ML20268A071

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2020 Palisades Ile Form ES-301-7
ML20268A071
Person / Time
Site: Palisades Entergy icon.png
Issue date: 07/06/2020
From: Bryan Bergeon
Entergy Nuclear Operations
To:
NRC/RGN-III/DRS/OLB
Bergeon B
Shared Package
ML19213A180 List:
References
Download: ML20268A071 (18)
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Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Palisades Exam Date: April 6, 2020 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 Admin 1a:

Perform Operability Checks for Safegaurds Transformer 1-1 and Startup Transformer 1-2 Conduct of Ops K/A 2.1.7 /

4.4 2

E NRC:

1) Initiating cue should direct performance of SOP-30 Section 7.3.2 Step e.7 (missing the e).

Licensee:

1) Correction made.

RO Admin 1b:

Perform SHO-1 Surveillance Steps Conduct of Ops K/A 2.1.19

/ 3.9 3

E Requires Simulator NRC:

1) Task element 1 - correct TIA-332 to TIA-0332 in the standard.
2) Task element 1 - Why are SIRWT temp indications have different acceptance ranges (1oF for TIA-0328 and 2oF for TIA-0332)?

Licensee:

1) Correction made.
2) Correction made to 2 degrees for both indications.

RO Admin 2:

Review P-7A, SWS Pump Tagout Equipment Control K/A 2.2.13

/ 4.1 3

S Requires Simulator 2017 ILE NRC:

1) Why does this need to be performed in the simulator? This was performed in the classroom during the 2017 ILE.

Licensee:

1) Use of simulator is for ease and realism as applicants are familiar with references and locations of references (drawings, etc).

RO Admin 3:

RIA-2322, Containment Gamma Monitor Electronic Source Test Radiation Control K/A 2.3.5

/ 2.9 3

X E

Requires Simulator NRC:

1) Task element 6 should be critical, as the applicant cannot proceed until the test pushbutton is released.

Licensee:

1) Task was marked as critical SRO Admin 1a:

Review / Approve SDM Calculations Review of Determination of Emergency Boration Requirements Conduct of Ops K/A 2.1.37

/ 4.6 3

X X

U JPM submitted is the same JPM as provided in the outline (in the submitted ES 301-1 and as discussed in the Summary for NRC SRO Admin document),

except the name/title was changed.

NRC:

1) Attachment 1 provided has the corrected final required boron concentration for step 5.a/c (1850), not the incorrect value from step 4.c (2075). It would make no sense for someone to determine an incorrect

ES-301 Operating Test Review Worksheet Form ES-301-7 value from steps 1-4 and then make an error to somehow transpose the correct value in step 5a. The applicant should have to correct boron in step 5.a, 5.c, 6.a, and 6.c (i.e error carried forward). Attachment 1 handout should have the following values: Step 5a =

2075, 5c = 1075, 6a = 1075, 6c = 106.43%. It appears the initial PCS boron concentration will need to be raised to lower the required CBAT change < 100%.

2) The 9.9 value in the calculation of step 6.c should be circled as well.

Licensee:

1) Changes made during validation to support correcting the JPM to support the comment provided.

Error carried forward has been changed such that the JPM is realistic and would not clue the applicant into what the initial error was. CBAT tank level can exceed 100% due to the system design including two independent tanks.

2) Correction made.

SRO Admin 1b:

Authorization Requirements to Exceed Work Hours Conduct of Ops K/A 2.1.5 /

3.9 3

S SRO Admin 2:

LCO Board and LCO Annex Review During SRO Turnover Equipment Control K/A 2.2.23

/ 4.6 3

E NRC:

1) JPM does not reference providing Admin Proc 4.02 (task element 2).

Licensee:

1) Reference added.

SRO Admin 3:

Respond to Stack Effluent Gas Alarms Radiation Control K/A 2.3.15

/ 3.1 2

S 2017 ILE Requires Simulator SRO Admin 4:

Classify A Mode 5 Event Emergency Plan K/A 2.4.41

/ 4.6 3

X U

Requires Simulator NRC:

1) It does not appear the InForm completion is time critical, yet the applicant is evaluated on the completion of it. Why?
2) The applicant may feel pressure as to the 15 minute declaration time being required from the time of observable conditions (i.e. Alert CA4.1 would be required by 10:21). The applicant may be confused as to what the start time is (10:14?) due to the timing of the events. Start time of the JPM should be clarified in the initiating cue.

