ML20329A141

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NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML20329A141
Person / Time
Site: Ginna Constellation icon.png
Issue date: 09/17/2020
From:
Operations Branch I
To:
Exelon Generation Co
Shared Package
ML19309E375 List:
References
CAC 000500
Download: ML20329A141 (21)
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Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Exam Date: October 5 - 29, 2020 1 2 3 4 5 6 Attributes Job Content Admin LOD ADMIN Topic and K/A U/E/S Explanation JPMs (1-5) I/C Critical Scope Perf. Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC:

  • Sub steps contained in JPM Steps 1 and 2 that identify the correct Tables within Attachment E for Time to Boil determinations should be flagged with an asterisk for designation as Critical Steps. Revise the Critical Step Justifications on Page 3 of the JPM accordingly.

GINNA:

Conduct of

  • Designated second sub step of JPM Operations Steps 1 and 2 as Critical Steps and 2.1.25 annotated with an asterisk. Critical SRO-A1.a E Determine 2 X Step Justifications on page 3 of JPM S

Time to Boil updated accordingly.

for a Loss of

  • OU-AA-103, Step 4.10.1.3 states Shutdown The Shutdown Safety Manager (or Cooling designee) shall COMMUNICATE the Unit status in a highly visible manner to each shift during outage execution, including: PROVIDE Control Room personnel with information such as Time to Boil and Key Safety Function Status for use in Operator shift briefings and/or postings in the Control Room. IP-OUT-2, step 4.2.A states that the Shutdown Safety Coordinator Position shall be filled by SRO assigned on shift with no other collateral duties.

NRC:

  • Performance Standard for the Conduct of Notifications Section of NRC Form Operations 361, Reactor Plant Event Notification SRO-A1.b 2.1.18 E Worksheet, states that a checkmark 3 X S or X will be placed in the NO and/or Determine WILL BE box associated with each Reportability of the 5 notification types. It appears Requirements that checking only the NO box would be an incorrect response, given

ES-301 Operating Test Review Worksheet Form ES-301-7 that the specified Notifications are required to be made. Checking only the NO box means that the Notification(s) will not be made.

Enhance the Performance Standard and Form 361 Answer Key to address this item.

GINNA:

  • Changed the KEY to accept WILL BE or NO for the final four notification check blocks (non-critical).
  • Changed the KEY to accept WILL BE for the Site Resident notification check block (critical).
  • Revised the Performance Standard for the applicable JPM Steps.

NRC:

  • Include an Examiner Note that JPM Step 5 for Line 1 column item Log OOS (Y/N) on Form A-52.12-F-03, is being addressed under A-52.12, Step 6.7.4. Intent is to avoid any potential confusion, given that JPM Steps 5 & 6 both reference procedure Step 6.7.4, which reads:

NOTIFY the Fire and Safety Watch (FASW) of the Equipment OR System deemed nonfunctional.

  • The Examiner Note pertaining to Step Equipment 9 of the JPM, and associated Note Control 2.2.42 with double asterisk at the bottom of SRO-A2 E Form A-52.12-F-03, should both 3

A-52.12, S include TR 3.7.5 Action A.1.1 since it Inoperability of has a 1-hour Completion Time.

a Fire Damper

  • Editorial: Performance Standard Elements for JPM Steps 2-11 reference procedure A-5.52.12.

Appears that the reference should actually be A-52.12.

GINNA:

  • Included an Examiner Note that JPM Step 5 for Line 1 column item Log OOS (Y/N) on Form A-52.12-F-03, is being addressed under A-52.12, Step 6.7,4.
  • Step 9 Examiner Note and Form A-52.12-F-03 Note with double asterisk revised to include TR 3.7.5, Action A.1.1.
  • Procedure reference in JPM Steps

ES-301 Operating Test Review Worksheet Form ES-301-7 corrected to A-52.12.

NRC:

  • The Initiating Cue, as written, is leading. Do not need to tell the applicant to identify all entries that must be changed to permit approval. Suggest revising the Initiating Cue to read as follows:

As Shift Manager, review the release permit for approval authorization and document the Radiation Control results on the cue sheet.

2.3.6 SRO-A3 E 3 X

  • Remove the Table from the cue Review and Approve S sheet, along with the accompanying Gas Decay Tank before and after statements.

Release Permit GINNA:

  • Revised Initiating Cue to As Shift Manager, review the release permit for approval authorization and document the results on the cue sheet.
  • Removed Table and accompanying before and after statements from Cue Sheet. Removed the separate Answer Key and all references to the Answer Key in the JPM.

NRC:

  • Sub step contained in JPM Step 1 that calculates how much exposure the rescuers will receive in excess of 5 Emergency REM should be flagged with an Procedures/Plan asterisk for designation as a Critical 2.4.38 Step.

