ML20056C601

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ES-301-7_Redacted Version
ML20056C601
Person / Time
Site: Byron  Constellation icon.png
Issue date: 12/16/2019
From: Joseph Demarshall
NRC Region 1
To:
Exelon Generation Co, NRC/RGN-III/DRS/OLB
Demarshall J
Shared Package
ML17214A840 List:
References
50-454/19-01, 50-455/19-01 50-454/OL-19, 50-455/OL-19
Download: ML20056C601 (16)
v • d • e


Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Byron Exam Date: October 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.

RO A1: Perform Shutdown Margin Calculation Conduct of Ops K/A:

G2.1.37 1

3 U

S NRC:

Minimal difficulty - determine SDM from 557°F to 500°F only requires applicant to determine minimum boron concentration. Recommend having applicant determine SDM from 500°F to a lower temp, (300°F?) to enhance the difficulty.

Facility:

JPM rewritten with a 500°F cooldown, but such that the SDM is not adequate (requiring evaluation of reactivity worth of boron, samarium, rod worth, etc).

RO A2: Establish Clearance Boundary for 0A FP Pump Equipment Control K/A:

G2.2.13 3

E S

NRC: Drawing references should be provided in the applicable 4030 and P&ID books (i.e. dont give the applicant specifically the sheets required).

The JPM guide does not specify that the tagging sequence is critical; sequence is only stated via a NOTE. Is the sequence critical?

Facility:

Tagging sequencing marked as critical RO A3: Change RMS Setpoints in Preparation for Unit 1 Containment Release Radiation Control K/A:

G2.3.5 3

E S

NRC:

Procedure will need a pen and ink change prior to providing to applicant (Step 11 on page 9 - there is no save option at this step).

Facility:

Pen & Ink procedure revision to be provided to applicants.

NRC: Confirmed Pen & Ink procedure revision on Administered JPM.

RO A4: Respond to a Diesel Generator FOST Fire Alarm Emergency Plan K/A:

G2.4.27 3

S SRO A1:

Evaluate License Holders Status Conduct of Ops K/A:

G2.1.4 2

X E

S NRC:

NSO 1 and 2 are not qualified for the same reason.

Should have some variety as to why theyre not qualified - the two critical steps in the JPM are critical for the same reason. Recommend variation, such as one NSO not qualified due to the 56-hour watch requirement and the other has an expiring medical.

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility:

NOTE 2 associated with NSO #2 revised to address the fact that NSO #2 is qualified to perform watchstanding duties based on the NSO License Maintenance Record information. Changed NSO #4 to have exceeded biennial medical exam frequency.

SRO A2:

Review/Approve a Shutdown Margin Calculation Conduct of Ops K/A:

G2.1.37 1

3 U

S NRC:

Minimal difficulty - determine SDM from 557°F to 500°F only requires applicant to determine minimum boron concentration. Recommend having applicant determine SDM from 500°F to a lower temp, (300°F?) to enhance the difficulty.

Facility:

JPM rewritten with a 500°F cooldown, but such that the SDM is not adequate (requiring evaluation of reactivity worth of boron, samarium, rod worth, etc).

NRC:

1) Completed key needs to be provided to enhance evaluation
2) Identifying the errors in performance step 8, 10, 11, 13 and 15 should also be critical steps.

Facility:

1) Key provided as requested.
2) Steps 8,10,11,13,15 all marked critical.

SRO A3:

Complete a Plant Barrier Impairment Permit Equipment Control K/A:

G2.2.21 E

S NRC:

1) As written, all information listed in critical steps 2, 3, 4, and 7 is critical. All information may not need to be considered critical. Additionally, steps 11 and 12 should be critical.
2) Initiating cue should be simplified to state Determine if a Plant Barrier Impairment (PBI) exists and if so, complete the PBI permit.

Facility:

1) Critical parts of steps 2,3,4,7 have been denoted by closed bullets. Step 11 marked as critical. Step 12 remains non-critical, as based on discussion with NRC.
2) Initiating cue rewritten as suggested.