Licensee:

1) InForm completion should be time critical. JPM task to complete form in a 15 minute time requirement.
2) JPM initial conditions clarified to reflect confusion of timing.

1

ES-301 Operating Test Review Worksheet Form ES-301-7 Simulator/In-Plant Safety Function and K/A JPMs Sim JPM A:

Align Control Rods to Address Deviations SF 1 K/A 001A4.03 4.0/3.7 3

X E

NRC:

1) Task element 15 - critical step has a rod position range from 117.1-120.9. If SOP-6 has a 2 deviation limit, shouldnt the high limit be 121.1?
2) Task standard should be enhanced.

Licensee:

1) 120.9 is the correct limit due to the 2 deviation between all group 4 control rods.
2) Task standard enhanced Sim JPM B:

Establish Hot Leg Injection via Alternate Path (PZR)

SF 2 K/A 006A2.02 3.9/4.3 3

X E

2017 ILE NRC:

1) Task standard should be enhanced (ex, EOP Supp 20, Section 1.0).
2) Task element 16 - why is closing CV-1057 not critical (are CV-1057 and 1059 in series?)?
3) Task element 18 - why are opening the valves in Supp 20 Section 1.0 step 5 not critical (isnt this the flowpath?)?

Licensee:

1) Task standard enhanced.
2) Spray valve CV-1057 is closed and in the closed position in the scenario setup; task is not critical.
3) Valves are already open, so the step is not critical.

Sim JPM C:

Open PZR PORV Isol Valves SF 3 K/A 010A4.03 4.0/3.8 3

S Sim JPM D:

Place the Zero Mode Bypass in Operation SF 7 K/A 012A4.05 3.6/3.6 3

X X

E Free-Look NRC:

1) Facility JPM # is highlighted - needs to be filled and and un-highlighted for approved version.
2) Consider providing refueling boron concentration as an initial condition in lieu of an evaluator cue in task element 4.
3) Where are the keys obtained from in task element 5 (as we are providing the applicant with the keys)?
4) Approved JPM version will need IC # corrected in the sim setup instructions in the JPM.

Licensee:

1) Correction made.
2) PCS boron concentration added.
3) Keys are obtained from the MCR key locker. JPM revised to require applicants to obtain keys.
4) Correction made.

Sim JPM E:

Trip Primary Coolant Pumps SF 4P K/A 003A2.02 3.7/3.9 3

X E

NRC:

1) Script evaluator cues to prevent performance of step 16.1.c/d/e to force the applicant to perform 16.1.b to trip PCPs from EC-11A rather than any local action.

ES-301 Operating Test Review Worksheet Form ES-301-7 per Supplement 16 (NFPA805)

Licensee:

1) Evaluator cues scripted.

Sim JPM F:

Start and Load a Diesel Generator in Parallel SF 6 K/A 064A4.06 3.9/3.9 3

X E

NRC:

1) Task element 14 and 15 - why are these not critical steps? Is the applicant not expected to have to make any voltage/speed adjustments?
2) Task element 18 - why is it not a critical step to add load to the DG after closing the output breaker? Isnt it critical to prevent a reverse power trip?

Licensee:

1) Tasks 14 is not critical as this affects reactive load and not the synch check relay. Task 15 is also not critical as the synch check relay will prevent breaker closure.
2) Task 18 is not critical as the EDG will have a minimum of 50MW load.

Sim JPM G:

Sample Containment for Hydrogen SF 5 K/A 028A4.03 3.1/3.1 3

S NRC:

1) Applicant may choose to address alarm EK-0227 if they do not call it expected. Should have a copy of the ARP to provide.

Licensee:

1) ARP guidance added and will be made available during JPM.

Sim JPM H:

Stop all Auxiliary Building Ventilation SF 9 K/A 060AA1.02 2.9/3.1 3

S RO Only I/P JPM I:

Manually Start P-9A Fire Pump SF 8 K/A 086A3.01 2.9/3.3 2

E Free-Look 2014 ILE NRC:

1) Task standard needs enhancing, ex. Fire Pump P-9A manually started in accordance with SOP-21.
2) If the T-handle is not rotated CCW to latch after the T-handle is pulled out to start the pump, will the pump remain running? If so, it does not appear this step is critical.
3) Can the T-handle be physically rotated CW instead of CCW, if so, what is the impact of doing the step incorrectly?
4) Portions of task elements 4 and 5 are highlighted and should be un-highlighted for the approved version.

