ML21356B725
| ML21356B725 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/28/2021 |
| From: | Gregory Roach NRC/RGN-III/DRS/OLB |
| To: | |
| Roach G | |
| Shared Package | |
| ML21055A847 | List: |
| References | |
| Download: ML21356B725 (30) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Exam Date: SEPTEMBER 27 - OCTOBER 8, 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 2.1.7 2
X E
S NRC: JPM Step 6 should not be critical. It is simply verifying data is properly recorded which it is. JPM step 4 requires the applicant to convert the given DVM determined current values by multiplying by 1000 so there is an actual action to performed, so I am ok with this step remaining critical. This flaw is considered an enhancement as the JPM remains valid with at least 2 critical steps remaining when step 6 is no longer considered critical.
The task standard can be edited to remove verify - focus should be on using the completed calculation to identify the calculation error, and then determine acceptance criteria not met.
Response
Removed JPM Step 6 from Critical Tasks. Revised Task Standard to remove verify and replaced with use completed calculation NRC validation comments:
Task standard - revise to say that the applicant will determine that N41 is above the acceptance criteria of 1.02 vs the error is in
Response
Replaced The error will be with The candidate will determine that N41 is (above acceptance criteria)
SRO-A1.2 COO 2.1.5 2
E S
NRC: A 20 minute validation time seems much too long for this JPM. I recommend a value of 10 minutes.
Response
Licensed SRO validation average time is 12 minutes.
Reduced time to 15 minutes.
NRC validation comments:
SA-1-06-2, Evaluate shift staffing Add statement in cue /stem that none of the STA
ES-301 Operating Test Review Worksheet Form ES-301-7 applicants have worked overtime in last 5 weeks (this is related to statement in stem about ESOMS being unavailable).
Add evaluator note that Charles Daniel would be in violation of working more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period (work hour rules violation)
Response
Added note to stem that none of the STAs called has worked overtime in the last 5 weeks. Annotated Charles Daniels for violating 72 hrs/ 7 days WHR NRC: This JPM is now SAT.
SRO-A2 EC 2.2.23 2
E S
NRC: None.
Response: None NRC validation comments:
Add cue that active MSIV accumulator pressure is something greater than 4800 #
Add cue that there are no risk informed completion times in effect.
Response
Added cues as stated. Changed Circle Condition A from closed bullet item to open bullet item.
SRO-A3 RC 2.3.4 3
X X
X E
S NRC: Since RAD 3.3 is applicable and requires a 30 day written report to the state, has SAF 1.9 been assessed correctly? Reports to the state are covered under SAF 1.9 when they involve the exposure of radioactive materials to onsite personnel. Since this a 30 day written report, that may preclude SAF 1.9 reporting. Just looking to ensure you assessed this. I do not want a conditional answer key. It is either correct or not for the purposes of the exam.
Modified: Stem scenario was changed and the applicant no longer is required to make an EAL determination, but does have to determine the reporting time requirement.
Response: SAF 1.9 was assessed and determined to not be applicable in the given scenario. The required reporting requirements to the State and to the NRC are both 30 day written reports, per RAD 3.3. The understood intent of SAF 1.9 is to ensure the NRC is informed of events that have the potential draw additional media attention from reports to other governmental agencies and press releases; especially when they would not otherwise be informed. Based on the given scenario not meeting the reporting criteria of 10 CFR 20.2202(a), it is unlikely to meet the threshold criteria of SAF 1.9. Additionally, when it is expected that a state notification per LS-MW-1320 is required and meets the threshold of SAF 1.9 then the notification to the NRC is included, as shown in RAD 3.4.
ES-301 Operating Test Review Worksheet Form ES-301-7 We also do not believe it likely to be selected by the candidates, as they are instructed to screen only for Federal reportability requirements, and we had no incidents of SAF 1.9 being chosen during the validation process.
NRC validation comments: Edit cue to just say the persons TLD is read and is found to be reading 9 rem. Delete the rest of the story to avoid need to determine how to prevent it being a loss of control.
Response: Removed excess verbiage from stem.
SRO-A4 EP 2.4.38 2
S NRC: None.
Response: None RO-A1.1 COO 2.1.19 2
X U
E S
NRC: This is an Admin JPM. The applicant needs to demonstrate that they know how to complete Data sheet D-1.
There should be a key provided to the examiner with the expected values filled in.
Add a phrase to the Task Standard indicating that Data Sheet D-1 is to be completed by the applicant in the course of completing the calorimetric calibration.
