ML20072P557
| ML20072P557 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/27/2020 |
| From: | Gregory Roach FirstEnergy Nuclear Operating Co |
| To: | NRC/RGN-III/DRS/OLB |
| Roach G | |
| Shared Package | |
| ML19121A156 | List: |
| References | |
| Download: ML20072P557 (13) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: DAVIS BESSE Exam Date: February 3 - 14, 2020 Admin JPMs 1
2 3
Attributes 4
Job Content 5
6 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.
SRO-A1.1 Conduct of Operations 2.1.23 3
X E
S NRC: KA listed on 301-1 form is not the same as the KA called out on the JPM Worksheet.
Response: Updated the ES 301-1 SRO form with corrected K/A number.
NRC: JPM is satisfactory after changes made.
SRO-A1.2 Conduct of Operations 2.1.4 2
X X
E S
NRC: For performance step 2, reactivated licenses being automatically active at the start of the next quarter is specifically addressed in NT-OT-01007, step 6.1.10.d.5 not in DBBP-TRAN-0014 as the performance standard indicates.
Response: Changed standard from DBBP-TRAN-0014 to NT-OT-01007, step 6.1.10.d.5 NRC: JPM is satisfactory after changes made.
SRO-A2 Equipment Control 2.2.12 2
S NRC: None.
SRO-A3 Radiation Control 2.3.6 2
S NRC: None.
SRO-A4 Emergency Procedures/Plan 2.4.41 3
X U
S NRC: Performance step 10 should be listed as a critical step as the Notification Form (DBEP-010) as a minimum must be accurately filled out to ensure an effective notification of state and local authorities is made.
TIME CRITICAL Response: Changed step 10 to critical step.
Identified check box for Drill or Actual Emergency as not critical to eliminate possible candidate confusion NRC: JPM is satisfactory after changes made.
RO-A1.1 Conduct of Operations 2.1.23 2
X E
S NRC: Recommend a small range of acceptable answers for performance step 6 (4578 to 4578.3) and performance step 7 (27826.7 to 27827) in the event the applicant does not round to the whole gallon.
FREE SAMPLE
Response
ES-301 Operating Test Review Worksheet Form ES-301-7 Agree, the ranges for step 6 and 7 were modified to allow for rounding of the calculated values. Span is in whole numbers NRC: JPM is satisfactory after changes made.
RO-A1.2 Conduct of Operations 2.1.25 3
X E
S NRC: Add non-critical step to sign and date as individual performing the calculation prior to JPM termination.
Response: Added step 11 as recommended.
NRC: JPM is satisfactory after changes made.
RO-A2 Equipment Control 2.2.37 3
X X
U S
NRC: Why is performance step 3 not critical?
CC127 appears to be a stop check valve similar to CC128 according to the print and CC127 is critical to close.
Have applicants identify and retrieve appropriate mechanical drawings for task instead of examiners providing them at start of JPM.
Response: Identified CC128 closed as a critical step.
Having applicants identify and retrieve will prevent group setting and require one at a time performance - recommend providing a series of plant drawings that the candidate must select from, versus a complete set of drawings.
NRC: JPM is satisfactory after changes made.
Group of drawings provided for exam validation were appropriate.
RO-A3 Radiation Control 2.3.5 2
S NRC: None.
ES-301 Operating Test Review Worksheet Form ES-301-7 LOD (1-5)
I/C Cues Critical Steps Scope Overlap Perf.
Std.
Key Minutia Job Link U/E/S Explanation Simulator/In-Plant Safety Function and K/A JPMs S1 1
004 A4.06 004 A4.12 2
X E
S NRC: Performance standard for step 4 depresses closed on HIS MU10B. The performance standard appears to incorrectly state that the applicant should verify that the GREEN light turns OFF and the RED light turns ON. With the valve going closed, the applicant should verify the GREEN light turns ON and the RED light turns OFF.
Since it would be acceptable for the applicant to place Demin 2 back in service and transfer MU11 to the MUT, include optional performance steps, with performance standards covering DB-OP-06001, steps 4.3.11.d.1 and 4.3.11.d.2 on the Job Performance Measure Worksheet. Indicate the steps are not applicable if the applicant isolates letdown per the annunciator response procedure.
FREE SAMPLE
Response
(1) Agree, the valve indication should be reversed, this was a typographical error, fixed.
(2) The applicant cannot return to the original flowpath as valve MUI11 is failed. An explanation was added to the JPM to remind the evaluator of the plant condition.
NRC: JPM is satisfactory after changes made.
S2 2
013 A4.02 2
X E
S NRC: Procedure being completely marked up for the applicant provides cues as to steps to perform and lowers the LOD of the JPM.
Response: Changed to only the first 3 prerequisite steps leading up to where the JPM starts being signed in advance.
NRC: JPM is satisfactory after changes made.
S3 4S 076 A2.01 2
X E
S NRC: Remove the word verify in Performance Step
- 1. The applicant must actually close the valve to adequately complete the task.
Response: Removed verify. Changed to Close NRC: JPM is satisfactory after changes made.