SRO-A4

  • Editorial: Performance Standard for Determine if E 2 X JPM Step 3, Second asterisk, Emergency Dose Limits S incorrectly specifies procedure EP-AA-and Thyroid Blocking 113-F-02; should be EP-AA-113-F-03.

Agents (Potassium GINNA:

Iodide [KI]) Should be

  • JPM Step 1 sub step annotated as a Approved for Use. Critical Step.
  • Performance Standard for JPM Step 3, Second asterisk, revised to procedure EP-AA-113-F-03.

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

  • For JPM Step 1, enhance the performance standard to show how the 6-Week Average comes out to 51.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> if the 16-hour period is worked, ensuring compliance with the 54-Hour Rule.
  • JPM appeared on the 2018 Exam and was randomly selected for use on the 2020 Exam. Explain the significance Conduct of of adding the following item to the Operations stem for the 2020 Exam:

2.1.5 RO-A1.a E Your work schedule reveals that Determine the 3 X S over the next five weeks you are Allowable scheduled to work an average of Hours an 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> per week.

Operator Can Work GINNA:

  • JPM Step 1 Performance Standard enhanced to show 6-Week average.
  • This additional Initial Condition was added to allow the Applicant to perform the 6-week rolling average for the current week plus the following five weeks to verify Work Hour Rules will not be violated in the future Conduct of Operations 2.1.25 RO-A1.b Complete 3 S Plant System Checks Inside Control Room (Verify SDM)

NRC:

  • Examiner Cue prior to Step 1 of the JPM gives direction to provide the Applicant with Handout 1. The Equipment Handouts field on Page 3 of the Control 2.2.41 JPM does not specify any Handouts.

RO-A2 E GINNA:

3 Determine S

  • Added the P&ID Drawings as Leak Isolation Handout #1 to be provided to the Boundaries Applicant initially. The remaining General References will be available when asked for.
  • This JPM will be administered individually.

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

  • Sub steps contained in JPM Step 1 that require the applicant to determine the R-47 HIGH and WARNING alarm setpoints should be flagged with an asterisk for designation as Critical Steps.
  • Examiner Cue prior to Step 1 of the JPM gives direction to provide the Applicant Handout 1, which is a blank Radiation copy of AP-SG.1, Steam Generator Control 2.3.5 Tube Leak. The applicant will also need to reference P-9 and Curve #06-RO-A3 Evaluate E 004 which will be available for use Steam 3 X S during the JPM. Why is AP-SG.1 Generator being given to the applicant at the Tube Leakage onset of the JPM?

from R-47 GINNA:

Reading

  • JPM Step 1 sub steps annotated as a Critical Step (asterisk).
  • AP-SG.1 is initially provided to the Applicant since this is the procedure that the crew is evaluating for entry.

P-9 and Curve #06-004 will be available for the Applicant when asked for.

  • This JPM will be administered individually.

ES-301 Operating Test Review Worksheet Form ES-301-7 match the font size 11 used throughout the JPM.

IP-J 3 3 S E04 EA2.2 IP-K 4S 2 S 061 K4.13

ES-301 8 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 10 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 2 Exam Date: October 5 - 29, 2020 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap NRC:

  • Editorial: On Page 9 of the ES-D-2, under the Indications Available section, the 1 - A Charging E description for alarm AR-B-10 is incorrect. Should be RCP 1B LABYR SEAL LO Pump Trip DIFF PRESS instead of RCP 1A.

GINNA:

  • Corrected AR-B-10 description to be RCP 1B LABYR SEAL LO DIFF PRESS.

2 - Fuel Failure /

High RCS TS S Activity 3 - Generator Hydrogen Temperature S

(Cold Gas)

Instrument Failure 4 - B RFP Oil CT1 S Leak Reactivity Manipulation NRC:

  • TS Required Actions scripted for LCO 3.1.4, Condition B, on Page 41 of the ES-D-2 5 - Control Rods do not accurately reflect what is currently in the TSs. Required Actions B.4, B.5, and Fail to Move E B.6 are incorrect. Specifically:

TS in AUTO / S o There is no B.6.

Stuck Rod o B.6 should be B.5.

o B.4 only lists 1 of 3 Surveillance Requirements.

GINNA:

  • Corrected ES-D-2 for script of Technical Specification LCO 3.1.4 to match Technical Specifications.

Major Event 6 - Condensate Header (TDAFW Pump Trip on Overspeed used on 2018 NRC Exam; Scenario 4, Event 7)

Break / Loss GINNA:

of Bus 14 / A E

  • During validation week, the NRC requested that the complete loss of AFW be MFW Pump X delayed until after the crew has performed substantive actions in ES-0.1.

