ML20265A245
| ML20265A245 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/11/2018 |
| From: | Chuck Zoia Operations Branch III |
| To: | Exelon Generation Co, NRC/RGN-III/DRS/OLB |
| Zoia C | |
| Shared Package | |
| ML17164A408 | List: |
| References | |
| 50-373/18-301, 50-374/18-301, RA18-100 50-373/OL-18, 50-374/OL-18 | |
| Download: ML20265A245 (11) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: LaSalle Exam Date: November 2018 1 2 3 4 5 6 ADMIN Attributes Job Content LOD Admin JPMs Topic U/E/S Explanation (1-5) I/C Critical Scope Perf.
and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC: The Technical Specifications should be listed as COO being required for the JPM setup.
A-SRO-39 2 E 2.1.20 Response:
Made change as requested.
COO A-SRO-20 2 S 2.1.18 NRC: Fire Protection Impairment Permit given to the applicant for review lists MMD as the work group in section I. Based on the nature of the work and the expected answer key, the work group should be listed as EC A-SRO-68 2 X E EMD.
2.2.17 Response:
Change made as requested, Added or 1-2 to step 4 standard.
Changed permit coordinates.
RC A-SRO-37 2 S 2.3.4 NRC: Step 18 indicates the applicant should enter code 20 when contacting IEMA. It appears that LaSalle is code 25 based on page 2 of the NARS form.
EP Response:
A-SRO-101 3 X E 2.4.30 Made change as requested.
Added a cue to give time for IEMA response.
Changed second time critical step to time of initial roll call vice completing block 10.
NRC: What are the verifiable actions for the critical steps COO where the applicant checks or determines A-RO-1 3 X E?
2.1.25 something? How is this documented? (GENERIC)
Response: Resolved at OV.
NRC: What are the verifiable actions for the critical steps where the applicant checks or determines something? How is this documented? (GENERIC)
A-RO-46 2 X E?
2.1.5 Steps 2 and 3 are no longer critical.
Changed initiating cue as requested and moved second half of original initiating cue to a cue at the end of the JPM.
NRC: Initial conditions 5th bullet is missing the word be EC preceding 12,500 GPM.
A-RO-48 2 X E 2.2.44 Response:
Made change as requested.
ES-301 Operating Test Review Worksheet Form ES-301-7 NRC: Include the limiting LGA-009 conditions in the JPM Standard.
RC A-RO-47 2 E Response:
2.3.5 Made change as requested.
Added LOA-PR-101 to JPM setup.
1 Simulator/In-Plant Safety Function JPMs and K/A 4
S-RH-29 203000 3 S Added or to step 2 standard.
A4.11 NRC: On JPM summary sheet, indicate that this is not 3 an alternate path JPM.
Response
S-MS-06 239001 2 E Made change as requested.
A2.03 Step 8 is no longer critical based on prep week comments.
NRC: 2nd bullet in initial conditions needs to be corrected as it reads, 1B TDRFP and the Both Feed Reg Valves 2 are in Auto. It should read 1B TDRFP and both Feed Reg Valves are in Auto. Also, consider an earlier exit S-RL-01 259002 2 X E strategy since all critical steps are completed after Step A1.04 6 is performed (OV).
Response
Removed the and added clarifying note.
1 NRC: Acknowledging a confirmatory pop-up message does not seem to be a Critical Step - suggest combining S-RM-02 201002 2 X E with step 8.
K1.08 Response:
6 NRC: Please clarify within the guide how each method is arrived at and performed (OV).
S-AP-08 262001 2 E
Response
A2.07 Removed second WR Pump running bullet.
NRC: The LOR given is for the 1B RHR SERV WTR RAD HI. The applicant is shutting down the 1A RHR heat exchanger. The LOR number also does not 9 correspond to step 4 either (B112 vs. B212) and was probably written for the 1A RHR heat exchanger rad S-RH-28 272000 3 X E monitor.
A1.01 Response:
Made change as requested. Removed step 8 and and added steps to close additional isolation valves (non-critical).
NRC: JPM Summary indicates that the K/A supported is 8 400000 A2.01. This is not the correct K/A as recorded S-WR-02 400000 2 E on the ES 301-2 operating test outline - K/A 400000 A4.01 A4.01 was supposed to be tested. The JPM meets both K/As so this issue can be considered an enhancement.