SRO A4:

Authorize Containment Entry Radiation Control K/A:

G2.3.13 2

X X

E S

NRC:

1) Due to the relatively simplistic nature of the JPM, the applicant should be expected to complete the 1BOL PC-1 as well. If the applicant is completing the checklist, they should also be prepping the BOL paperwork. Would need a completed BOL as a key and what in the BOL is considered critical.

ES-301 Operating Test Review Worksheet Form ES-301-7

2) A key version of BAP 1450-T2 should be provided, with how the applicant is expected to mark the checklist.

Facility:

1) 1BOL PC-1 added to JPM, with a critical step to determine the correct condition of the LCO.
2) keys provided.

SRO A5: Perform Follow-up PARs for a GE Emergency Plan K/A:

G2.4.44 3

X U

S NRC:

JPM does not match the outline to perform follow-up PARs. The JPM requires the applicant to classify the event and complete the NARs form.

Facility:

JPM rewritten to perform followup PARs.

NRC:

1) Revise initiating cue to As Shift Emergency Director, perform any required actions due to the changes in meteorogical data
2) Marked up copy (key) of the NARs form should be provided.
3) Revise JPM to include a cue for the second of two (12 minutes) Time Critical Actions (TCAs).

Facility:

1) Cue revised.
2) Key provided.
3) JPM revised to include a cue for the second of two TCAs.

1 Simulator/In-Plant Safety Function and K/A JPMs Sim A: Perform partial 1BOSR 1.4.2-1 Moveable Control Assemblies Qtly (Alt Path - two control rods fully drop, requiring Rx trip)

SF 1 K/A: 014 A2.03 3

S NRC:

Delete the word On in the task standard.

Facility:

Correction made Sim B: Isolate SI Accumulators per 1BCA-1.1 Step 26 (Alt Path - two discharge valves fail to close requiring venting)

SF 2 K/A: 006 A4.07 3

X E

S NRC:

1) Applicants cue sheet does not match examiners cue sheet.
2) Revise task standard to read Applicant performs 1BCA-1.1, Loss of Emergency Coolant Recirculation, step 26, to isolate SI accumulators and vent the accumulators with failed open

ES-301 Operating Test Review Worksheet Form ES-301-7 discharge valves, in accordance with the specified standards.

Facility:

1) Fixed cue sheet.
2) Revised task standard Sim C: Establish and Secure Normal RH Letdown Flow SF 3 K/A: 006 A4.04 3

E S

NRC:

1) JPM title should read Establish RH Letdown Flow and Secure Normal Letdown
2) From the task standard, delete such that all critical steps are completed for consistency with other task standards.

Facility:

1) Fixed title
2) Fixed task standard.

Sim D: Synch Main Generator per 1BGP 100-3 Step 27 (requires raising turbine speed per BOP EH-13)

SF 4s K/A: 045 G2.2.44 3

X E

S NRC:

1) Add a cue to provide the applicant BCB-1 Fig 20a if the applicant asks to review reactive loading.
2) Is reactive load within the BCB-1 Fig 20a limits upon the synch (is the applicant having to adjust reactive load a critical step)?
3) From the task standard, delete such that all critical steps are completed for consistency with other task standards.

Facility:

1) Cue not required to provide the applicant with BCB-1 Fig 20a. BCB will be available for the applicant to review as necessary.
2) Reactive load is within limits upon synch. Step is non-critical.
3) Correction made to task standard.

Sim E: Start RCFCs in Low Speed (Alt Path -

SX Valves not Open)

SF 5 K/A: 022 A4.01 3

S Sim F: Unload a DG that is Paralleled to the SAT SF 6 K/A: 064 A4.06 S

Sim G: Respond to Power Range Channel N41 Failure by Bypassing Associated Bistables SF 7 K/A:

E S

NRC:

In the initial conditions, specify which unit, i.e. Unit 1 is in Mode 1, rather than The Unit is in Mode 1.

Facility:

Correction made to initial conditions.