S Trip / Consequently, the malfunction for loss of Bus 14 will be inserted after the crew TDAFW completes ES-0.1, Step 1 RNO AND S/G narrow range level is 12%. Revised ES-Pump Trip on D-1 and ES-D-2 to insert the loss of Bus 14 eliminating the only available source (A Overspeed MDAFW Pump) until after Step 1 of ES-0.1. with S/G narrow range level 12%.

ES-301 12 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 3 Exam Date: October 5 - 29, 2020 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap 1 - Load Ascension /

MRPI TS S Reactivity Manipulation System Failure 2 - Main Generator Voltage S Regulator Fails High 3 -Letdown Temperature Control Valve S

(TCV-130)

Controller Failure 4 - Leak in the NRHX to S CCW System 2019 NRC Retake Exam; Scenario 1, Event 3 (Loss of Bus 12B only).

NRC:

  • Agree with LCO 3.8.1, Condition C. However, questioning the applicability of Condition A, Required Action A.1, Declare required feature(s) inoperable when its redundant required Feature(s) is inoperable. What is the redundant required feature that is inoperable on associated safeguards Buses 14/18? Provide an explanation on the TS Page of the ES-D-2 explaining the applicability of LCO 3.8.1, 5 - Loss of Condition A, Required Action A.1.

Offsite Circuit E GINNA:

767 / Restore TS X S

  • In accordance with Technical Specification LCO 3.8.1 Basis (page 3.8.1-5) One 4160 Bus qualified independent offsite power circuit connected between the offsite 12B transmission network and the onsite 480V safeguards buses and separate and independent DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Therefore, while offsite power is NOT connected to Buses 16 and 17, LCO 3.8.1, Condition A applies. Required Action A.1, though not currently necessary for plant conditions, must be entered due to a potential future event.

Revised ES-D-2 to include this explanation on page 43.

6 - B EDG Trips

/ Loss of 7T CT3 S Major Event Circuit

ES-301 16 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 5 Exam Date: October 5 - 29, 2020 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap 1 - Load Ascension /

TS S Reactivity Manipulation Bus 18 UV Relay Failure 2 - VCT Divert Control Valve X S 2018 NRC Exam; Scenario 3, Event 1.

(LVC-112A)

Failure NRC:

  • Comment: TR 3.2.3, Axial Flux Difference (AFD) Monitor, Condition A, Action A.1, 3 - PR N42 requires performance of TSR 3.2.3.2 every 15 minutes. Applicants will be expected Upper to demonstrate/ensure compliance with this TR action during the course of the TS S Detector scenario, given the short 15-minute Completion Time.

Failure GINNA:

  • Understand that the Applicants will be required to comply with the 15-minute action.

Added an Examiners NOTE on page 20.

4 - Hotwell Level Controller X S 2018 NRC Exam; Scenario 4, Event 4.

Fails to Full Makeup NRC:

  • Comment on Page 27 associated with Step 2 RNO for AP-CW.1, Loss of A Circ Water Pump, states that Rapid Load Reduction guidance per AP-TURB.5 is provided on Page 28. Guidance is provided on Page 29.

5 - Circ Water

  • Comment on Page 29 associated with AP-TURB.5, Step 1, states that rods cannot Pump A Trips E be inserted in AUTO due to a previous malfunction. Is this accurate? What is the

/ Loss of S previous malfunction that precludes automatic rods insertion?

Vacuum GINNA:

  • Corrected Comment on page 27 to reference page 29 for AP-TURB.5.
  • The rods are in MANUAL due to the load ascension. If not, rods would have been placed in MANUAL due to the Power Range Channel failure. The NOTE is not helpful and has been removed.

6 - Inadvertent Steam Line S Major Event Isolation Signal 7 - Failure of Rx to Trip From CT1 S Control

ES-301 18 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 19 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Exam Date: October 5 - 29, 2020 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 RHR Pump A was inoperable at the start of the scenario (Turnover Sheet item).

Accordingly, entry into LCO 3.5.2, Condition A, had already been made. Event requires the E crew to enter Condition B of the same LCO. Unable to evaluate the applicant in 1 9 0 2 1 3 0 7.14% accordance with NUREG-1021, ES-303, under TS Competency Rating Factors 6(a) and S 6(b), given that the LCO was previously entered. The event only requires the applicant to demonstrate competence in Rating Factor 6(c) by identifying and complying with the correct Condition and Action Statement.

E 2 8 0 2 0 3 0 0%

S E

3 8 0 2 0 3 0 0%

S 4 SPARE SCENARIO - INFORMATION REDACTED E

5 8 0 2 0 2 0 0%

S 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

ES-301 20 Form ES-301-7 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.

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