ML19351E194
| ML19351E194 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/29/2019 |
| From: | Chuck Zoia Exelon Generation Co |
| To: | NRC/RGN-III/DRS/OLB |
| Zoia C | |
| Shared Package | |
| ML17164A344 | List: |
| References | |
| Download: ML19351E194 (20) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7
`+Facility: Byron Exam Date: January 2019 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.
RA-1 COO 2.1.43 3
X E
NRC: The answer key provided indicates that steps 1.h and 1.i (steps 9 and 10 on the JPM worksheet) are N/A.
These are considered critical steps with specific values for Sm and Xe to calculate on the JPM worksheet.
Update/align the key with the JPM.
Response
Revised Key to align with JPM.
From O/V:
Added (RRD) to Initiating Cue.
Revised accepted criteria to suggested range for step 7; (-)1425 to (-)1450 pcm.
Revised accepted criteria to suggested range for step 10; (-)2925 to (-)2975 pcm.
RA-2 COO 2.1.31 3
E NRC: Combine steps 13 and 14, and change DETERMINE to DOCUMENT to support the acceptance criteria critical step with a verifiable action.
Response
Revised per comment.
From O/V:
Created KEY and appended as pages 12-14.
Added Note prior to step 2 identifying existence of the key.
Removed Note prior to step 4.
Added Note prior to Step 5 stating that the US may be notified of failed acceptance criteria now or at JPM completion.
Designated step 5 as critical, added closed bullet for US notification, and deleted step 13.
Step 11 revised element for Feed breakers open and available.
Critical steps revised to 1-3 & 5.
RA-3 EC 2.2.41 3
S From O/V:
Revised Initiating Cue as recommended, to determine the isolation boundaries (mechanical and/or electrical) to support repair of the leak.
Revised Initiating Cue as recommended to document recommendations on cue sheet.
Revised Initial Condition to clarify leak location.
Steps 2 and 3, removed CLOSED from identified valves. Only asking for isolation points.
Removed Cue following step 4, request now included in Initiating Cue.
ES-301 Operating Test Review Worksheet Form ES-301-7 Moved Cue following step 5 to a second cue following step 2 as prints/valves may be requested/identified in varying orders.
RA-4 EP 2.4.43 2
X U
NRC: The proper 15-minute time critical action must be associated with the NRC requirement to notify state and local authorities of an emergency declaration IAW 10 CFR 50, APP E, D.3. This time is determined after blocks 1-10 of the NARS form have been read to the state and local authorities. The Performance Indicator (PI) performance standard is tied to the initial roll call time (as the JPM is presently written) and is separate from the requirement to transmit all required information within 15 minutes. Time critical actions must be tied to design basis and/or NRC requirements.
Response
Revised time critical acceptance criteria: from initial roll call complete, to after Block 10 is read to state and local authorities. Moved NOTE to calculate the time to prior to step 7.
Revised task Performance Standard.
From O/V:
Step 6, removed critical step designation and removed second bulleted item.
Moved time calculation Note from prior to step 7 to following step 7.
Added parenthetical statement in step 8 for probable MCR phone extension can be contacted and documented in Block 11 of NARS form.
SA-1 COO 2.1.23 3
X E
NRC: Procedure OU-AP-104, Attachment 9, Page 1 incorrectly directs the operator to page 56 for configuration 4. The correct page is 59. This may cause confusion for the applicant as configuration 4 is the path they must evaluate.
Also, with an RH pump operable, why is step 10 of the JPM NO?
Response
Further validation upon current procedural guidance on page 12 of OU-AP-104 results in an Orange determination for SDC as conservative.
GENERIC: Determine should be Document for critical steps to be verifiable actions.
Response
Response:
Added and document to determine steps.
From O/V:
Added note prior to step 1, Figure 9 in current revision directs correct Configuration but an incorrect page number. Revision to correct to be submitted post-exam.
SA-2 COO 2.1.25 2
X E
NRC: A specific time critical completion value of 30 minutes should be identified and a grading criteria placed into Step 9 of the JPM for the evaluator to
ES-301 Operating Test Review Worksheet Form ES-301-7 acknowledge so that it can be shown whether or not the regulatory requirement (TS action time) was met.
Response
Added Note prior to step 9 for time calculation.
From O/V:
Initial Conditions, removed the word transformer from the sixth open bullet.