Licensee:

1) Task standard enhanced
2) No, the pump will stop. This was added to the JPM as an evaluator note.
3) No, handle can only be operated CCW. This was added to the JPM as an evaluator note.
4) Correction made.

I/P JPM J:

Supply AFW Pump from Service Water SF 4S K/A 016K4.01 4.1/4.2 3

S 2014 ILE NRC:

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

1) Task element 4 - Is there a flow indication or pressure gauge the applicant may use? Would they simply hear flow?

Licensee:

1) Not likely in the specified area; they will see flow from the vent valve.

I/P JPM K:

Outside Control Room B S/G ESDE Isolation IAW EOP Supplement 18 SF 4P K/A 040AA1.03 4.3/4.3 3

X E

NRC:

1) Task element 10 - is the applicant expected to locally verify CV-0744 open or use the picture in the attachment to determine position? Is the valve not easily accessible? Its difficult to determine position from the picture.

Licensee:

1) Applicant is expected to verify the position locally, however, depending on the plant condition, the valve may not be in the position expected. A picture is provided for that. Clarification of this has been added to the evaluator cue and an evaluator note.

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: Palisades Scenario: NRC-1 (FREE LOOK) Exam Date: April 6, 2020 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

Return MFP Controller to Cascade S

NRC:

1) To ensure adequate verifiable actions occur - A mismatch in output signals must be present at the start, such that the applicant must take action to lower HIC-0525 to match signals.

Licensee:

1) Mismatch exists such that applicants must exhibit positive control prior to placing in cascade.

2 Feed Regulating Valve erratic operation. SG manual control available.

E NRC:

1) Consider swapping Events 2 and 3, due to the 5-minute ramp of Event 2. This ramp of the FRV failing closed could be building during the TS evaluation of the Thot failure.
2) D-2 references AOP-23, Feedwater Transient, however, AOP-23 is Primary Coolant Leak. Correct typo to AOP-3.

Licensee:

1) Event modified from valve failure to erratic operation. 5-minute timer no longer necessary. Recommend keeping event as event 2.
2) Correction made 3

Thot #2 RTD fails to 100%

TS X

S 2017 ILE Scenario 2, Event 4 NRC:

1) Consider swapping Events 2 and 3, due to the 5-minute ramp of Event 2. This ramp of the FRV failing closed could be building during the TS evaluation of the Thot failure.

Licensee:

1) As discussed in Event 2, this is not necessary due to the modification to Event 2.

4 CVCS Backpressure regulator fails closed with failure of RV-2006 to seat X

TS E

NRC:

1) To perform the PCS leakrate, as directed, is the applicant expected or required to complete AOP-23 Att 1 to perform the leakrate, since that is what is directed by the SRO applicant per Operator Actions step 3.a?
2) D-2 is missing a step (AOP-23, Operator Actions step 4.2 RNO) to notify Chemistry to verify NSSS sample panel isolated.
3) When the RO performs AOP-23 Att 2 to isolate the leak, the Att 2 should be referenced in the step for clarification.
4) SRO is to determine TS 3.4.13 limits are not exceeded - TS no calls are not considered TS beans as no-calls do not count. Leak size may need changed to > 10 gpm.
5) After the crew isolates L/D, wont the PZR level be rising with P-55B/C in auto? How quickly?
6) No Event transition information is included to move to the next Event.

Licensee:

1) PCS leakrate is directed to be performed IAW AOP-23 Att 1.
2) Correction made.
3) Correction made.
4) TS limits will be exceeded as the valve will fail to reseat. TS call is valid and is added to the D-1 and 301-5.
5) All charging and letdown will be secured. P-55A will be required to be manually started to maintain PZR level.

ES-301 8

Form ES-301-7

6) transition information added.

5 MSR Drain Tank Outlet Valve, CV-0608, HDP outlet valve fails open. Requires rapid power reduction before the HDP trips.

