ML22131A194

Ile ES-301-7

ML22131A194
Person / Time
Site:	Davis Besse
Issue date:	02/24/2022
From:	Chuck Zoia NRC/RGN-III/DRS/OLB
To:	Energy Harbor Corp, FirstEnergy Nuclear Operating Co
Zoia C
Shared Package
ML20140A262	List: L-22-061, Ile Post Exam Letter L-22-061 ML22118A330 ML22118A795 ML22131A194 ML22131A204 ML22131A211 ML22131A213
References
L-22-061
Download: ML22131A194 (24)

Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Exam Date: February 7, 2022 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 A1.1 (JPM 216)

COO 2.1.25 3

S Walkthrough comments Validation time changed to 15 minutes NRC: The JPM is SAT.

RO A1.2 (JPM 261M)

COO 2.1.18 2

X X

E S

NRC: JPM Step 4 (Step 4.7.1) performance standard incorrectly states verify 1DH831 is closed. It should verify that 1DH830 is closed.

JPM Step 13 performance standard expects the applicant to sign Section 4.y completed by line. What is section 4.y? JPM Step 10 already expects the applicant to sign Section 4.7 completed by line.

Validation time seems much too long, 15 minutes seems much more reasonable.

This JPM is listed as modified. Provide the original JPM or indicate what is modified from the original version of this JPM.

Licensee:

Changed JPM Step 4 performance standard to verify DH830 is closed.

4.y is a typo. Should be 4.7.

Removed, Sign Section 4.7 from JPM Step 13 performance standard.

Changed validation time to 16 minutes to match actual performance during crew validation.

Provided original version of the JPM Walkthrough comments Rewrote for classroom only option.

NRC: The JPM is SAT.

RO A2 (JPM 227)

EC 2.2.12 2

X X

E S

NRC: Task Standard does not agree with the performance standard of critical JPM Step 6. Critical Step 6 performance standard requires total loop flow to be calculated between 406-407 KGPM. This is an appropriate band. The Task Standard states that total flow will be calculated between 405 and 407 KGPM.

This is too wide a band. Even if the applicant does not interpolate and uses the lowest possible specific gravity (0.02166 at 2200 psia/560F) they will still calculate a total flow just above 406 KGPM.

Why are we giving the applicants Attachment 1, Page 4?

The JPM does not indicate the applicant is expected to verify the performance criteria is met. If this is expected, an additional step should be added to the JPM.

Licensee:

Changed Task Standard to match JPM Step 6 (406-407 KGPM)

ES-301 Operating Test Review Worksheet Form ES-301-7 Removed Attachment 1, Page 4 from the list of Required Materials and Initial Cue.

Walkthrough comments

1.

Made step 1 critical

2.

Added bands to answer key NRC: The JPM is SAT (Note: the underlined steam table values in Aid 3 were not significant to any critical steps and matched the MCR copy).

RO A3 (New JPM)

RC 2.3.5 2

X E

S NRC: JPM Step 3 cue indicates that the applicant should be told that another operator will place an OOS placard on RE1878B1 after the applicant determines that it is turned off. In the JPM setup instructions, an OOS is to be placed on RE 1878B1 before the JPM is started. Correct the setup instructions to match the cue and do not place an OOS tag in the instrument until it is determined to be off by the applicant.

Licensee:

Corrected the setup instructions to match JPM Step 3 cue. An OOS Tag will NOT be placed on RE1878B1 during setup.

Walkthrough comments Made into a classroom JPM.

NRC: The JPM is SAT.

SRO A1.1 (New JPM)

COO 2.1.19 2

E S

Walkthrough comments

1.

Added the specific errors to be identified to the Task Standard.

2.

Deleted JPM Step 4.

NRC: The JPM is SAT.

SRO A1.2 (JPM 278)

COO 2.1.5 4

X E

S NRC: This is a long, somewhat difficult JPM. Based on the fact that the applicant only has to determine what is wrong and is not expected to identify the actual correct values, is this a task that they would be expected to do on shift, or would this normally fall to a QNE to perform?

Licensee:

This task for JPM 262 is not normally performed on shift.

Replaced with JPM 278.

Walkthrough comments

1.

