ML21137A331
| ML21137A331 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/18/2021 |
| From: | Gregory Roach NRC/RGN-III/DRS/OLB |
| To: | FirstEnergy Nuclear Operating Co |
| Roach G | |
| Shared Package | |
| ML20136A260 | List: |
| References | |
| Download: ML21137A331 (10) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 1
Facility: DAVIS-BESSE Exam Date: FEBRUARY 2021 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.
SRO-A1.1 COO 2.1.38 3
X X
E S
NRC: Task Standard statement should be very clear as to how the Critical Steps of the JPM were determined. In this instance, steps which are associated with notifications driven by regulatory requirement were considered critical steps, but notifications just directed by the procedure (e.g.
RIO, SLT, EPPI) were not deemed critical steps.
The Task Standard simply states identify all required notifications. Perhaps adjust the Task Standard statement to state, identify all notifications required by regulatory requirement and their reporting time requirements.
The validation time seems a little short at 10 minutes. It is typical for applicants to really go over these types of administrative procedures with a fine-toothed comb to ensure they didnt miss anything.
FREE SAMPLE
Response
- 1.
Corrected task standard as suggested.
- 2.
Adjusted validation time based on NRC Comment and historical administrative JPM performance.
SRO-A1.2 COO 2.1.37 2
X X
E S
NRC: Why is the incorrect specific gravity an order of magnitude greater as compared to the correct value? 0.19 versus 0.022. This tends to make it quite obvious something is wrong as compared to the data in the table.
Task standard needs to be more specific, indicating that the applicant should identify and correct the incorrect information in the calculation.
Response
This value was chosen by the JPM author. Not sure why this value was chosen. This value can be changed per further discussion.
ES-301 Operating Test Review Worksheet Form ES-301-7 2
Changed task standard as specified.
SRO-A2 EC 2.2.14 2
X X
X E
S NRC: The I/C specifically indicates that the applicant should document the required log entry.
As this is an administrative JPM, documenting the log entry for this condition should be a critical step for this JPM.
Cue for providing a standard log in JPM step 4 should be removed. NOP-OP-1014 Step 4.6.4.4 clearly indicates what information should be included in the log entry. In addition, generating the log entry is required as a part of the initiating cue (see above).
Indicate in the initial conditions that the applicant is the Unit Supervisor.
Response
JPM changed as specified.
SRO-A3 RC 2.3.6 3
S NRC: None.
Response
Validation Comments: Fix circle slashes, procedure cover sheet should have a verification stamp, change inoperable to not functional in the I/Cs.
SRO-A4 EP 2.4.43 2
X X
X E
S NRC: Add to I/C that the start time and date of the JPM should be added by the applicant to the DBEP-010 block 3 as the classification time and date.
It must be clear that the entire standard of JPM step 3 is critical. The comment indicating the 15-minute nature of picking up the phone and when that time is marked is appropriate, but the action of correctly reporting the data to the initial local phone recipients and recording the information on the DB-EP-012 is also critical.
JPM Step 7 should be requesting call back IAW with RA-EP-02110 step 6.3.9.a not 6.3.7.a.
TIME CRITICAL
Response
JPM changed as specified except JPM Step 7.
RA-EP-02110 6.3.7.a is the correct step.
ES-301 Operating Test Review Worksheet Form ES-301-7 3
Validation Comments: Remove step 2 (SM signature will be on sheet provided to applicant),
add cues to step 3 for 4 way phone prompts as the phone does not work in plant or simulator, remove step 7 as unnecessary as applicant will have already read this information off in step 3.
ES-301 Operating Test Review Worksheet Form ES-301-7 4
1 Simulator/In-Plant Safety Function and K/A JPMs S1 2
006 A4.07 3
S NRC: None.
Response
S2 4S 061 A2.04 2
X E
S NRC: Performance Standard for JPM Step 9 should specifically identify what proper Steam Generator level should be based on plant conditions and IAW SR4.
JPM Performance Step 9 incorrectly lists that MDRFP flow should be limited to < 1000gpm on FI 5879. DB-OP-02000, Attachment 5, Step d. states that flow is read on FI 5876.
FREE SAMPLE Alternate Path
Response
- 1.
Added what proper SG level is. (49 inches)
- 2.
Corrected flow indicator to FI5876.
S3 7
012 A4.03 2
S NRC: None.
Validation Comments: Remove step 8 as doors will need to be reopened to refresh simulator Initial Conditions.
P1 6
064 A2.12 2
S NRC: None.
Validation Comments: Remove I/C bullet about ESOMS handheld.
Fix I/C abbreviation for SBODG.
Add cue for tachometer reading 780 RPM when the DG is operating at 900 RPM.
P2 8
068 AA1.21 3
X E
S NRC: Task Standard indicates that only steps 4 and 5 of Attachment 3 need to be performed as critical steps. Attachment 3 step 6 also includes critical steps. Modify task standard to indicate steps 4-6 of Attachment 3.
Response
Modified task standard as requested This JPM is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 5
Facility: DAVIS-BESSE Scenario: 1 (Low Power)
Exam Date: FEBRUARY 2021 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
MDFP to MFP2 E
S Normal Event NRC: Event termination criteria still lists the original CAC 3 as 1 failure instead of CAC 2.