S4 4P 005 A2.04 2
S NRC: None.
ES-301 Operating Test Review Worksheet Form ES-301-7 S5 5
026 A2.03 2
S NRC: None.
Simulator/In-Plant Safety Function and K/A LOD (1-5)
I/C Cues Critical Steps Scope Overlap Perf.
Std.
Key Minutia Job Link U/E/S Explanation S6 6
062 A4.01 2
S NRC: None.
S7 7
012 A4.03 2
S NRC: None.
S8 8
008 A4.01 2
X X
E S
NRC: Cue in performance step 6 is unnecessary. Applicant should be able to assess whether there is an expected alarm and respond appropriately.
Performance step 8 incorrectly calls CC5097 CCW Line 2 Return Isolation. It should be CCW Line 1 Return Isolation.
Response: Removed cue, fixed valve designation NRC: JPM is satisfactory after changes made.
P1 4S 039 A4.01 040 AA1.03 2
X X
U S
NRC: Performance step 1 is unclear as to whether the applicant actually simulates adjusting setpoint.
Cue seems to indicate that we should tell the applicant that the setpoint for the PIC 1650 has been set to zero, yet this is a critical step. Follow on cues indicate only show the internals of the PIC if we are asked.
Procedure has the operator isolate steam from the Aux boiler by closing AS40 or AS42. Why is this step not included in the JPM?
Response: Clarified step 1 and made step not critical due to this is just a controller setpoint for the reducer and the manual isolation to the reducer will be closed in the next step.
NRC: JPM is satisfactory after changes made.
Steps for AS40 and 42 not included as they are not accessible and would not be critical to isolating the steam leak.
ES-301 Operating Test Review Worksheet Form ES-301-7 P2 5
067 AA2.17 2
X S
NRC: What purpose do performance steps 1-3 have with regards to completing the task standard (i.e why are they not critical, yet require verifiable action to complete the procedure)?
Response: The Task Standard is specific to aligning Service Water to CAC 1. Step 1 is related to CAC 3 which is not running and steps 2 and 3 are related to preventing the consequence of the motor inlet valves repositioning due to fire. Not completing any of these first 3 steps would not prevent completing the Task Standard as written.
(discuss having the first step completed by someone else since it is not in the aux building and not critical)
NRC: JPM is satisfactory as originally constructed.
P3 8
086 A4.05 2
S NRC: None.
ES-301 4
Form ES-301-7 Instructions for Completing This Table:
Check or mark any item(s) requiring a comment and explain the issue in the space provided using the guide below.
- 1.
Check each JPM for appropriate administrative topic requirements (COO, EC, Rad, and EP) or safety function requirements and corresponding K/A. Mark in column 1.
(ES-301, D.3 and 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 5
Form ES-301-7 Facility: DAVIS BESSE Scenario: 3 Exam Date: February 3 - 14, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1
S 2
X S
3 X
S 4
X S
5 S
BOP - Manual FW flow re-ratio following failure to auto re-ratio, subsequent to trip of 1-1 RCP 6
X S
7 X
X S
ATC - Throttle HPI/MUP to control pressurizer level during overcooling event 8
S BOP - Manual initiation of SFRCS following failure to auto actuate 8
0 0
0 0
2 2
6 S
ES-301 6
Form ES-301-7 Facility: DAVIS BESSE Scenario: 4 Exam Date: February 3 - 14, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1
S 2
X S
3 X
U S
NRC: Without establishing the alternate make up pathway (this is listed in the D-2 as a possible option for the crew) how will increasing RCP seal injection with a limit of 10 gpm per RCP enable letdown to be reestablished at 70 gpm without adversely impacting pressurizer level? The D-2 is written with the actions for isolating MU32, lower letdown flow, increase RCP seal injection with limitations, and then restore letdown. This does not appear to balance flows by the end of the event.
ATC - Manual control of letdown flow control to maintain pressurizer level Response: Removed steps in the guide to restore letdown to 70 gpm. This would only apply if the alternate injection line was placed in service per attachment 4, which was not done during validation.
NRC: Event is satisfactory with changes made.
4 X
E S
NRC: SM cue informing crew that the completion and review of DB-SC-03023, Off-Site Sources will be completed by another operator should only be provided if crew recognizes that the Technical Specification required actions necessitate the performance of this procedure.
Response: Changed to a booth cue and added, If asked,.
NRC: Event is satisfactory with changes made.
5 S
BOP - Manual start of emergency bearing lube oil pump for MFPT#2 6
X S
7 X
S 8
X S
ATC - Manual control of RCS pressure by cycling pressurizer heaters and vent. Manual control of pressurizer level with MU and HPI throttled.
8 1
0 0
0 2
2 7
E S NRC: Scenario is satisfactory with changes made.
ES-301 7
Form ES-301-7 Facility: DAVIS BESSE Scenario: 5 FREE SAMPLE Exam Date: February 3 - 14, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1
X E
S NRC: In scenario 3, event 3 T.S. 3.7.5 is also the expected TS call for a loss of the Motor Driven Feed pump. Ensure SRO making call does is not the same applicant for both scenarios.