X TS E

NRC:

1) Does not appear there are any verifiable actions for this event. The D-2 has Event 5 and 6 combined into a single event, which would be accurate with no verifiable actions for this Event, however, this Event would be Unsat if going by the D-1.
2) This event requires a TS call (3.1.6 Cond A), but the D-1 and 301-5 forms do not include this TS call.

Licensee:

1) Combined CV-0608 failure and the rapid power reduction events (events 5 and 6 are now event 5). Verifiable actions include the rapid power reduction.
2) TS call added to D-1 and 301-5.

6 5

Emergency power reduction to stabilize feed system X

E NRC:

1) Listed under Event 5 in the D-2 form
2) Include the 5oF PCS temperature deviation goal under AOP-7 Operator Action step 4.a as a note.
3) D-2 does not include the crew borating - why is boration not included after insertion of the regulating rods if the crew is expected to reduce the ramp rate to near 30%/hr?

Wouldnt the crew need to borate the rods out for PDIL as theyd enter the TS action to do so?

4) How much is the crew expected to be required to ramp down to mitigate/stabilize the HD valve failure (i.e. far enough to reduce FW pump operation)?

Licensee:

1) Resolved by combining events 5 and 6.
2) Correction made.
3) 2-hour action to borate the rods back out. The next event in the scenario is the LOCA and Rx trip, so the crew would not reach the point of borating.
4) < 90% RTP. This was added to the D-2.

7 6

100 gpm LOCA Inside of Containment. Requires manual Rx trip. LOCA raises to 500 gpm on the trip. Failure of A HPSI pump to auto-start - manual start available.

CT1 S

NRC:

1) Listed under Event 6 in the D-2 form
2) CT for T2/L2 should be first noted under PCS pressure control step on page 3/8 under Event 6.
3) Event description not consistent for the event pg 1-5 (SI failure left off pages 2-5)
4) HPSI pump failure is a separate failure and the ATC is receiving separate credit for that event - recommend splitting this into its own event Licensee:
1) Corrected
2) Pressure will be recovering due to SIAS - crew should not see conditions requiring PCP tripping at this point.
3) Correction made.
4) HSPI pump failure separated out into new Event 7.

8 7

Failure of A HPSI Pump to auto start Trip2 Leave2 and LOCA raises to 1100 gpm.

CT2 CT3 E

NRC:

1) Listed under Event 6 in the D-2 form, however, applicant will receive additional component credit for this malfunction.
2) Is it correct that this failure is input to start the scenario? Will the pump start upon manual SIAS?
3) RO action on page 6/8 under Event 6 states the applicant identifies B HPSI pump has not started. It appears this should be P-66A and not B. This step seems out of place just prior to the EOP-1.0 / 4.0 transition. Shouldnt this CT be moved to the PCS pressure control step on page 3/8 under Event 6?
4) Event 7 and the Larger LOCA does not apply until T2L2 is implemented on page 3 of 4 on Event 7. Pages 1 and 2 of Event 7 should be part of Event 6.
5) What action is the ATC performing to get credit an (I/C) component bean for here?

Licensee:

1) HPSI pump failure has been moved to event 6
2) Failure is input to start scenario.

ES-301 9

Form ES-301-7

3) Correction made. CT to start HPSI pump moved to PCS pressure control step.
4) Correction made.
5) ATC will not receive I/C credit as the event changed to Major for All applicants.

9 8

Failure of P-54A, Containment Spray Pump AND Failure of P-54B, C to auto start - manual start available CT4 X

E 2017 ILE Scenario 1, Event 9 NRC:

1) Listed under Event 6 in the D-2 form, however, applicant will receive additional component credit for this malfunction.
2) Is it correct that this failure is input to start the scenario?
3) If no action is taken to establish one CS train, can containment pressure reach 55 psig in this scenario?

Licensee:

1) Created a separate event in the D-2 for this event.
2) Failures are input to start the scenario.
3) No, cnmt pressure will not exceed design limits. CT4 has been removed.

9 0

1 0

0 2

3 2

E NRC:

1) D-1 and D-2 forms do not match in terms of Event numbering. If an applicant is receiving credit for an Event, that Event should be listed separately for clarification.
2) Provided scenario does not include Event summary page, CT details, malfunction page, scenario setup, etc.
3) 301-5 enhancements - SRO should get Event 2 I/C bean. Validate/ensure accuracy of TS beans on Events 4 & 5. Is the ATC bean for Event 7 accurate?