All steps that are required to be completed to perform the calorimetric and fill out D-1 (requiring action by the applicant) need to be critical steps. This would include, JPM steps 2, 3, 4, 7, 13, 14, 15, 17, 18, and 20. These are the steps that if they are not performed the applicant will not be able to complete the Task Standard. (U)
FREE SAMPLE
Response
Data Sheet D-1 key provided. Statement added to Task Standard. Specified steps marked as critical.
NRC: The key appears incorrect in that NI44 should be adjusted to 99.93% based on Data Sheet D1 Step 9 which indicates that the value is determined by step 8 - step 6
[99.00 - (-0.93)]. The Data Sheet indicates power should be adjusted to 99.99%.
Response: Corrected 99.99% to 99.93%. Revised calculation step to show equation and work. Each individual is allowed 0.5% deviation in reading the gauge. Revised step takes that deviation into consideration.
NRC validation comment: Need simulator to be stable when they do the readings. Please make changes needed.
Response
IC has been re-snapped after stabilizing at 99.93% on 10 minute calorimetric. Changed calculations for Step 14
ES-301 Operating Test Review Worksheet Form ES-301-7 and 15 to NI channel - 99.93 to more accurately reflect candidate calculation with margin of error from initial reading.
RO-A1.2 COO 2.1.25 2
X E
S NRC: None.
Response: None NRC validation comment: based on wording of the task standard, Steps 3 and 5 should be critical.
Response
Marked steps 3 and 5 as critical steps NRC: This JPM is now SAT.
RO-A3 RC 2.3.7 2
X E
S NRC: The cue to provide the applicant RP-AA-410 when the RWP is given is not appropriate. The applicant should determine from the RWP that they require this procedure.
When they determine this, they can then be given the procedure.
Response: Cue changed, and cue added, to provide the candidate with RP-AA-410 only upon request.
NRC validation comments:
Delete cue before #1 (we dont need to ask them where to go to get RWP)
On student answer sheets: add ALARM in between Dosimetry settings Add evaluator note that for all dose alarm settings, they need to have two answers - one for neutron and gamma Add a cue that says ARGOS monitor is operable Add evaluator note to key that another acceptable answer is electronic dosimetry with neutron monitoring and DLR since some newer electronic dosimetry monitors neutron and gamma dose
Response
Made changes as described. Deleted cue before #1.
Added alarm to student answer sheets. Added note for evaluator for requirement of two answers for dose alarm settings. Added cue for ARGOS operable. Added evaluator note about additional acceptable answer.
Changed modesty garments from closed bullet to open bullet.
RO-A4 EP 2.4.43 2
X E
S NRC: Why is this JPM time critical with a time of 10 minutes?
There is no NRC requirement to activate the ERO within 10 minutes. Does the facility have a specific commitment to the NRC to activate Everbridge within 10 minutes? It is
ES-301 Operating Test Review Worksheet Form ES-301-7 noteworthy that procedure EPA 17-001 does not mention any time limits or expectations for activating the ERO.
TIME CRITICAL Response: The time limit is documented in EP-AA-122-300-F-01 DRILL AND EXERCISE EVALUATION CRITERIA under Objective / Demonstration Criteria E.2.2 Notification. The document references NUREG-0654-FEMA-REP-1 Rev1 and specifically [FB0654] Fleet Response to IER L2-11-39, Lack of Timely Response Organization and Emergency Response Facility Activation for the requirement.
NRC validation comments:
Need to uncheck time critical box on the JPM summary sheet.
Need to delete statements in applicants cue and examiners cue sheet that it is time critical.
Response
Unchecked yes box for Time Critical. Checked No box.
Added line to 10 minute ERO expectation note - Not applicable to ILT NRC: This JPM is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 LOD (1-
- 5)
I/C Focus Cues Critical Steps Scope Overlap Perf.
Std.
Key Minutia Job Link U/E/S Explanation Simulator/In-Plant Safety Function and K/A JPMs A
Perform 50 gal boration 1
004A4.12 2
X E
S NRC: JPM Step 10 needs to specify what actions the applicant MUST take to stop the boration manually.
Modified: Converted the JPM to alternate path.
Response: Added specific steps required to take to terminate the boration. Added note on possible alternate actions the candidate may take.
NRC validation comment: Change the task standard to allow them to have one minute (70 gal, not 60 gal) to stop the boration.
Response
Changed task standard to 70 gal vice 60 gal.
B Raise 1C SI accumulator level 2
006A1.13 2
X E
S NRC: JPM Step 2 should have a separate bullet for RWST Makeup from Boric Acid Blender.
Why is verifying closed 1SI8802A in JPM Step 6 not required (closed bullet) while 1SI8802B is?
For JPM Step 18, the performance standard should be specific that the pump discharge pressure should be verified that it is < 50 psig.