Sim H: Start Standby CW pump per BOP SF 8 K/A:

E S

NRC:

1)Typo in the JPM title BOP CWS-1

ES-301 Operating Test Review Worksheet Form ES-301-7 CW-1 (discharge valve fails to open)

2) Consider adding evaluator note to the effect of BAR 1-17-C13 provides direction to trip the CW pump with the discharge valve failing to open.

Applicant may elect to allow the CW pump to run in that condition until annunicator 1-17-C13 is received and subsequent actions taken.

Facility:

1) Correction made.
2) Note added.me to pump damage is unknown.

I/P K: Local Operation of SG PORV SF 4p K/A: WE13 EK3.3 3

S I/P J: Local Control of the

_AF005A-D at the Remote Shutdown Panel SF 4s K/A: 061 G2.1.30 3

S I/P I: Perform Manual Makeup to the U2 CC Surge Tank per BOP CC-17 SF 8 K/A: 008 A1.04 3

S

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:

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 7

Form ES-301-7 Facility: Byron Scenario: 1 Exam Date: October 2019 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Actions Verifiable actions LO D

TS CTs Scen.

Overlap U/E/

S Explanation 1

Start standby CD/CB Pump S

2 Raise power to 50%

S NRC: It does not appear that the crew is directed to raise power at any specific rate in the turnover information, yet 2.2 MW/min is listed in Event 2 in the D-2. Is the crew expected to ramp at this rate?

Facility: 2.2 MW/min is a REMA directed ramp rate.

3 1PT-534 fails high X

S 4

1PK-455C PZR Spray controller fails (PORV opens)

S 5

1CC685 spurious closure X

S 6

1A CV Pp trip (req L/D isolation, manual trip)

X X

S 7

ATWS X

S NRC: Does the TCA apply to tripping RCPs in this situation? RCPs should not be tripped > 5% per the ATWS bases. The crew should trip RCPs within 10 minutes of a loss of thermal barrier cooling, however, the ATWS mitigative strategy delays that response. Is the CT to trip RCPs upon verification that the Rx is subcritical? Is the 10-minute requirement from the time the Rx is subcritical (which appears to be a rather lengthy duration w/o seal cooling)?

Facility: TCA begins when all seal cooling is lost. This is irrespective of the ATWS conditions.

8 Uncontrolled RCS C/D (SD controller fails high in auto)

S

ES-301 8

Form ES-301-7 Facility: Byron Scenario: 2 Exam Date: October 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

Perform 1BOSR FW-M4, 1A FW Pump AOP Test S

2 1LI-459 PZR level channel fails low X

S 3

1PT-505, Turbine Impulse pressure channel fails low X

S 4

Spurious Phase A isolation (1SD005C fails to close)

X S

NRC: 1) On page 17, add LCO 3.6.3 under RF 6c for Condition C (RAs C.1 and C.2)

2) Add LCO 3.3.2 Cond C (Function 3a) to scenario summary on page 3.

Facility:

1) Correction made
2) Correction made.

5 6A FW Htr string leak requiring turbine load reduction X

E S

NRC: D-2 guide is not clear on what substantiate actions the BOP will perform to receive component malfunction credit.

Facility: BOP will receive component malfunction credit for Event 5 by determining need to perform prompt action and initiating turbine runback to < 1050 MW. ATC will receive reactivity credit for Event 6. BOP will not receive credit for reactivity manipulation (or normal) due to credit for Event 5.

6 Borate for ramp down <

1050 MW S

NRC:

1) BOP can receive a Normal bean for this evolution.
2) D-2 guide has 1159 MW as the operational limit IAW BOP HD-6T1, whereas, the expected ramp value is 1050 MW. Why is there a difference?

Facility:

1) Normal credit not be given as discussed at Pre-OV.
2) 1159 MW is the BOP HD-6T1 limit, however, the prompt operator action is limited to 1050MW due to margin.

