pumps JPM Steps 4-7 modified to match Rev.

(Overcurrent)

APE:022 006 of 3581 AA2.02; KIA JPM Step 33-39 modified say adjust Rating: 3.2/3.7 3CHS-FCV121 as necessary (instead of increase flow 2-Reactor Coolant Revised the task standard (page 3)

System Inventory Procedure Rev. changed to Rev. 19 Control (page 3): No impact to the JPM SIM JPM B - S.2 /

I 006~A4.05; KIA INITIAL CONDITION condition (page 4 Transfer to Cold Leg E

& 18): changed to state complete through step 14 Recirculation (vice 13) of E-1 (typo correction).

Rating: 3.9/3.8 JPM STEP 9 (page 8): Added comment EPE 011-for expected action if CTMT pressure is less than EA1.11 KIA 17.5 psia and made this step non-critical.

Ratin : 4.2/4.2 Replaced previous JPM S.3 with this bank JPM.

Ran the JPM and identified / corrected the following:

Revised the task standard (pg 3)

Changed Initial Condition (pg 4, 14): To 3-Reactor LOP condition (rather than building a JPM around Pressure all RCP's tripped - with no explanation). Done to SIM JPM C - S.3 /

Control increase realism.

Depressurize the RCS E

E-3 Procedure revised from R26 to R27 During a SG Tube KIA Number:

(pg 3): No impact to JPM Rupture 010-A2.03 KIA Changed Simulator Requirements (pg Rating: 4.1 /

4): to IC 84 and added LOP to simulator set-up.

4.2 JPM Step 2 (pg 5): changed standard to RCP's off due to LOP (instead of all RCP's tripped)

JPM Step 20 (pg 11) changed standard Verification of JPM Completion (pg 13):

Minor format changes to be consistent with 2K 19 submittal 4 primary-Replaced JPM with Bank JPM S038.

SIM JPM D - S.4 / Align I Heat Removal RHR for Cooldown from Reactor E

Additionally, identified and corrected the following Core (during NRC validation):

ES-301 Operating Test Review Worksheet Form ES-301-7 Changed validated time from 21 to 25 K/A Number:

minutes (pgs 3, 17) 005-A4.01 KIA Changed Initial Condition to 340 - 370 Rating: 3.6 /

psia (pgs 4, 18) 3.4 In simulator requirements (pg 4),

removed instruction 6 to insert key into 3RHS*MV8701C (key is not expected to be inserted, removes cueinq)

Changed task standard (pg 3) 4 secondary -

Changed Initial conditions and Cue to Heat Removal clarify and provide a more realistic direction (pgs 4, SIM JPM E - S.5 / Dump from Reactor

15)

Steam Using Core JPM Steps 1 and 2 were removed (both E

Atmospheric Relief Valve KIA Number:

were non-critical steps)

JPM Step 14 (pg 11) was added (to 041-M.06 KIA close MSIV's and add a second cue to begin the Rating: 2.9/3.1 cooldown). Additionally, added a cooldown band of between 50 80 F / hr.

5-SIM JPM F - S.6 /

Containment Respond To An Integrity Changed task standard (pg 3)

Inadvertent Containment E.

JPM Step 10 (pg 8): corrected typo Isolation Phase 'A' KIA Number:

(inserted space between "LEAST" and "ONE").

103-A2.03; KIA Rating: 4.3/4.4 Changed task standard (pg 3)

Initial Condition (pgs 4 & 19) changed to 6 - Electrical add a more realistic IC (same resultant plant status) and added Master Silence.

KIA Number:

JPM Step 5 (pg 8) changed to add an SIM JPM G - S.7 /

062-A2.05; KIA alternate JPM flowpath in comment section Energizing Bus 34A And Rating: 2.9/3.3 E

JPM Step 14 (pg 12) changed to have 34C After Fault EPE 055 examinee place control switches in pull to lock EA1.07 KIA (rather than have them in PTL as part of IC). This Rating: 4.3/4.5 makes the step critical and adds 2 minutes to the JPM.

JPM Step 21 (pg 15) changed cue to have candidate provide recommendation Simulator Requirements (pg 4): added 7-clarification to simulator set-up by revising Note 1 Instrumentation and added an alternative to resetting IC 87.

JPM Step 1 (pg 5): added clarification to SIM JPM H - S.8 /

K/A Number:

comment section that it's unlikely that the Respond to RMS-41/42 072-A3.01; KIA E

candidate will isolate CTMT Purge Valves iaw AOP Alarm Rating: 2.9/3.1 3573 APE 061 JPM Steps 6, 10 (pgs 7, 8): changes to AA1.01 KIA reflect 3HVR-HVU1A (1 B) auto stopping when the Rating: 3.6/3.6 associated exhaust fan was taken to stop previously. This changed the associated standard and made these steps non-critical.