Initial conditions - edit to say, 1BOL 5.1 was been entered 20 minutes ago due to the low level.
Response: Added separate bullet for JPM Step 2.
Both line items for JPM Step 6 are closed bullets.
Added bullet item for JPM Step 18 to verify
ES-301 Operating Test Review Worksheet Form ES-301-7 pressure less than 50 psig. Initial condition sentence corrected as recommended.
NRC validation comment:
- 1.
Remove the NOTE before JPM Step 1 that all prereqs and precautions are met. They will get the procedure from the simulator and will read these. Removed
- 2.
The applicant might take actions to reposition the SVAGs, and if they do, there is a possible TS entry while they are aligned to the other train. If so, include in the script. Added note
- 3.
Step 20 is N/A. Add note that they are not required to notify chemistry. Added note and removed step to notify chemistry
- 4.
Added the following cue to the guide for operation of the 1B SI Pump If the candidate provides use of the 1B SI Pump as a means to raise SI Accumulator level, direct the candidate to use the 1B SI Pump to raise level. Added cue NRC: This JPM is now SAT.
c Align ECCS to cold leg 3
011EA1.11 3
X E
S NRC: Will containment be adverse based on the LOCA conditions? This will impact the JPM Step 8 performance standard.
The Task Standard incorrectly indicates that ES-1.3 Steps 1 - 8 will be performed. The JPM performs steps 1-7 only.
TIME CRITICAL Response: No, containment will not be adverse.
Setup for the JPM has the following conditions.
CNMT Press is 1.86 psig (containment cooling has reduced containment pressure below the adverse setpoint). Containment Floor Water level is 20.
RWST Level is 48%. 8 inches will satisfy the procedure step (adverse value is 13 inches and will also be satisified).
Changed the Task Standard to perform 1BEP ES-1.3 Steps 1-6. Time critical steps are complete by the end of Step 6.
NRC validation comments:
- 1.
Add setup instruction for examiner to have a headset for communicating with the booth during this JPM. Added
- 2.
Add to the task standard a statement that the applicant must energize and close CV9415.
Added
- 3.
Delete Step 3 (notify emergency director)
Deleted
ES-301 Operating Test Review Worksheet Form ES-301-7
- 4.
Add note above Step 6 on Page 7 (check CC to RH HX flow) that is also start of an abnormal path. Moved note
- 5.
Add steps after Step 6 that they must recognize flow is less than 5000 gpm, and to call operator to energize CV9415, and then open it, which are all critical steps. Added and made critical
- 6.
Step 10 - the part of this step to check open the CNMT sump valves SI8811A and B is NOT part of the critical step. Made non-critical portions open bullet NRC: This JPM is now SAT.
d Restore FW 4S 059A4.11 3
E S
NRC: None.
Response: None NRC validation comments:
- 1.
Add to Task Standard and add an examiner cue that candidate should restore flow to the U1 SGs prior to reaching 10%NR level (which is entry criteria for BFR H1). Added to task standard and added note
- 2.
Add setup instructions that the examiner needs to wear headset to communicate with the booth operator. Added NRC: This JPM is now SAT.
e SX Flooding 5
022A2.05 3
X U
S NRC: In order to comply with the Task Standard Steps 7 and 8 should be critical as this is fundamental to achieving the described final line-up.
Response: JPM Steps 7 and 8 marked as critical tasks.
NRC validation comments:
- 1.
Applicant cue sheet not same as the examiners cue. Add RNO to last sentence in applicants cue sheet so it reads as Step 6.d RNO. Added
- 2.
In the task standard, delete the 1B and 1D RCFCs running in high speed from the last sentence. Deleted
- 3.
To the NOTE before JPM Step 6, add the first sentence The applicant may perform Added
- 4.
JPM Step 7 should NOT be marked as a critical step, and please add that the applicant MAY start previously secured RCFCs. Removed from critical steps. Added note.
f 6
064A4.06 2
E NRC: None.
Response: None
ES-301 Operating Test Review Worksheet Form ES-301-7 Synchronize a D/G to a Bus and Load S
NRC validation comments:
- 1. Include loading range in Task Standard of above 1000 KW but less than 1500 KW. Changed task standard. Added note before loading step.
- 2. Add a step to adjust KVARS to between 0-1000 KVARS (Not critical because they will be at around 0 initially and will only adjust middle of the band.
Added
- 3. Add another NSO will complete the loading sequence at the termination of the JPM. Added Added setup instruction to place sync switch in ACB 1414.
g RCP Thermal Barrier Leak 4P 003A4.08 2
E S
NRC:
Response: None NRC validation comments:
- 1.
Please add note in the setup instructions for the NRC examiner to have a headset for talking to the booth operator for sim JPMs (for this one, it is required). Added
- 2.
