ML20024E820
| ML20024E820 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/23/2019 |
| From: | NRC Region 1 |
| To: | Exelon Generation Co |
| Shared Package | |
| ML18347A730 | List: |
| References | |
| EPID L-2019-OLL-0039 | |
| Download: ML20024E820 (11) | |
Text
ES-301 Facility:
Ginna (Retake Exam)
Admin JPMs SRO ADMIN A1 - Perform a Critical Rod Position Calculation in accordance with 0-1.2.2 SRO ADMIN A2 -
Determine Operating Limits for Station 13A Transmission in accordance with 0-6.9 SRO ADMIN A3 -
Determine limitations in accordance with A-52.12, Nonfunctional Equipment Important to Safety ADMIN Topic and KIA Conduct of Operations 2.1.25 Conduct of Operations 2.1.32 Equipment Control 2.2.40 2
I LOD '
(1-5) I Operating Test Review Worksheet 3
Attributes 1/C I I Critical I Scope I I Perf.
Cues Overlap Focus Steps (N/B~ _ **...
7
- " Std.
Exam Date: July 23, 2019 4
Job Content Key I Minutia Job Link 5
U/E/S E
E E
Form ES-301-7 6
Explanation Cue prior to Initial Conditions vague COLR Figure was needed by Validator to complete JPM Tolerances throughout JPM are not realistic when interpolating curves JPM Step 25 Standard incomplete Procedure needs a definite end point to give to Applicants On JPM CUE SHEET, add place for Applicant to enter Estimated Critical Position Changed cue prior to Initial Conditions to "Provide Applicant with Initial Conditions/ Cue Sheet and Data Sheet (Last 2 pages of this JPM) and Handouts 1 and 3.
Added COLR Figure COLR-3 as Handout 3 Revised JPM Steps 12, 13, 14, 19, 21, 23, and 25 Added "Bank D" to JPM Step 25 Standard Changed 2nd Initiating Cue to add "through Section 6.8" On JPM CUE SHEET, added place for Applicant to enter Critical Rod Position Current Time in Initial Conditions not consistent between pages 2 and 9 3rd Initiating Cue is confusing for Applicant Assignment of critical steps incorrect Applicant should state Tech Spec LCO entered on CUE SHEET Change Current Time in Initial Conditions on page 9 to 1330 Deleted 3rd Initiating Cue Changed 2nd part of JPM Step 7 to NOT critical; and changed JPM Steps 11 and 12 to critical Added place for Applicant to enter applicable Tech Spec LCO on CUE SHEET EIN in A-601.16 is incorrect leading Applicant to make mistake Operator needs to know duration of maintenance activity to determine contingency actions Applicant needs CC-Gl-118 as reference to determine contingency actions JPM Step 11 Standard is incorrect
ES-301 Operating Test Review Worksheet Form ES-301-7 Changed EIN to other fuel trailer (TB001A) throughout JPM Added "Expected duration 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to Initial Conditions Added CC-Gl-118 as a Handout Revised Standard for JPM Steps 11 and 12 since TB001A is fire risk imoortant JPM can NOT be administered to SRO Applicants at same time Add a Critical Step to NOT sign and approve release permit Current date and time missing from Initial SRO ADMIN A4 - Review Radiation Conditions and Approve Gas Decay Control E
Task Standard lacks details Tank Release Permit 2.3.6 Added Statement to JPM cover page to administer JPM to Applicants one at a time Added Critical Step 6 to JPM to NOT sign and approve release permit Added Current date and time to Initial Conditions Added soecificitv to Task Standard Applicant may question whether EAL declaration SRO ADMIN A5 -
Emergency is correct, Determine Protective Action Recommendations in Plan E
Added "and the EAL declaration has been verified accordance with EP-CE-111 2.4.41 by the STA" to end of last Initial Conditions bullet Added EAL Wallboard as Handout if reauested 2nd Initiating Cue is vague (no clear end point)
Malfunctions are too close to discern deficiency Conduct of 2nd CUE following JPM Step 4 needs to be RO ADMIN A1 - Perform a Operations E
revised Daily Surveillance Log 2.1.18 Changed 1st Initiating Cue to add "pages 1 - 3" Adjusted malfunctions Revised 2nd CUE followina JPM Stec 4 to "88%"
JPM Step 12 needs a tolerance band in the Standard Need place for Applicant to state Actual and RO ADMIN A2 - Calculate Conduct of Required SOM on CUE SHEET SOM for an Operating Operations E
Reactor with a Misaligned Control Rod 2.1.37 Added tolerance band of +/-1 pcm for JPM Step 12 Standard Added place for Applicant to state Actual and Required SOM on CUE SHEET 1st Initiating Cue vague Equipment RO ADMIN A3 - HCO JPM Step 2 Standard needs to be changed to Review of STP-0-36QC Control E
include capturing the transposition error between 2.2.42 procedure and Attachment