ES-301 Operating Test Review Worksheet Form ES-301-7 JPM Step 16 (pg 11 ): changed to reflect candidate likely closing the CTMT Purge Valves in this sten 4 secondary Heat Removal from Reactor IN-PLANT JPM I - P.1 /

Core Cross-Connect Service KIA Number:

Water To East s

Switchgear Ventilation 076-K1.19; KIA Rating: 3.6/3. 7 APE 068 AA1.21 KIA Ratina: 3.9/4.1 6

Electrical IN-PLANT JPM J - P.2 /

Locally Starting An K/A Number:

Emergency Diesel EPE-055-E Changed task standard (pg 3)

Generator EA1.02; KIA Rating: 4.3/4.4 8

Plant Service IN-PLANT JPM K-P.3 /

Systems Establish Feed and Bleed KIA Number:

s on SI Pump Cooling APE-056-AA1.11; KIA Ratina: 3.7/3.7

ES-301 6

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 (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 7

Form ES-301-7 Facility: Millstone 3 Scenario: 1 Exam Date: September 9, 2019 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 Changes resulted from PRE validation run on new THOR model, 2 procedure changes, and NRC validation run. Changed IC number from 13 to 91 (same 100% power level) and embedded malfunctions into IC-91 (rather than load a separate schedule). Additionally, added TS titles to TS calls (throughout guide).

On page 4, removed EAL entry (not tested as part of simulator scenario).

On page 10, removed SGR01 thru SGR04 (draining SG's at 1%/min). This was a remote to speed entry into Bleed and Feed (B&F); however, it is not an expected condition (& wasn't needed during validation to promote B&F entry).

On page 12, corrected typo on general note 2 (T/S 3.7.1.4 vice 3.7.1.6).

1 thru 6 E

On page 15-16, AOP 3581 rev. 6 changes incorporated into sim guide.

On page 19 (second row down), corrected expected plant response to one CTMT vacuum pump running.

On page 23, changed general note 1 to reference trigger 4 (not 5) (typo correction). Also, removed reference to draining of SG's at 1 % / min.

On pages 27, 30, removed reference to draining of SG's at 1% / min.

On page 29 (second row down), corrected typo to RNO 4i2. "PROCEED TO step 5" (was missing letter 5).

On page 34, made minor changes to turnover sheet (THOR model has slightly different rod height, boron concentration, MWe).

On page 35, chanaed to current revision of E-0 and AOP 3581.

ES-301 8

Form ES-301-7 Facility: Millstone 3 Scenario: 2 Exam Date: September 9, 2019 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 Changes resulted from PRE validation run on new THOR model, 2 procedure changes, and NRC validation run. Changed IC number from 81 to 92 (power level changed from 74 to 75%) and embedded malfunctions into IC-92 (rather than load a separate schedule).

Additionally, added TS titles to TS calls (throughout guide).

On page 4, removed EAL classification (not part of scenario evaluation). Additionally, broke out Event 4 into Event 4 thru 6. Changed Event 5, 6 & 7 to Event 7, 8 & 9.

On page 5, changed ES-D-1 event numbering (as explained in above bullet).

On page 6, changed Transient and Event Checklist iaw with above changes to event numbering.

1 thru 9 E

On page 16, revised MVAR guidance.

On page 19, changed gal of BA per% power from 31.56 to 28.59 (& made resultant changes to expectant boration calc).

On page 22, changed severity 14 to 16 in general note 1 (typo correction).

On page 36, added Examiner Note to end the simulator while in E-0 (if desired).

On page 39, made minor changes to turnover sheet (THOR model has slightly different rod height, boron concentration, MWe). Additionally, clarified turnover on why plant is at reduced power.

On page 40, changed to current revision of E-0 and AOP 3581 (non-consequential to scenario). Also, added ARP MB7C.

ES-301 9

Form ES-301-7 Facility: Millstone 3 Scenario: 3 Exam Date: September 9, 2019 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 Changes resulted from PRE validation run on new THOR model, 3 procedure changes, and NRC validation run. Changed IC number from 82 to 93 (power level changed from 60 to 65%) and embedded malfunctions into IC-93 (rather than load a separate schedule).

Additionally, added TS titles to TS calls (throughout guide).

On page 4, removed EAL classification (not part of evaluation).

On page 13, corrected typo ("RCS-Ll460A")

On page 18, added possible TS call for PZR level.

On page 19, corrected typos (announces IA for SG level vice Chg event).

On page 20, corrected expectant pump dp to -120 psid.

On page 21, correct typo ("PT544A").

On page 22, corrected expectant pump dp to -120 psid.

On page 24, corrected typos ("TS3.3.3.5 I TS 3.3.3.6")

1 thru 7 E

On page 26, removed last sentence in cue "Once power is stabilized, start preparing to remove "A" TDMFP from service."

On page 28, minor change to boron calculation (due to power level change).

On page 32, corrected expectant flow path if SI has actuated (Examiner Note 2).

On page 35, corrected typo in header of Event 6 ("CIA").

On page 39, added clarification to end of General Note 2 (not acceptable to isolate AFW unless AFW flow is below 5% ).

On page 43, added clarification that the critical task is to isolate the AFW flowpath.

On page 44, made minor changes to turnover sheet (THOR model has slightly different rod height, boron concentration, MWe). Additionally, clarified turnover on why plant is at reduced power. Removed 24E status.

On page 45, changed to current revision of E-0, AOP 3581, ARP MB3A (non-consequential to scenario).

ES-301 10 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, 0.5.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, 0.5.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 11 Form ES-301-7 Facility:

Millstone 3 Exam Date: September 9, 2019 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

6 0

2 0

2 0

0 s

2 9

0 2

0 3

0 0

s 3

7 0

2 0

2 0

0 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 + 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 12 Form ES-301-7 Site name: Millstone 3 Exam Date: September 9, 2019 Admin.

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

Total Total Unsat.

9 0

11 1

3 0

23 OPERATING TEST TOTALS Total Total Edits Sat.

Explanation 8

9 See above 8

10 See above 3

3 See above 19 22 4.3%

Operating Test Submittal is SAT 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 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.