The step at JPM Step 7 on Page 8 to Determine 1B RCP seal injection flow is > 13 gpm needs to be marked as a critical step since if they dont figure that out then, they wont be able to perform the subsequent steps and meet the task standard. Marked step 7 critical and added to critical step list Revised task standard to properly reflect step 12 NRC: This JPM is now SAT.
h RMS Functional Test 9
071A4.25 2
X E
S NRC: The K/A listed on the summary page is incorrect. Match the K/A on the 301-2.
In termination cue, add a statement that another NSO will perform testing of the 0PB102 detector since the applicant was directed to test both channels in the initiating cue.
Response: Revised KA to match KA from ES 301-
- 2. Statement added to termination cue.
NRC validation comments:
- 1.
For JPM Step 5, when they enter a value, it must be below the current value that is in the system, so please add what the value should be. The actual value is not relevant, as long as it is below current indicated radiation value. Added any value below current indicated radiation level to step.
Added note to identify the location of the current radiation reading on the
ES-301 Operating Test Review Worksheet Form ES-301-7 screen.
- 2. For JPM Step 9, make open bullets for Select channel items, and all below it in that step.
- 3. For terminating cue, include that another NSO will complete the peer check and the testing of 0PB102. Added NRC: This JPM is now SAT.
I Locally close AF valves 4S 2.1.30 2
X E
S NRC:
Since Step 1 is not going to be a critical step, remove that from the task standard.
Response: Removed statement from Task Standard referencing locating the valves.
Note: Modified JPM to use UNIT 2 to avoid impacting outage activities NRC: This JPM is now SAT.
J Bus duct response 6
062A2.01 2
X U
E S
FREE SAMPLE NRC:
I/C:
Please tell them the Mode and power level of the unit as part of the initial conditions.
You are an EO in the initial conditions.
Since they are going for a licensed position extra operator is more appropriate.
I think it would make the initial cue clearer to the applicant if we say this: The Unit 2 NSO directs you to determine the cause of the alarms per 2BOA TG-9, Step 1.
Performance standard:
For the task standard, please specify the unit number and fan identifier The JPM ends once they check conductor temperatures (Step 9 of the JPM, which is listed as a critical step, indicating it is intended to be a step that is necessary to accomplish the task standard). However, the task standard is to start the STBY fan, and that occurs before they check temps in the procedure. Please broaden the task standard if you want to keep temp checks as part of the JPM. If not, we should end the JPM before they check temps. If you do want to broaden the task standard to include them, then I recommend rephrasing the task standard like this: Candidate restores duct cooling by starting the B fan, verifying the B discharge damper is open, and checking conductor temperatures are within the acceptable limits for continued operation identified
ES-301 Operating Test Review Worksheet Form ES-301-7 in 2BOA TG-9, Step 3. If you go choose to do this, then I also recommend editing the initial cue to tell them that they have been directed to investigate the cause of the alarm using 2BOA TG-9, Step 1, and then adding cues to tell them to check that temperatures are within acceptable limits for continued operation.
If you want to end the JPM after they verify the B fan is providing cooling, then I recommend rephrasing the task standard as this: Candidate restores duct cooling by starting the B fan and verifying the B discharge damper is open IAW 2BOA TG-9.
Critical steps:
Why is Step 5 a critical step (place A Fan control switch (_MP01C) in A/T)? (U)
Other:
JPM Step 8 says Proceed to Step 2, which is to verify at least one fan is runningBut the Standard is to inform Unit NSO of status. Why do we expect them to do this at this step?
At JPM Step 9, it says A and B phase, but the procedure says to check A and C phase.
Response
Added mode and power level to IC.
Changed EO to Extra NSO Expanded Task Standard to include temperature check.
Changed JPM step 8 to mirror procedure Unit specifier was not added to JPM to allow flexibility to perform the JPM on either unit at time of execution.
Placing the control switch for the tripped fan into A/T is what clears the alarm in the MCR, enabling the alarm for the newly started fan.
This is critical because the control room operators are aware they have to reduce power to 650 MWe if there is no bus duct cooling, and without this indication, they may have to begin ramping before the EO in the field calls to report status.
JPM Step 9 corrected to phase A & C
ES-301 Operating Test Review Worksheet Form ES-301-7 NRC: Is it possible to provide a picture of the temperature indicator the examiner will cue the applicant with instead of just telling them the value in JPM Step 8?
Response: Working on generating a picture for use. Instrument requires ladder and two individuals to obtain picture.
NRC validation comments:
- 1.