Licensee:

1) D-1 and D-2 now match.
2) Event summary, special instructions, turnover info, CT details, scenario setup information all added.
3) Corrections made. See Events 4&5 for TS calls. See Event 7 for event changed to major event.

ES-301 10 Form ES-301-7 Facility: Palisades Scenario: NRC-2 Exam Date: April 6, 2020 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

Borate to the SIRW Tank E

NRC:

1) Include batch and flow limit sizes Licensee:
1) Flow limits added.

2 Chemistry results provided to SRO showing high activity TS S

NRC:

1) This event could be removed due to 3 other TS calls in the scenario.

Licensee:

1) Event removed.

3 Cooling Tower Pump, P-39A Seal Lube Low Flow -

Requires manually tripping pump and initiation of rapid down power E

NRC:

1) BOP action to trip the pump should be listed in Event 3, not in Event 4.

Licensee:

1) Correction made.

4 Rapid down power TS E

NRC:

1) BOP action to trip P-39A pump should be listed in Event 3, not in Event 4.
2) TS for LCO 3.1.6 is called out in the D-2 but is not accounted for on the D-1 or in the 301-5.

Licensee:

1) Correction made.
2) TS call added to D-1 and 301-5.

5 Spurious trip of Bus 1C with failure of auto transfer to Startup power resulting in EDG 1-1 supplying bus.

TS E

NRC:

1) List AOP steps (4,5) that show how the BOP will determine bus 1C is not faulted
2) List AOP step (6.1 RNO) for how BOP will attempt to transfer bus 1C to startup power (EOP Supp 29). List EOP Supp 29 steps on what the BOP is expected to do (section 3.0 step 1).
3) ATC should receive (C) credit for starting a SWS pump to restore SWS header pressure since they wont automatically start.
4) What is the impact for failing to start a SWS pump (i.e. no SWS pumps running)?

Should starting a pump be a CT?

5) Event 5 has 2 different failures (loss of bus 1C and the auto-start failure of P-7B) that should be treated as 2 separate Events, as the SRO is addressing TS for each event separately.

Licensee:

1) AOP steps added.
2) AOP steps added.
3) ATC I/C credit listed in the SWS pump start failure in a new event.
4) Event does not result in a complete loss of service water. EDG will have some pressure, although system low pressure alarms will be present.
5) Event 5 split into two separate events as requested.

5 TS E

NRC:

ES-301 11 Form ES-301-7 Failure of Service Water Pump to start from NSD Sequencer

1) Event 5 has 2 different failures (loss of bus 1C and the auto-start failure of P-7B) that should be treated as 2 separate Events, as the SRO is addressing TS for each event separately.

Licensee:

1) Event 5 split into two separate events as requested.

6 SGTR on B S/G requiring a manual Rx trip CT2 S

7 Failure of auto SIAS on both trains (fail auto signals and manual actuation P/B)

CT3 E

NRC:

1) The BOP is being given I/C credit for this event, based on starting SWS, CCW, and repositioning other values per EOP Supp 5. The D-2 does not appear to address CCW pump operation.

Licensee:

1) CCW added to EOP Supp 5 list.

8 ESDE on B S/G 10 minutes after the Rx Trip CT1 CT4 E

NRC:

1) Change to BOP and SRO I/C component credit rather than Major for All applicants credit.

Licensee:

1) Based on the validation, the BOP will not receive I/C credit.

9 0

0 1

0 4

4 0

E NRC:

1) Event descriptions need edited for consistency and accuracy on Events 6, 7, 8 in the D-2.

Licensee:

1) Corrections made.

ES-301 12 Form ES-301-7 Facility: Palisades Scenario: NRC-3 Exam Date: April 6, 2020 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

Alternate CCW pump to place P-52B in service S

2017 ILE Scenario 1, Event 1 2

Power escalation at 12%/hr E

NRC:

1) General guidelines for reactivity manipulation should be provided; i.e. approximate amount of boron and control rod movement.
2) Is the power escalation to be performed IAW with GCL 5.1 (starting at step 4.1?)?

The D-2 references GOP-5 but does not reference any specific steps (ex. Does step 4.2, S/G blowdown need to be performed?). Would GCL 5.1 be placekept and provided to the crew upon turnover?