Response: Corrected as noted 2
Raise Power S
Reactivity Event 3
CAC 2 High Bearing Temp X
X E
S NRC: ES-D-1 incorrectly attributes the TS call for this event to event 4 in the Event Type box.
Response: TS call changed to event 3 4
PZR Level Temp Comp Instr Fail X
S ATC manually controls Make-up flow to restore PZR Level to normal.
5 SW Pump Trip X
U S
NRC:
- 1.
Action to complete DB-SC-03023, Off-Site Sources should be directed by the shift. It demonstrates Competency 6.c for the SRO to complete TS required actions. The shift can direct any imaginary person to complete it, but they must demonstrate that they need to have someone complete it within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Remove the cue from the SM that another operator will perform this action. This is one of the few TS actions that may have to have been completed prior to the end of a scenario.
- 2.
Pages 2 and 3 of this event in the D-2 incorrectly call this event 4 instead of event 5.
Response
- 1.
Cue was meant to be given only if asked. Added a note to clarify when cue should be given and added If asked to cue.
- 2.
Corrected as noted 6
Large LOCA X
E S
NRC:
- 1.
Will SW pump 3 be running as 2 by the start of this event or will the shift be obligated to shut down the Division 2 EDG?
- 2.
The D-2 incorrectly calls this events 5 & 6 instead of events 6 & 7.
Response
- 1.
SW Pump 3 will NOT be running. The EDG is required to be shutdown per SR 6 if CCW Temp rises to 130F. Temperature will not exceed 130F during the scenario. The crew may elect to have the EDG shutdown as manpower and time allows.
- 2.
Corrected as noted 7
LPI Pumps Fail X
S ATC manually throttles LPI through both loops to not exceed 4000 gpm total and not be less than 1350 gpm in either loop.
Validation Comments: Change event to both LPI pumps fail to auto start on ESFAS.
Applicant will be able to start 1 LPI and will have to cross tie as there will be a leak in the
ES-301 Operating Test Review Worksheet Form ES-301-7 6
line that the pump starts in. In addition the 20 minute TCOA clock will start when the crew enters Attachment 10 for Large LOCA actions.
7 0
0 0
0 2
2 5
E S
NRC: Address issues identified above.
This Scenario is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 7
Facility: DAVIS-BESSE Scenario: 2 (Free Sample)
Exam Date: FEBRUARY 2021 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
Stop Condensate Pump 1 E
S Normal Event NRC: Plant status handout has conflicting information. In the top general data section, it states that plant power is 90%. Lower on the document and on the D-1/2 it states reactor power is 93%.
Termination step incorrectly states, cue Event 2, Deaerator Level Transmitter Failure.
Should say RCS Pressure NNI failure.
Response
- 1.
Initial power level was changed after validation. Plant Status Handout changed to 93%.
- 2.
Cut and paste error. Corrected 2
RCS Pressure NNI Fails Low X
S ATC manually controls RCS pressure with heaters.
3 CW Pump High Temperature S
4 MU38 Fails Closed X
X X
E S
NRC: Steps that only require the applicant to Verify the condition of valves when performing Attachments 4 and 5 of DB-OP-02512 should be open bulleted if they will not require a verifiable action on the part of the applicant. It is necessary to distinguish which steps must be performed.
Response
- 1.
MUP 1 Trip changed to MU38 Fails Closed to prevent overlap with the written exam.
- 2.
Changed as requested, Verifiable actions are closed bulleted and equipment checks are open bulleted.
NRC: TS 3.6.3 Required action A.2 should be entered as well to verify isolation every 31 days.
Response
Added Required Action A.2
ES-301 Operating Test Review Worksheet Form ES-301-7 8
5 Small RCS Leak X
E S
Reactivity Event NRC: ES-D-1 and event summary state leak is ~200 gpm. D-2 action page indicates leak is ~275 gpm. These values should be matched.
List specific valves to be operated for piggy-back operation per Attachment 2 in the ES-D-
- 2. This is to assist the examiners.
Response
- 1.
Actual value is ~275 gpm. This value was changed after validation. Verified values are matched.
- 2.
Listed specific valves per Attachment 2 on ES-D-2 6
LOOP/LOSCM S
Validation Comments: Removed CT-2 restoration of HPI. Due to the nature of the leak there was not a safety significance for this CT.
7 EDG 2 Trip/HPI Fails to Auto Start X
E S
NRC: Be clear which steps must be completed with a verifiable action to accomplish CT-8.
Specifically, closing AD 301 to energize D2 prior to energizing C1 or D1 appears to be an action which must be accomplished to complete the CT.
Response
Marked CT verifiable actions with an asterisk 7
0 1
0 0
3 2
7 E
S NRC: Address issue identified above.
This Scenario is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 11 Facility: DAVIS-BESSE Exam Date: FEBRUARY 2021 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 1
7 1
2 0
2 0
9 E
2 7
0 3
0 2
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.
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 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.
2 + 4 + 6 1 + 3 + 5100%
ES-301 12 Form ES-301-7 Facility: DAVIS-BESSE Exam Date: FEBRUARY 2021 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 5
0 3
2 Sim/In-Plant JPMs 5
0 1
4 Scenarios 2
0 2
0 Op. Test Totals:
12 0
6 6
0 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).