Mark the step to take the other pump switch to A/T as a critical step due to wording of task standard. Marked step 5 critical Need to change cue for the temperatures to say that they are as indicated if they use any other indication that is not the right indication that is located under the duct, and if they do look at correct indication, then we will say 90C. Added If candidate reads incorrect gauges, Temperatures are As indicated to cue
- 2. Need to make sure there is a cue for each switch indication / indications. Facility to check. All indications have cue.
K Operate fire detection/alarm equipment 8
086A2.04 3
X U
S NRC: Update the JPM Summary page to indicate that this is an alternate path JPM.
JPM Step 14 should be marked as a critical step.
Response: Updated the JPM Revision Summary denoting it as an Alternate Path. Marked JPM Step 14 as a critical step.
NRC validation comment:
Need to mark JPM as alt path on the JPM summary page.
Response
Checked Alternate Path: Yes box on summary page.
Specified Unit 2 throughout JPM to avoid impacting B1R24 NRC: This JPM is now SAT.
ES-301 Operating Test Review Worksheet 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 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Scenario: 2 Exam Date: SEPTEMBER 27 - OCTOBER 8, 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
IV/RV Surveillance X
E Normal Event NRC: D-2 does not include procedure step F.1.b.5) which has the applicant select EXECUTE in the popup window.
Response: Added step to D-2 Event 1.
2 Ramp down X
U Reactivity Maneuver NRC: ATC actions listed on page 12 are for a dilution. The event is a down power which requires the ATC to perform a boration. The parameters the ATC is to monitor should change in the opposite manner as is indicated in the D-2 due to a boration being performed and not a dilution.
Response: Replaced dilution steps with boration steps; replaced reference to 1BGP 100-4T1.1 with 1BGP 100-4T2.
3 PZR Level Controller Failure X
S ATC takes manual control of pressurizer level.
4 VCT Level Failure X
S 5
CC Pump Trip X
S BOP manually starts standby CC pump after failure to auto start.
6 DG Control Power Failure X
S 7
CC685 Closure X
S 8
Steam leak in containment X
X E
NRC: Group 3 containment isolation monitoring lights should be verified LIT. D-2 incorrectly states NOT LIT. I am guessing this is a cut and paste error from Scenario 1.
Response: Changed statement NOT LIT to LIT 9
CS Pump Fails X
X E
NRC: Include equipment numbers in the D-2 for valves manipulated when aligning SX cooling towers.
Response: Added EPNs for the valves in SX Tower Alignment
ES-301 Operating Test Review Worksheet Form ES-301-7 9
0 2
1 0
2 2
5 E
S NRC: Address concerns above for events 1, 2, 8, and 9.
Response: Concerns addressed and documented above.
NRC validation comments:
CT-17: Need to add 1A AND 1D SGs need to be isolated.
CT-3: CTMT pressure did not rise to 50# and is not expected to do so, so the boundary criteria needs to be revised. We talked about changing scenario to have a failure of both CS pumps to start when containment pressure rises to 20#. The crew will then have to go to Att B then Att C to start a pump. Boundary criteria is to start a CS Pump before exiting E-0.
Event 1: Add cue to move to the next event at the start of the 10 minute waiting period. It will be a complete SR, not a partial SR. After they do the first valve, we will call in Event 2. Change D-1 and D-2 (delete partial SR).
Event 2: ATC actions include manually inserting rods, but the rods will be left in auto. Please delete this and add statement that they will be left in auto.
Event 3: For CUE, add Regen HX temp alarm (A1)
Event 4: ATC action says to Place 1CV112A Letdown Diversion to VCT or HUT tanks valve to HUT as necessary, and should just say, Place 1CV112A Letdown Diversion to VCT.
Event 6: On Page 16, LCO 3.5.2 ECCS is listed, but should be to enter LCO 3.0.3 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Event 7: please add to evaluator note, and when CC685 is open, continue with Event 8.
Notes for us: need to make sure ATC gets some component failures - may need to intervene and tell CRS to give one event to the ATC, esp. if its an SRO instant in that ATC position for this scenario.
Byron:
Removed 1A SI pump OOS from Turnover and summary.
Added 1A and 1D SGs to CT-17
ES-301 Operating Test Review Worksheet Form ES-301-7 Changed Event 1 from Partial surveillance to surveillance performance. Changed summary, D-1, and Turnover.
Removed Z-1 Red path from CT-3 and replaced with out of 1BEP-0.
Changed CS pump failures to neither pump starts automatically. Updated D-1 and summary for Event
- 8. Crew will be required to manually start pumps per 1BEP-0 Attachment C. Termination criteria changed to transfer to 1BEP ES-1.1.
Added setup to implement SBT Data capture.
Event 2 removed reference for manual operation of Control Rods. Added Rod control will remain in Auto.