Licensee:

1) General reactivity guidelines will be provided.
2) Yes, power escalation to be performed IAW GCL 5.1 step 4.3, which will be provided (placekept) to the crew.

3 Loss of EY-10, Preferred AC Bus TS E

NRC:

1) Typo on page 1 - SOP-3 should be AOP-3
2) Missing steps 6, 8, 9, 12, 14-21 from AOP-12
3) AOP-12 does not reference SOP-36 to bypass RPS trips. Procedure enhancement?
4) Is it expected that we wait until the crew gets EY-10 on the bypass regulator (for Event 6, specifically)?

Licensee:

1) Correction made.
2) Steps added.
3) Procedure enhancement is worthwhile and will be processed after the exam. ARP provides direction for bypassing RPS trip using the SOP, so specific guidance to use the SOP exists based on the indications the crew will receive.
4) Yes, the crew must be on the bypass regulator for Event 6.

4 Trip of CCW pump with failure of auto-start on other pumps TS CT1 S

5 Main steam flow transmitter failure S

NRC:

1) If the crew does not take manual action and the hi level override closes the valve, will the valve remain full closed and a low level trip & AFW actuation occur or does the FRV throttle open and closed to maintain the 60-90% band?

Licensee:

1) Yes, the hi-level override will result in the FRV cycling between the 60-90% band.

6 PZR level channel (2) fails downscale demand E

NRC:

1) Include steps prior to step 5 of AOP-22 in the D-2.

Licensee:

1) Steps added to D-2 7

X E

2017 ILE Scenario 1, Event 7 NRC:

ES-301 13 Form ES-301-7 Main turbine GV failure, requiring manual Rx trip.

1) ATC should get (I/C) component credit for tripping the Rx.

Licensee:

1) 7 ESDE Outside containment CT4 E

NRC:

1) This should be the (M) major event and should be renumbered as Event 9 Licensee:
1) Revised D-1 includes this as the major event.

9 Main turbine auto-trip failure, manual trip required CT2 X

E 2017 ILE Scenario 1, Event 7 NRC:

1) This should be renumbered as Event 8
2) BOP gets the (I/C) component bean for tripping the turbine, ATC gets the (I/C) component bean for tripping the Rx.
3) Event 8/9 page 1/8 has a ? in the cue for B S/G level lowering.

Licensee:

1) Correction made.
2) Revised D-1 and 301-5 includes BOP (I/C) event credit.
3) Correction made.

10 ESDE severity rises, MSIVs fail to auto close CT3 E

NRC:

1) BOP should get (I/C) credit for manually closing the MSIVs Licensee:
1) Revised D-1 includes BOP credit for closing MSIVs and the event being reclassified as a (I/C) event.

11 Failure of second CCW pump to auto start on SIAS S

NRC:

1) Event is not necessary based on the number of beans the ATC and BOP receive up to this point.

Licensee:

1) After OV discussion, recommend leaving event in the scenario.

11 0

0 0

0 2

4 3

E NRC:

1) No Event 8 on the D-1 (skips from 7 to 9). Renumber events as discussed under each event explanation above.
2) CT4 wording should be the same as scenario 2, CT4 Licensee:
1) Correction made on revised D-1.
2) CT4 wording is correct in the CT guidance at the end of the scenario D-2. Corrected wording on the D-1.

ES-301 14 Form ES-301-7 Facility: Palisades Scenario: NRC-4 Exam Date: April 6, 2020 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

Close switchyard breaker 25F7 E

NRC:

1) Would the crew have switching orders from the transmission system operator they would have to complete in order to close the breaker (tags, notifications, etc)?
2) Event transition (to event 2) is missing.

Licensee:

1) No, no additional information required for the crew.
2) Event transition added.

2 Power ascension E

NRC:

1) General guidelines for reactivity manipulation should be provided; i.e. approximate amount of boron and control rod movement.
2) Is the power escalation to be performed IAW with GCL 5.1 (starting at step 3.1?)?

The D-2 references GOP-5 but does not reference any specific steps (ex. Does step 4.2, S/G blowdown need to be performed?). Would GCL 5.1 be placekept and provided to the crew upon turnover?