Cue prior to step 1, revised to provide the entire 1BOSR 8.1.1-1 vs. just the data sheet. The note and Cue prior to both step 2 and step 7 simplified to continue the review the provided 1BOSR 8.1.1-1 and document any inaccuracies. This eliminates any confusion that may be entered by provide multiple data packages as written based on applicant response.
SA-3 EC 2.2.21 4
S From O/V:
Added to Initiating Cue and clarified in first Note; Passport is unavailable.
Deleted steps 3, 5 and 7 as redundant. Incorporated all the PMT retest procedures required in step 2.
Renumbered subsequent steps.
Clarified Note that is now prior to step 6 on the critical portion of the subsequent steps is to identify the type of test to be performed. Listed BOSRs are supplemental information.
Added Note prior to step 8; Functional Stroke is satisfied by previously identified tests.
Critical steps now numbered 6 & 7.
SA-4 RC 2.3.6 2
S SA-5 EP 2.4.41 3
X E
NRC: The 12-minute time requirement to complete writing up the NARS form is not directly tied to a regulatory requirement or facility commitment to the NRC. Therefore, that aspect of the JPM cannot be considered time critical (without referencing a specific requirement). The 15-minute time critical aspect of classifying the event, however, is appropriate.
Response: NRC: The 12-minute time requirement to complete writing up the NARS form is not directly tied to a regulatory requirement or facility commitment to the NRC. Therefore, that aspect of the JPM cannot be considered time critical (without referencing a specific requirement). The 15-minute time critical aspect of classifying the event, however, is appropriate.
Response
Removed Note prior to step 16 and time critical element from step 16. Reworded task performance standard.
From O/V:
Added additional note ensuring SED binder is available if JPM is performed in classroom.
ES-301 Operating Test Review Worksheet Form ES-301-7 Revised Initial Conditions and Initiating Cue as suggested, incorporating items in Initial Conditions that were in Initiating Cue and shortening cue statement to remove redundancy.
Revised cue following step 12 to Provide screen shot of Met Tower data, now incorporated into the JPM as page 14.
Added back in the Note prior to step 16 for TCA completion time for NARS form completion, now at 15 minutes. Added bulleted item to step 16 to denote completion.
ES-301 Operating Test Review Worksheet Form ES-301-7 1
Simulator/In-Plant Safety Function and K/A JPMs CR-a 1
014A1.01 2
S From O/V:
Removed cues prior to steps 1 and 3 and removed steps 1 and 2.
Added cue to provide a copy of BOP RD-8 with the Initiating Cue.
Revised Simulator Setup for failure to be in on JPM start and removed item for manual event initiation.
Revised Initial Conditions, Initiating Cue and Task Performance Standard such as to limit actions to the performance of BOP RD-8.
Renumbered steps with steps 3, 5 7 & 8 denoted as critical.
CR-b 3
011EA1.11 3
X E
NRC: JPM Step 17 indicates to return to procedure 1BEP ES-1.3. The initiating cue indicated that step 19 of 1BEP-1 was in progress before transitioning to 1BEP ES1.4 per the US. Please align this to the proper procedure in effect.
Response
Revised JPM Step 17 to return to procedure 1BEP 1 per initiating cue. Clarified initiating cue.
From O/V:
Revised Initiating Cue to Notify US when complete.
Added Note to provide a copy of 1BEP ES-1.4 with the Cue Sheet.
Added Step 18 to notify US on completion and of 1SI8802A failure..
Added Cue following step 18.
CR-c 4P 005A4.01 2
X E
NRC: This alternate path JPM ends prior to determining an alternate success path. It would be most appropriate to begin to establish an RH lineup for a loop that ensures RCS integrity when the A RH pump becomes inoperable.
Response
At this RCS temperature, US/operations team when notified will determine course of action. The remaining RH pump will not be placed in service and remain available for injection until RCS temperature is lowered.
From O/V:
Initial Conditions corrected typo; SX pumps plural.
Added Cue prior to step 9, to be provided if applicants state waiting for temperatures to stabilize.
Revised Task Performance Standard clarifying RH Pump Stop criteria.
ES-301 Operating Test Review Worksheet Form ES-301-7 Expanded Note prior to Step 9 including clarification of Task Performance Standard.