Add cue for Event 3.
Changed ATC action to place 1CV112A to VCT for Event 4.
Removed 1A SI Pump OOS. LCO 3.0.3 no longer required.
Added with 1CC685 open to evaluator note for Event 7.
Added evaluator note in Event 4 to ensure ATC performs actions.
Changed termination statement to read critical tasks complete and transition to 1BEP ES-1.1 is declared.
NRC: This SCENARIO is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Scenario: 3 (LOW POWER)
Exam Date: SEPTEMBER 27 - OCTOBER 8, 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
Raise power and synch to grid X
E Normal Event Reactivity Maneuver NRC: Include specific action steps from BGP-100 Step 27 to synchronize the main generator and Step 72 to raise power in the D-2.
Response: Added Steps F.27 and F.72 to D-2 2
PT131 Failure S
ATC controls letdown pressure in manual.
3 PZR PORV Leaking X
X E
NRC: Will the leaking PORV contribute to RCS Operational leakage which could cause the applicant to temporarily enter TS 3.4.13 before the associated block valve is closed? Since we set the leakage rate, we should know whether it should be entered or not. No maybe enter Tech Specs.
Response: PORV leakage is 5 gpm identified leakage. This will not require entry into TS 3.4.13 as it is below the 10 gpm threshold. The potential for the candidates to enter the TS is a possible conservative entry until the leak rate can positively identified.
4 Loss of Instrument Bus 114 X
U NRC: No maybe enter Tech Specs. Either TS 3.8.7 is appropriate to enter or not. Greater detail will need to be provided if it is expected that the applicant is to enter TS 3.8.7.
Response: Removed the reference to LCO 3.8.7. Entry into the TS is not required.
5 SB LOCA 1B SI Fails to start X
X U
BOP manually aligns ECCS systems with a LOCA signal present.
NRC: Why are we expecting high radiation levels on the A & D steam generators and subsequently having the ATC isolate AF to these S/Gs? This is a LOCA and not a SGTR (Pg. 19).
Response: Removed references to SGTR related indications.
6 CV112 Fails to swap to RWST X
S ATC manually swaps ECCS suction from the VCT to the RWST.
6 0
3 0
0 2
2 5
E NRC: Address concerns above for events 1, 3, 4, and 5.
ES-301 Operating Test Review Worksheet Form ES-301-7 S
Response: Concerns addressed and documented above.
NRC validation comments:
Initial conditions: Cant have 1A SI Pump OOS at beginning of scenario since they will be in LCO 3.0.3 when loss of instrument bus occurs due to loss of auto start for the 1B SI pump. Change scenario setup so that 1A SI pump is not OOS at the beginning of the scenario, and we can retain CT-7. Removed 1A SI OOS. Changed to 1A SI pp fails to start.
Event 1: Add step for adjusting VCT level during dilution.
Added step to monitor VCT level and adjust 1LK112 as desired Event 1: Remove sync main generator to grid actions.
Once BOP has done the actions to ramp the turbine to 1800 RPM, we will go to Event 2. Event 1 can end on Page 10 after BOPs steps to ramp turbine to 1800 RPM, and that can be counted as a normal event for the BOP.
Removed steps for event 1 after raise turbine to 1800 RPM Event 2: Add evaluators note that if the crew isolates letdown, they should restore letdown or excess letdown before moving to the next event, and if they restore normal letdown, they will have to control letdown in manual due to the loss of indication. Added evaluator note Event 3: 1RY456 is leaking, so the scenario guide should be updated to say the ATC should close 1RY8000B, not 1RY8000A/B (page 15). Corrected PORV isolation step Event 3: need to delete LCO 3.4.11 Condition A and add Condition B, B.1, B.2., B.3. Need to also add a cue to respond to their call to remove power. Reviewed with site rep, determined A is correct condition.
Event 4: During validation, the crew took an action to shut down the instrument inverter for the affected bus. If the applicants are expected to do this, please add to the scenario guide. Added step to direct EO to shutdown inverter Event 4: Please add evaluator note for step for ATC to CHECK TAVE-TREF DEVIATION (Page 17) that Tave and Tref deviation will not be within 1F due to where they were in the startup, and they should decide to proceed on. Please add cue to tell the crew as the SM to move on without doing that step, in case they make a call to the
ES-301 Operating Test Review Worksheet Form ES-301-7 SM requesting permission. Added evaluator note and cue Event 5/6: For the CUE on Page 19, please add Containment Drain Leak Det Flow High annunciator, too. Added annunciator to event NRC: This SCENARIO is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Scenario: 4 Exam Date: SEPTEMBER 27 - OCTOBER 8, 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
AFW Stroke Test S
Normal Event 2
Ramp Up S
Reactivity Maneuver 3
Dropped Rod X
S 4
CRDM Exhaust Fan Trip X
S 5
1B CD/CB pp Trip S
BOP manually starts standby CD/CB pump which fails to auto start.