Licensee:

1) General reactivity guidelines added.
2) GCL 5.1 will be provided as a placekept in-progress procedure.

3 RIA-1810 failure low requiring ATC to close dampers for Safeguards room isolation TS X

S 2017 ILE Scenario 1, Event 5 NRC:

1) Event description not bolded like the others.

Licensee:

1) Correction made.

4 P-40A Dilution water pump trip requiring valve throttling to maintain cooling tower levels TS X

E 2014 ILE Scenario 3, Event 2 NRC:

1) List all BOP actions in ARP-24, rather than state BOP addresses and performs ARP-24 actions
2) Is there an expected cooling tower level band that the applicant should be expected to maintain?

Licensee:

1) ARP actions added.
2) Added high level to the D-2 to ensure applicant maintains < overflow.

5 VCT level failure resulting in charging suction swapping to SIRWT. Requires manual isolation of charging/letdown to prevent PCS boration S

6 P-50D vibration resulting in manual Rx trip followed by securing of P-50D CT1 X

E 2017 ILE Scenario 2, Event 6 NRC:

1) PCP Vibration Danger alarm should be EK-0914, not EK-0915.
2) If the applicants are expected to respond to the alarms, the D-2 should direct the actions from the ARPs.

ES-301 15 Form ES-301-7

3) Will the PCP automatically trip within 10 minutes if not operator action is taken?

Licensee:

1) Correction made.
2) Applicants will likely enter the AOP and trip the Rx and subsequently the PCP due to the timing and urgency to do so.
3) No, it will not auto trip.

7 Ramped vapor space LOCA CT2 CT3 E

NRC:

1) Heading formatting issues on page 5/6
2) Provide EOP Supp 1 in the D-2 for the evaluators use to observe PCP operating limits to validate completion of CT3.

Licensee:

1) Correction made.
2) EOP Supp 1 provided as a handout to examiners, separate from the D-2 8

Loss of offsite power 10 minutes after P-50D is tripped. Failures of both EDGs require manual action to restore Bus 1C or 1D CT4 X

E 2014 ILE Scenario 1, Event 7 NRC:

1) If the crew is performing EOP-1.0 verbals at the time of the Loss of Offsite Power, wouldnt the crew have a LOOP/LOCA and transition to EOP-9.0 per EOP-1.0 Att 1?
2) Under a LOOP event, the crew would have 30 minutes to strip DC bus loads (as the battery charger(s) power supply is lost), but the TCA is to restore power to bus 1C or 1D within 60 minutes. How is the 30 minute TCA not applicable here?

Licensee:

1) No, the crew would be required to transition to EOP-4.0 based on the flowchart diagnostic.
2) CT4 bounding condition changed from procedure transition to 60 minute time requirement (if the crew does not restore power within 30 minutes, the crew must initiate DC load shed within that 30 minutes, but power must be restored within 60 minutes).

9 Manually start IA compressor after EDG loading is complete S

NRC:

1) Events 8-11 are all combined into Event 8 in the D-2. This should be reflected in the Event heading.

Licensee:

1) Events 8-11 added to heading.

10 Manual action to restore charging pumps S

NRC:

1) Events 8-11 are all combined into Event 8 in the D-2. This should be reflected in the Event heading.

Licensee:

1) Events 8-11 added to heading.

11 After loss of all AC, two CACs trip off requiring manual action to start during post-SIAS checklist S

NRC:

1) Events 8-11 are all combined into Event 8 in the D-2. This should be reflected in the Event heading.

Licensee:

1) Events 8-11 added to heading.

11 0

0 0

0 2

4 4

E

ES-301 16 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 17 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

9 0

3 0

3 0

0 E

Confusion between the D-1 and D-2 forms (Events do not correlate). See scenario specifics for Event details.

2 9

0 3

0 4

0 0

E Issues with Event crediting and TS crediting. See scenario specifics for Event details.

3 11 0

3 0

4 0

0 E

Issues with Event numbering and Event credit. See scenario specifics for Event details.

4 11 0

2 0

4 0

0 E

Editorial changes - see scenario specifics for Event details.

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

OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

2 4

3 See above for details on SRO 1.a and SRO 4.

Sim./In-Plant JPMs 11 0

7 4

Scenarios 4

0 4

0 Op. Test Totals:

24 2

15 7

8.3%

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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