Response: Modified Scenario #3 to replace the oil leak of the Aux Feedwater pump with an oil leak on a Containment Spray pump, which is a different Tech Spec.
NRC: Concerns addressed. Event is satisfactory.
2 S
BOP - Manually starts SAC 1 following failure to auto start 3
X S
4 X
E S
NRC: In quotation marks include specific cue from Shift Manager directing crew to place RPS channel in bypass, test module in test operate, and ICS in auto to ensure equity between crews.
Response: Agree, determined that the cue is not necessary based upon the validation, cue has been removed.
NRC: Concern addressed. Event is satisfactory.
5 S
6 X
E S
NRC: CT-17 requires isolating the overcooling event within 10 minutes of steam generator (S/G) pressure 630 psig. Explain in more detail the specific design basis for this barrier criteria.
Response: Added verbiage to the last page of the scenario to state the basis for the criteria.
NRC: Concerns addressed. Per procedure DB-OP-02000, this is a time critical action. Event is satisfactory.
ATC - Manual control of pressurizer level and pressure during overcooling event with PZR spray and throttling MU.
7 X
E S
NRC: CT-16 requires controlling FW flow to the affected S/G within 10 minutes of S/G pressure 630 psig. Explain in more detail the specific design basis for this barrier criteria.
Response: Added verbiage to the last page of the scenario to state the basis for the criteria.
NRC: Concerns addressed. Per procedure DB-OP-02000, this is a time critical action. Event is satisfactory.
8 X
E S
NRC: D-2 pages 7-9 should include event 8 at the top. Presently, they only list events 5-7.
Event 8 required actions are listed in this portion of the document.
In event termination criteria, also include pressurizer level steady between 80 -120 inches.
ES-301 8
Form ES-301-7 BOP - Manually controls SG2 level by throttling AFW speed or isolating injection.
Response: (1) The event number was added to the listed pages.
(2) The termination criteria has been modified as recommended.
NRC: Concerns addressed. Event is satisfactory.
8 0
0 0
0 2
3 7
E S NRC: Scenario is satisfactory with changes made.
ES-301 9
Form ES-301-7 Instructions for Completing This Table:
Use this table for each scenario for evaluation.
2 Check this box if the events are not related (e.g., seismic event followed by a pipe rupture) OR if the events do not obey the laws of physics and thermodynamics.
3, 4 In columns 3 and 4, check the box if there is no verifiable or required action, as applicable. Examples of required actions are as follows: (ES-301, D.5f) opening, closing, and throttling valves starting and stopping equipment raising and lowering level, flow, and pressure making decisions and giving directions acknowledging or verifying key alarms and automatic actions (Uncomplicated events that require no operator action beyond this should not be included on the operating test unless they are necessary to set the stage for subsequent events. (Appendix D, B.3))
5 Check this box if the level of difficulty is not appropriate.
6 Check this box if the event has a TS.
7 Check this box if the event has a critical task (CT). If the same CT covers more than one event, check the event where the CT started only.
8 Check this box if the event overlaps with another event on any of the last two NRC examinations. (Appendix D, C.1.f) 9 Based on the 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, pre-identified 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: DAVIS BESSE Exam Date: February 3 - 14, 2020 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 3
8 0
2 0
2 0
0 S
4 8
1 2
0 2
0 8.3 E
NRC: Event realism is challenged by letdown/makeup flow balance following makeup flow controller failure.
5 8
0 2
0 3
0 0
E Instructions for Completing This Table:
Check or mark any item(s) requiring comment and explain the issue in the space provided.
1, 3, 5 For each simulator scenario, enter the total number of events (column 1), TS entries/actions (column 3), and CTs (column 5).
This number should match the respective scenario from the event-based scenario tables (the sum from columns 1, 6, and 7, respectively).
2, 4, 6 For each simulator scenario, evaluate each event, TS, and CT as (S)atisfactory, (E)nhance, or (U)nsatisfactory based on the following criteria:
- a.
Events. Each event is described on a Form ES-D-2, including all switch manipulations, pertinent alarms, and verifiable actions. Event actions are balanced between at-the-controls and balance-of-plant applicants during the scenario. All event-related attributes on Form ES-301-4 are met. Enter the total number of unsatisfactory events in column 2.
- b.
TS. A scenario includes at least two TS entries/actions across at least two different events. TS entries and actions are detailed on Form ES-D-2. Enter the total number of unsatisfactory TS entries/actions in column 4. (ES-301, D.5d)
- c.
CT. Check that a scenario includes at least two pre-identified 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.
2 + 4 + 6 7
In column 7, calculate the percentage of unsatisfactory scenario elements:
(
) 100%
1 + 3 + 5 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 11, 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 14 Form ES-301-7 Facility: DAVIS BESSE Exam Date: February 3 - 14, 2020 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
2 4
3 Sim/In-Plant JPMs 11 1
4 6
Scenarios 3
0 2
1 Op. Test Totals:
23 3
10 10 13 SATISFACTORY SUBMITTAL 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 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).