6 CV121 Fails Closed X
E ATC manually restores make up flow and pressurizer level.
NRC: Scenario Overview states make up flow fails low to 52 gpm, D-2 indicates 25 gpm, please confirm which is accurate.
Response: Corrected D-2 to read ~52 gpm.
7 PZR Pressure Ch 458 Fails Low X
U NRC: Will Function 6 of TS 3.3.1 OTT also be impacted by channel PT 458 inoperable. As operators must remove the failed pressure instrument from OTT, it would appear it should be identified as a required function of the TS to be entered.
D-2 also incorrectly lists Condition E for TS 3.3.2, should be Condition D. D-2 does correctly call out required action D-1.
Response: Yes Function 6 will also be impacted. It has been noted in the guide. TS Actions mirrored actions taken for Function 8, so no additional conditions applied. TS 3.3.2 corrected Condition E to Condition D.
8 Spurious SI X
U NRC: Evaluator note indicates that RCPs must be tripped within 10 minutes of reaching the trip criteria. CT-16 is written with a boundary criteria which indicates that the RCPs must be tripped before exiting BEP-1. The crew is not expected to enter BEP-1 during this scenario. It is in BEP-0 and then transitions to BCA 1.2. Correct the boundary condition removing BEP-1 transition. If it is determined that 10 minutes
ES-301 Operating Test Review Worksheet Form ES-301-7 is a time critical action, provide technical justification in the D-1/D-2. Otherwise remove the examiner note.
Response: CT-16 boundary changed to the 10 minute trip criteria. Excerpt from PWROG-14043-NP_3 ERG Rev 3 added to CT-16 description to provide additional background for time requirement. Examiner note left as is to identify that tripping the RCPs may not occur at that specific point in the procedure.
X U
NRC: Why are we expecting MSIVs to be closed and then not being able to be manually closed on page 24 during Att. B actions? This appears to be a cut and paste flaw from a different scenario.
Response: Removed reference to MSIV failing closed.
9 2
2 7
U S
NRC: Address concerns above for events 6, 7, 8 and 9.
Response: Concerns addressed and documented above.
NRC validation comments:
Event 1: add TS 3.7.5 for AFW during SR valve testing (enter then exit). Also update the D-1 for SRO TS call.
Event 3: There were no verifiable operator actions since rod control is in manual, so event 2 needs to be changed to an event with higher ramp rate so rods can be in AUTO (for example, start at 100% power and do downpower) so ATC can have the bean.
Event 2: Add ATC action on Page 10 that ATC may lower VCT level control setpoint.
Event 4: In evaluator note, replace and with or and second and with with for preferred lineup statement (page 14).
Event 4: Page 14, add step for BOP to place 1VP03CD to PTL).
Event 5: need event termination statement.
Event 6: For CUES on Page 16, add RCP seal inj flow low alarm Event 7: on D-1, add that it is also an instrument failure for the BOP. Upon initiation of the spurious SI event, red turbine trip annunciator came in - please investigate why since this was unexpected.
Event 8: on D-1, please update title of event as Spurious Safety Injection on Train A and also update event summary on Page 2 to indicate it is on Train A only.
ES-301 Operating Test Review Worksheet Form ES-301-7 Event 8/9: the crew was not able to reset SI (page 21),
and there was a comment made after the scenario that there is a malfunction that needs to be deleted -
please make changes so SI is able to be reset.
BYRON:
Changed initial conditions to 75% RTP, MOL, steady state. Removed Ramp to 100% from scenario summary, turnover, and D1.
Changed Event 2 from Normal Ramp to 1A HD Pump trip and 1C HD pump fails to start, HD Pump Runback.
Added TS - SRO to event 1, I - BOP to event 7 and Train A to event 8 on the D-1.
Changed Event 2 and Event 3 summary to reflect new HD event. Added Train A to Event 8 and 9 summary.
Added instructions to gather SBT data during scenario.
Changed Event 4 wording as suggested and added step to place fan inPTL Event 5 termination statement was lost in formatting. Restored the statement.
Added cue for Event 5 Changed D-1 for Event 7 to add BOP - I Update all references of Spurious SI to include Train A Investigation of Red First Out for the RX Trip determined that it was correct. The spurious SI had no actual SI indications to drive actuations, and alarms, for the SI. The first RX Trip signal came from the Turbine Trip caused by the SI signal.