CR-d 4S 045G1.20 3
X X
E NRC: Notifying the TSO within 15 minutes is not an NRC regulatory requirement or facility commitment to the NRC per ES-603, page 3. This step being accomplished in 15 minutes can be considered a critical step, but this should not be coded as a time critical JPM.
A copy of BCB-1, Figure 20b should be available for the applicants to use.
Response
Did not locate similar statement for NRC regulatory requirement or facility commitment to the NRC in the initial license portion ES-302 of the NUREG.
Removed Time Critical elements from the Initiating Cue and from the JPM Summary.
From O/V:
Removed second bullet from step 3.
Step 8changedd first standard from open bullet to closed bullet.
CR-e 5
007A1.01 2
S From O/V:
Third Cue prior to Step 2, corrected typo from effedc to affect.
Removed Critical Step designation from step 8.
Removed Cue following step 8.
Step 10 changed first item to an open bullet and revised to < 85%.
CR-f 6
064A2.09 2
S From O/V:
Removed Critical Step designation from step 10.
Moved second bulleted item in step 10 to first bulleted item of step 11.
CR-g 7
016A4.01 2
S CR-h 8
029A1.02 2
S NRC: Requires the simulator operator to enter the fault at the start of venting operations. This should occur right after the time is entered per JPM step 5.
Response
The fault is entered after time is entered in step 5.
The simulator operator likely will not see when this occurs and will rely on the Evaluator to provide a prompt.
From O/V:
Revised Smart Scenario; the fault is now entered automatically on a timer after the three containment isolation valves are open.
Revised Simulator Setup to include revised Smart Scenario and removed item 8 for manual initiation.
Removed Cue prior to step 6 as it is no longer required.
Added Note prior to step 8 specifying acceptable release termination.
IP-i 1
029EA1.12 2
S From O/V:
ES-301 Operating Test Review Worksheet Form ES-301-7 First Cue following step 3, did not incorporate suggestion for adding lamp indication. The control switches are in pullout, thus no lamp indication.
Cue following step 4; revised to still indicate amps, light indication provided.
Added Cue prior to step 5 to provide picture of breaker.
Added additional Cue with lamp indications following step 6.
Added picture of breaker to JPM.
IP-j 3
010A2.03 3
S From O/V:
Added cue prior to step 6; Provide picture of PORV Dummy Fuse Blocks (slugs) for 1RY456 when 1JB5071A is identified.
Revised third cue after step 6 to include PZR heaters are ON.
Added picture to JPM.
IP-k 4S 076A2.01 2
E NRC: JPM Summary page lists this as an Alternate Path JPM. This JPM does not include Alternate Path steps and is not coded as Alternate Path on the ES 301-2.
Response
Removed Alternate Path designation from JPM Summary.
ES-301 8
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 9
Form ES-301-7 Facility: Byron Scenario: 19-1 Exam Date: January 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation From O/V:
Revised turnover information for load increase. To anticipated during the shift.
Instructor Run Guide: Event 8, corrected to verify Loss of ALLL AC automatically inserts instead of manually on Evaluators cue.
1 S
2 X
S From O/V:
Removed: P.2 items from Tech Spec determination.
Removed: the 1B Diesel Generator from Evaluator Note.
3 S
From O/V:
Swapped events #3 and #4 from submitted. Power increase to follow 1B Diesel Generator failure.
Added 1B Diesel Generator to D-1 description.
Changed final Evaluator Note: to read initiate the next event vs. insert the next event.
4 X
S From O/V:
Added 1B Diesel Generator to D-1 description. Swapped events #3 and #4 from submitted. Power increase to follow 1B Diesel Generator failure.
5 X
E NRC: Why are operators expected to place 1CV131 back in automatic following a failure to control in AUTO with no identified/corrected cause?
Response
Removed the placement of 1CV131 in AUTO during letdown restoration per 1BOA ESP-2.
6 X
X E
N16-1, Event 4 NRC: Discuss with licensee TS 3.7.7 for 1A and 1B CC pumps inoperable due to TS 3.8.1 B3 requirement to declare systems inoperable when their EDG is inoperable and their redundant component (1A CC in this case) is inoperable. Is plant in TS 3.0.3?
Response
The plant is not in 3.0.3.
The Completion Time for Required Action B.3 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for
ES-301 10 Form ES-301-7 beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:
- a. An inoperable DG exists; and
- b. A required feature on the other division is inoperable.