7 SBLOCA inside Cnmt X

S 8

X S

ES-301 9

Form ES-301-7 A-Train SI failure (SI, RH, AF pumps fail to start)

ES-301 10 Form ES-301-7 Facility: Byron Scenario: 3 Exam Date: October 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

Perform Turbine Oil check BGP 100-2 Step 24 S

2 Raise power to > 5% to enter Mode 1 S

3 VCT level channel 1LI-112 fails high S

4 RCS Thot RTD fails high (manual control of PZR leve)

X S

5 AB flooding from SX return header (loss of both A-train SX Pumps)

X XX E

S NRC: 1) Does the crew need a cue that the 2A SX pump has tripped off (when the 1A SX pump trips)?

2) Does the 2B SX pump need an auto-start defeat? I.e. if the crew fails to start the 1B SX pump altogether, will the auto-start of the 2B SX pump mitigate the transient?

Facility: 1) This will be evident by lowering SX header pressure on both Units.

Communication will be made to the crew announcing the loss of SX on Unit 2.

2) Auto-start is defeated.

6 Dual unit LOOP due to lightning strike, Bus 242 fault, 1A DG Lockout S

7 1B DG fails to start (auto or manual) - Loss of all AC (1B DG starts on SI actuation)

X S

ES-301 11 Form ES-301-7 Facility: Byron Scenario: 4 Exam Date: October 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

Perform partial 1BOSR 3.G.4-1 TV/GV Surv S

2 PZR PORV 456 Leak -

requires isolating 1RY8000B X

E S

NRC: Is LCO 3.4.13 not applicable with the size of the leak rate?

Facility: Yes, but it is not identifiable/quantifiable based on the duration of the leak. The crew would have to be perform an RCS leak rate to determine the actual leak rate, which would require stabile plant conditions for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The crew may still identify the TS applicability, however, they may have no indications of quantifying the leak rate depending on how quickly the PORV is isolated. Evaluator Note added.

3 1C HD Pp trip S

4 1B DG inadvertent auto-start with 1SX169B failing to open X

X E

S NRC: 1) Crew will have to secure from MCR to get credit for the failure (D-2 p.16 allows crew to secure 1B DG from MCR, or direct EO to secure locally, per BOP DG-12.

2) Include evaluator cue for BAR 1PL08-1-D1, DG operating with 1SX169B not full open.

Do we need to provide this cue to the crew? Provide them with the BAR so they make the decision to trip the DG?

3) CT should be a TCA and should be bounded with a 5-minute requirement to secure the DG with no cooling water supply (UFSAR section 8.3-25). Equipment damage is vague and bounding conditions are necessary.

Facility: 1) Communication added to prevent EO from accessing DG room until DG is secured

2) BAR will not be provided to the crew, as determined during Pre-OV.
3) CT is not a specific TCA as it is bounded by the loss of all SX TCA. CT bounding condition was changed to 20 minutes based on information provided to the exam team, the bounding condition will be set at 20 minutes (engineering change evaluation EC352244).

5 1A HD Pp trips (turbine runback to 780 MW)

S 6

U1 BAT Pump trips during runback (swap to U0 BAT Pp)

S 7

DC Bus 112 fault (manual Rx trip - loss of main FW)

S

ES-301 12 Form ES-301-7 8

Automatic & Manual turbine trip failure S

9 LOAF - 1A AF auto-start failure. Shaft shear upon starting. 1B AF Pp lockout (1BFR H.1, bleed and feed)

X S

ES-301 13 Form ES-301-7 Facility: Byron Scenario: 5 (Spare)

Exam Date: October 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

ES-301 14 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 15 Form ES-301-7 Facility: Exam Date:

Scenario 1

2 3

4 5

6 7

8 11 Event Totals Events Unsat.

TS Total TS Unsat.

CT Total CT Unsat.

% Unsat.

Scenario Elements U/E/S Explanation 1

8 0

3 0

2 0

0 S

2 8

0 3

0 2

0 0

S 3

7 0

2 0

3 0

0 S

4 9

0 2

0 2

0 0

S 5

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 16 Form ES-301-7 Site name: Exam Date:

OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

3 5

6 Sim./In-Plant JPMs 11 0

5 11 Scenarios 5

0 4

5 Op. Test Totals:

25 3

14 22 12 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).
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