Smart scenario update to include an automatic removal of the spurious SI signal as soon as the 1A SI Pump is running. This will allow the SI to be reset Scenario 4 events have been reordered after the introduction of the HD Pump Trip and Runback.
With the HD Runback and Rod Drop at the beginning of the scenario, validation showed that it
ES-301 Operating Test Review Worksheet Form ES-301-7 caused distracting alarms during the other events and made the 1CV121 failure nearly impossible to identify. Scenario guide and D-1 have been updated with the new order.
NRC: This SCENARIO is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Scenario: 5 Exam Date: SEPTEMBER 27 - OCTOBER 8, 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
Swap CV pp S
Normal Event ATC maintains PZR Level control in manual during pump swap.
2 Loss of Bus 141 X
S 3
CNMT Press Fails High X
E NRC: In the Instructor/Simulator Run Guide section, this event is incorrectly titled Containment Pressure Channel 937 fails low. Should be fails high.
Response: Changed fails low to fails high 4
1TI-130 Fails Low X
S ATC maintains CC Temperature control in manual.
5 1C FW Trip S
Reactivity Maneuver 6
S 7
A Fails X
S 8
Turbine Fails to Trip S
8 0
0 0
0 2
2 7
S NRC: Address concern above for event 3.
Response: Concerns addressed and documented above.
NRC validation comments:
Event 2: Need to add ATC actions for starting 1B charging pump and restoring letdown IAW BOA ESP 2. Added note to endure ATC performs CV pump start and Restore letdown.
ES-301 Operating Test Review Worksheet Form ES-301-7 Event 2: Need to add steps to secure EDG locally prior to crosstie Added step to scenery and smart scenario to depress Emerg Stop PB 1A DG Event 2: add Bus 141 restoration steps for ECCS equipment, and we want them to do these before we move on to Event 3. Added BOP steps from BOA elec-3 Event 2: add note that crew should discuss bus crosstie limits. Added note that crew should discuss & monitor cross-tie limits.
Event 2: add to evaluator note that ECCS equipment also needs to be restored to move to next event. Added note to ensure ECCS equipment is restored before moving on.
Note that BAR 1-3-B4 needs to be updated to refer to BOA INST 2. Added to post exam deficiency list.
Event 4: Add note on Page 15 that initially, ATC should restore letdown flow by lowering output on 1TK-0130. added Event 4: need bullet that the crew might place controller back in auto since its a spurious failure. Bullet added.
Event 4: Please update D-1 to say 1TI-130 fails low (spurious) Updated.
Event 5: Add evaluator note that we expect them to add about 180gal boron. added Event 6: Need steps in guide for E-1 done and ES 1.3, with termination at ES 1.3, completion of Step 5. Scenario termination changed Event 6: In BEP 1, add information about crew securing 1 CS pump and leave one running for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Added Event 6: in BEP 1, fix steps on Page 23 that RH pumps cannot be secured. changed Event 6: add evaluator note that RCP trip is going to be based on Phase B and CS
ES-301 Operating Test Review Worksheet Form ES-301-7 running (instead of RCS low pressure).
Added Event 6: Add CT-36 for swap to cold leg recirc prior to reaching 9% RWST level.
added Event 7: Change Event 7 so that SI does auto actuate, but Phase A fails to actuate.
changed Adjust CT accordingly. adjusted Done Event 8: Keep as BOP malfunction, but do not mark as a CT since the MSIVs will close very shortly thereafter due to the Phase B actuation if operators did not trip it.
Changed to malfunction, not CT CT list on Page 2:
Delete CT-2. deleted
Add CT for failure of Phase A to actuate.
added
Delete CT-13. deleted
Add CT-36, with boundary criteria as prior to reaching 9% in the RWST. Added Byron:
This scenario has been elected to given on Day 1 of the Operating Exam. It will keep its designation as Scenario 5.
NRC: This SCENARIO is now SAT.
ES-301 Operating Test Review Worksheet 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 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Exam Date: SEPTEMBER 27 - OCTOBER 8, 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
9 0
2 0
2 0
0 S
FREE SAMPLE, SPARE 2
8 1
2 0
2 0
8.3 E
3 6
1 2
1 2
0 20 E
4 9
1 2
1 2
1 23.1 U
5 8
0 0
0 0
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:
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.
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)
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 Operating Test Review Worksheet Form ES-301-7 Facility: BYRON STATION Exam Date: SEPTEMBER 27 - OCTOBER 8, 2021 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
0 6
3 Sim/In-Plant JPMs 11 2
7 2
Scenarios 4
1 3
0 Op. Test Totals:
24 3
16 7
12.5 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.
ES-301 Operating Test Review Worksheet Form ES-301-7 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).