In addition, it is predicted that the applicants will align the Unit 0 CC Pump to Bus 141 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery, thus 1B CC pump would not be required to be declared inoperable.
7 S
8 XX X
S Similar to N16-5, Event 8 & N17-2, Event 8 with minor changes.
NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria From O/V:
Pg. 23, Corrected Crew Behavior from, Determine Loss of Off-Site Power has occurred, to Determine Loss of All AC Power has occurred.
Pg. 23 Added to BOP/US behavior for Reset SI the parenthetical statement, (60 seconds after manual actuation).
9 X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria 9
1 0
0 0
3 3
7 E
NRC: See comments above.
ES-301 11 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 12 Form ES-301-7 Facility: Byron Scenario: 19-2 Exam Date: January 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
X S
2 S
3 S
4 X
E NRC: US actions on D-2 form instruct the direction of starting the 1B CC Pump.
The D-2 should say, Direct/ensure BOP attempts a manual start of 1B SX pump 5
S 6
X X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria From O/V:
ATC behavior, relocated ; Maintain RCP seal injection flow above CT bolded statements and revised range to 6-13 gpm.
7 X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria From O/V:
ATC/BOP behavior; CHECK IF RCS IS INTACT: corrected typo, CNMT floor drain sump level - LESS THAN 46 INCHES is now on one line.
Pg. 24 removed Crew Transition statement prior to evaluator note terminating scenario.
8 X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria 8
0 0
0 0
3 3
8 E
NRC: See comments above.
ES-301 13 Form ES-301-7 Facility: Byron Scenario: 19-3 Exam Date: January 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation From O/V:
Changed turnover materials and guide to support only a partial performance of 1BOSR EH-M2.
1 S
2 X
E NRC: On Simulator Run Aid Guide for this event, the instructions, use Smart Scenario to cause 1A RCP #3 Standpipe level low to annunciate. appears to be a typographical error from Scenario 19-2.
Response
Corrected to state ACB 1445BC, Bus 144 to PZR Htr to trip.
From O/V:
Added BOP behavior, open bullet, Recognize/report ACB 1445 Disagreement/Trip light.
3 X
S From O/V:
Corrected typos in BOP behavior.
Added bullet to BOP behavior to Close 1SI8880 upon SI Accumulator fill completion.
Added Open bullet to BOP and US behaviors to Close 1PS9357A and 1PS9357B, SI Accumulator Sample Isolation Valves.
4 X
X E
N17-3, Event 6 NRC: D-2 indicates that the BOP will take manual control of 1CC130 and potentially recover letdown if it is isolated. This component failure is assigned to the ATC with regards to verifiable actions on the D-1, but is not noted as a change on the List of Changes Documentation.
Response
Corrected initial event response to ATC on D-2. BOP may subsequently place excess letdown in service if crew is slow to diagnose failure.
5 S
From O/V:
Added additional crew option to perform a turbine load reduction to operate with the Governor valves off of the full open seat.
Added Evaluator Note, Repeated ATC behaviors for boration Added BOP behaviors to perform load reduction
ES-301 14 Form ES-301-7 In the Instructor/Simulator Run Aid guide; added Shift Manager concurrence to performance of a requested load reduction to operate with the Governor valves off of the full open seat Added open bullet behavior for BOP to Reset C7 Loss of Load.
6 X
S N17-3, Event 8 From O/V:
Added Evaluator Note and US behavior for a POTENTAL TS 3.4.1 DNB TS entry if applicable per transient plant conditions.
7 XX E
NRC: D-2 indicates events 7/8/9 when there are only 8 events in scenario.
Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria
Response
Corrected per comment.
8 X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria 8
0 0
1 0
2 3
6 E
NRC: See comments above.
ES-301 15 Form ES-301-7 Facility: Byron Scenario: 19-5 Exam Date: January 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
X E
N16-1, Event 1 NRC: NSO turnover does not include pending GC pump swap. It is listed on the SM/US turnover.
Response
Corrected per comment.
2 X
X E
Similar to N16-4, Event 5, with minor differences NRC: D-2 incorrectly lists TS 3.3.1 Function 7 as Overtemperature T. It should be Overpower T.
Response
Corrected per comment.