ES-301 RO ADMIN A4 - Determine Maximum Reactor Vessel Venting Time Sim ulator/ln-Plant JPMs SIM JPM A - Establish RCS Injection in AP-RCS.4 with Cl Valve Failures SIM JPM B - Transfer 4160V Auxiliary Loads and Take Actions for Loss of Bus SIM JPM C - Defeat Failed RCS Temperature Channel SIM JPM D - Placing L TOP in Service Radiation Control 2.3.11 Safety Function and KIA 2: Reactor Coolant System Inventory I
Control 006 Emergency Core Cooling System (ECCS) [006 A4.01 (4.1/3.9 6: Electrical 062AC Electrical Distribution System [062 A4.01 p.3/3.1 7:
Instrumentation I
012 Reactor Protection System (RPS)
[012 A4.04 3.3*/3.3 3: Reactor I
Pressure Control Operating Test Review Worksheet E
s s
s E
Form ES-301-7 Revised 1st Initiating Cue to 'The US has directed you to perform the HCO/CO review of the procedure and all attachments in STP-0-36QC" Revised Standard for JPM Step 1 to annotate the transposition error Revised Standard for JPM Step 2 for Action Statement 3 applies Applicant needs to know whether a RCS cooldown is in progress Added an Initial Condition bullet "A controlled cooldown is NOT in progress" Multiple instances of "on Service" vice "in service" throughout JPM Changed "on service" to "in service" throughout JPM
ES-301 Operating Test Review Worksheet Form ES-301-7 010 Pressurizer Pressure Control System (PZR PCS)
[010 A4.03 (4.0/3.8)]
4 primary:
Heat Removal From Reactor Core JPM Steps 3 and 4 NOT critical since SI and Cl SIM JPM E - Vent RCS for E
already reset at start of JPM Accumulator/RHR Injection EPE W/E06 Removed Critical Step annotation from JPM Steps Degraded Core 3 and 4 Cooling (EPE W/E06 EA2.2
/3.5/4.1 )1 4 secondary:
Heat Removal From Reactor SIM JPM F - Perform Core Intercept and Reheat Stop 045 Main s
Valve Test with Low EH Turbine System Pressure Generator (MT/G) System
[045 A4.01 (3.1/2.9)]
5:
Containment Integrity SIM JPM G - Secure 026 s
Containment Spray in E-1 Containment Spray System (CSS) [026 A2.08 (3.2/3.7)1 8: Plant Service Systems SIM JPM H - Respond to APE 026 Loss Complete Loss of CCW of Component s
Flow Cooling Water (CCW)[APE 026 M1.02 (3.2/3.3)1 4 secondary:
JPM contains unnecessary/extra Steps Heat Removal IN-PLANT JPM I - Locally From Reactor E
Removed JPM Steps 1 - 4 Close MSIVs Core Added "beginning at Step 2.1" to end of Initiating Cue
ES-301 Operating Test Review Worksheet Form ES-301-7 039 Main and Reheat Steam System (MRSS) (039 A3.02(3.1 /3.5*)1 8: Plant Service Systems IN-PLANT JPM J - Alternate 033 Spent Fuel E
Changed JPM Step 4 and CUE to have Operator SFP Cooling Systems (A to Pool Cooling closing V-8685 to raise flow B)
System (SFPCS) (033 G2.1.29 (4.1/4.0)1 5:
Containment Integrity IN-PLANT JPM K - Locally EPE 009 Small s
Isolate CI/CVI Valves Break LOCA
[EPE 009 EA1.08 (4.0/4.1 )1
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 (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:
D The initial conditions and/or initiating cue is clear to ensure the operator understands the task and how to begin. (Appendix C, 8.4)
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 (8).
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:
o 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: Ginna Scenario:
1 Exam Date: July 23, 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 1
s 2
X X
s 3
X s
4 s
5 X
s 2018 scenario 1, event 5 exam overlap 6
X s
2018 scenario 1, event 7 exam overlap Provide a specific flow rate range for AFW that is necessary to meet X
E this critical task.
7 Solution: Licensee added "50 aom to each" in critical task.
Other Changes:
- 1.
Scripted in LCO 3.4.1 if RCS pressure lowers to < 2175 psig
- 2.
Scripted additional notes
- 3.
Deleted AP-ELEC.1 steps after Step 40.d RNO
- 4.
Deleted scripted actions for manual reactor and turbine trips
ES-301 8
Form ES-301-7 Facility: Ginna Scenario:
2 Exam Date: July 23, 2019 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
s 3
s 4
X s
X u
Missing TS 3.4.17, SG Integrity 5
Solution - Licensee added TS 3.4.17 6
xx s
Two critical tasks associated with SGTR 7
s 8
s
- NOTE: This scenario has no entry into a contingency EOP with substantive actions
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, 8.3).)
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: Ginna Exam Date: July 23, 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
7 0
2 0
2 0
0 s
2 8
0 2
1 2
0 8.3 s
See table above for resolution to unsat TS 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 lOOo/o 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./In-Plant JPMs Scenarios Op. Test Totals:
Ginna Total Total Unsat.
9 0
11 0
3 0
23 0
Total Edits 0
0 3
3 11 Form ES-301-7 Exam Date:
July 23, 2019 OPERATING TEST TOTALS Total Sat.
9 11 3
23 0
Explanation Deleted details about review of Scenario 3 as it was not run during the actual exam.
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.