ES-301 Operating Test Review Worksheet Form ES-301-7
Response
Made change as requested NRC: Initial conditions 4th bullet should read, has been 7 checked. Also, this is actually a New (vs. Modified, as S-RP-05 212000 2 X E the outline indicates) JPM.
A4.07 Response:
Revised JPM to incorporate a surveillance 5
P-PC-06 223001 2 S A2.07 4 NRC: Error message stated with no initial conditions given on paper copy only - possible file error?
P-RH-04 205000 2 X E
Response
A2.03 Made change as requested.
NRC: If intention is to have some applicants perform the 2 jpm on Unit 2, ensure that Attachment 2B is provided.
P-CY-05 295031 3 E Not provided with review packet.
EA1.08 Response:
Changed pressure in cue after step 5.
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: LaSalle Scenario: 1 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.
Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S Change bearing rise to be more steady increase.
S Add additional credit for RR Pump trip (Component Failure) to D-1 2 (BOP).
3 X X S Formatting on TS call change.
4 S NRC: No event termination criteria established.
E Response:
Made change as requested.
5 Removed steps as requested.
6 X S Moved ATC steps to Event 5.
7 X S 8 X S 9 XX S NRC: In addition to initiate Emergency Depressurization, establish RPV level controlled and in band (provide values) and containment pressure
< (provide value) and being controlled as event termination criteria.
X E
Response
10 Made changes as requested.
10 0 0 0 0 2 3 7 E NRC: See above comments.
ES-301 6 Form ES-301-7 Facility: LaSalle Scenario: 2 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.
Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 S 3 X S Note: Verifiable action step for BOP occurs if SRO recognizes ODCM S
4 entry requirement and orders 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action requirement performed.
5 X -
NRC: Based on HPCS initiating on an invalid Level 2 signal, the lo-lo level instrumentation appears that it is indeed inoperable. With the actions taken to shutdown HPCS and prevent its restart, LCOs 3.3.5.1 and 3.5.1 BOTH appear appropriate to be entered. The HPCS DG is not affected by plant conditions, and therefore it would not be X X E appropriate for the SRO to enter or consider LCO 3.8.1 with HPCS inoperable for reasons other than operability of the HPCS DG.
Response
6 Made change as requested.
7 X S 8 X S NRC: Action for SRO to direct and BOP perform inhibiting ADS not labeled as a Critical Task. Identified as a Critical Task in summary section of scenario.
XXXX E
Response
9 Made change as requested.
9 0 0 0 0 2 4 5 E NRC: See above comments.
ES-301 7 Form ES-301-7 Facility: LaSalle Scenario: 3 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.
Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 S 3 S 4 X S 5 X S NRC: Consider reordering this event to just before the major event or just before the FRV fails open event as an untimely response to this failure could lead to a procedurally driven manual scram (runback E
occurs with power > 20%RTP).
6 Response: Resolved at OV.
7 X S 8 S 9 X S 10 X X S 11 XX X S NRC: Critical task to initiate suppression chamber sprays is not listed in the summary front matter section of the scenario paperwork.
E Response: Resolved - included.
ES-301 8 Form ES-301-7 Facility: LaSalle Scenario: 4 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.
Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 X S 2 S 3 S 4 S NRC: This failure is silent as there is no annunciator that will sound and comprises one valve losing indications lights. It is very likely the applicants may not notice this event has occurred without some form of X X U prompting.
5 Response: Replaced scenario NRC: More actions should be listed on the D-2 including review PPC for rod positons, LPRM indications, run OD-20, contact QNE, etc.
X E 6 Response: Replaced scenario 7 X X S 8 S NRC: ATC will be directed to manually scram the reactor with a primary system discharging into secondary containment. D-2 should include X E action to scram when directed and those actions taken post reactor 9 scram IAW LGP 3-2.
10 X X S 10 0 0 0 1 2 2 6 U NRC: See above comments. Replaced scenario with spare.
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 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: Exam Date:
1 2 3 4 5 6 7 8 11 Scenario % Unsat. Explanation Event Events TS TS CT CT Scenario U/E/S Totals Unsat. Total Unsat. Total Unsat.
Elements 1 8 0 2 0 3 0 0 S 2 7 0 2 0 4 0 0 S 3 9 0 2 0 3 0 0 S NRC: One event is LOD 5 as there is a silent failure indicated only by one valve losing position indication.
4 8 1 2 0 2 0 8.33 E
Response
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.
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 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.