From O/V:
Added open bullet cue for Annunciator 1-9-D3, CHG LINE FLOW HIGH LOW is LIT 3
S From O/V:
Removed from EVALUATOR NOTE; After measurable change in power and 4
X S
5 S
6 S
7 S
From O/V:
Added open bullet cue for Annunciator 1-16-D2, FW PUMP DSCH FLOW HIGH 8
X S
NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria 9
X S
NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria From O/V:
Corrected to as run during validation to reflect simulator model change; noted, on D-1, overview, simulator setup, and ATC behavior on page 20:
control rods fail to minimum speed.
Pg.21; added to ATC/BOP behavior, the RNO steps to Perform following until turbine is tripped as open bulleted items, though Main Steam Line Isolation had been performed earlier.
0 0
0 0
2 2
7 E
NRC: See comments above.
ES-301 17 Form ES-301-7 Facility: Byron Scenario: 19-6 Exam Date: January 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation From O/V:
Reworded scenario termination criteria to align with Evaluator Note (page
- 27) following establishment of Train B of Cold Leg Recirculation capability.
1 S
2 S
3 X
S N17-4, Event 3 From O/V identification:
Changed failure switch for event initiation. This results in the removal of the need for manual actions to override lights/annunciators when clearing.
Corrected on D-1 and on Instructor/Simulator Run Guide.
4 X
S From O/V:
Corrected fault value to100 (high) to match actual failure on D-1 and on Instructor/Simulator Run Guide.
Corrected BOP behavior to Select operable SG level channel and also corrected in Scenario Overview.
Corrected BOP behavior to Identify 1LT-519 failed high.
5 X
S 6
X U
NRC: The action to manually start SX CT fans in High is not IAW the RNO step of 1BEP-0 Attachment B. IF any fan does NOT start in Hi Speed, THEN close its associated riser valve, is the RNO step for all 8 SX CT fans running in HIGH speed. This affects whether this critical task is valid. Also, provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria
Response
Step 10g. of 1BEP 0 Attachment B is to Verify SX Cooling Tower alignment:
- 1)
To satisfy (Verify) All EIGHT riser valves - OPEN, the operator must take manual action to Open riser valves that are currently closed. In this case, 0SX163C and 0SX163D.
- 2)
All FOUR Hot Water Basin Bypass valves - are CLOSED.
- 3)
To satisfy (Verify) All EIGHT SX Cooling Tower Fans - RUNNING IN HI SPEED, the operator must take manual action to Start SX Cooling Tower Fans in Hi Speed that are not currently operating. In this case,
ES-301 18 Form ES-301-7 0SX03CC, 0SX03CD AND 0SX03CG.
The RNO actions do not apply as the fans will be able to be started via operator actions.
Added level of detail for required operator actions to satisfy the CT detailing manual actions required and specifying the individual valves and fans.
Completion of the time critical actions as specified in OP-BY-102-106, Operator Response Time Program at Byron Station, assures the plant complies with the assumptions made during the analysis of design basis events, regulatory committed design events, and events with high PRA significance.
TCA#49 is to Align the SXCT to maximize the heat removal capacity following LBLOCA, and in this case, is implemented by procedure 1BEP-0.
From O/V:
US/BOP behavior; ALIGN RH PUMPS SUCTION TO CNMT SUMPS:
added bullet to Determine ONLY 1B RH Pump RUNNING.
7 X
S NRC: Provide evidence (WOG, EOP Basis, etc.) that CTs meet App. D criteria 8
S 8
0 0
0 0
2 2
7 U
NRC: See comments above.
ES-301 19 Form ES-301-7 Facility: Byron Exam Date: January 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 19-1 9
0 3
0 3
0 0
S 19-2 8
0 3
0 3
0 0
S 19-3 8
0 2
0 3
0 0
S 19-5 9
0 2
0 2
0 0
S 19-6 8
1 2
0 2
1 16.7 E
The action to manually start SX CT fans in High is not IAW the RNO step of 1BEP-0 Attachment B. IF any fan does NOT start in Hi Speed, THEN close its associated riser valve, ris the RNO step for all 8 SX CT fans running in HIGH speed. This affects whether or not this critical task is valid.
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:
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 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.
2 + 4 + 6 1 + 3 + 5100%
ES-301 20 Form ES-301-7 Site name: Exam Date:
OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
1 5
4 Sim./In-Plant JPMs 11 0
4 7
Scenarios 5
1 4
0 Op. Test Totals:
25 2
13 11 8
<20 therefore 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 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).