Validation time to 25 minutes

2.

Added determine reason why working hour limits are exceeded to the task standard.

3.

Revised initiating cue to include the reason why.

NRC: The JPM is SAT.

SRO A.2 (JPM 273M)

EC 2.2.37 2

E S

NRC: This JPM is listed as modified. Provide the original JPM or indicate what is modified from the original version of this JPM.

Licensee:

Provided original version of the JPM Walkthrough comments

1.

Added M-0023 drawing to references

2.

Revised Task Standard to: Review completed paperwork and identify errors, Identify Valve Open and Closed Stroke times are > Maximum

ES-301 Operating Test Review Worksheet Form ES-301-7 Permissible time, Identify LCO 3.6.3 is not met and required actions

3.

Changed Initiating Cue to:

Perform a review of DB-PF-03272 for CV5010D.

Document any errors found AND required actions on this page below.

NRC: The JPM is SAT.

SRO A3 (New JPM)

RC 2.3.14 2

E S

NRC: Validation time seems too long. 20 minutes seems more reasonable.

Licensee:

Changed validation time to 20 minutes to match actual performance during crew validation.

Walkthrough comments

1.

Changed Task Standard to:

Review DB-SC-03200, Shift Channel Check of the Radiation Monitoring System

• Identify RI4686 High Alarm light was recorded as ON (Locked-in).

• Comply with actions of ODCM Table 2-1 Action C.

• Initiate DB-SC-03200, Attachment 3, Chemistry Compensatory Actions for RE 4686.

2.

Changed Step 1 Standard to:

Identify RI4686 High Alarm light was recorded as ON (Locked-in).

• Comply with actions of ODCM Table 2-1 Action C.

• A grab sample shall be taken and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> NRC: The JPM is SAT SRO A4 (JPM 150)

EP 2.4.44 3

X E

S NRC: In the partially filled in RA-EP-01900 provided, the EAL is listed in RG1 in step 6.1.1.d, but on the answer key for DBEP-010-12 the EAL is listed as RG1.1. The correct EAL should be listed in RA-EP-01900.

Has the four-way phone been repaired?

Licensee:

The EAL has been changed from RG1 to RG1.1 in RA-EP-01900. The 4-way phone has not been repaired.

This JPM ends when the 4-way phone is picked-up. The 4-way phone is not required for this JPM as it can also be completed in a classroom.

Walkthrough comments

1.

Added wallboard as a reference.

2.

Added a phone prop to required materials

3.

Added an answer key to the JPM.

4.

Deleted cue The Emergency Response Organization is being notified of the General Emergency.

5.

Added cue Offsite notifications have NOT been completed.

6.

Removed cue, Time critical clock begins now, from step 1.

7.

Added Time critical clock, to start time.

NRC: The JPM is SAT

ES-301 Operating Test Review Worksheet Form ES-301-7 1

Simulator/In-Plant Safety Function and K/A JPMs P1 (JPM 042)

SF 1 -

K/A 007 EA2.04 2

E S

EARLY SUBMITTAL NRC:

1.

Explain why DB-OP-02000, Step 3.3 RNO 4 and the JPM Task Standard are not the same (and vs.

or).

2.

The Note for JPM step 2 should also be included for JPM Step 3.

3.

Does the 3rd Initial Condition need to be provided?

(Concern with overlap with CT-24: Shutdown Reactor-ATWS in Scenario 2)

4.

The scope of the JPM is very narrow. Can this be enhanced?

Response

1.

It is only critical to open breaker A or C and B to cause an actual reactor trip. If the applicant opened Breakers A and B the reactor would trip which is the critical nature of this JPM.

They would be subject to a comment for procedural compliance by not also tripping breaker C. Hence the difference between the procedure step and the task standard.

2.

Added note to JPM Step 3.

3.

Removed 3rd initial condition.

4.

The JPM tests the ability of applicants to locate and manually open reactor trip breakers, as well understand reactor trip logic and is therefore a discriminating test tool.

Walkthrough comments Added a note prior to step 2, NOTE: It is only critical to trip CRD Breaker A or C.

NRC: The JPM is SAT.

P2 (JPM 115)

SF 6 -

K/A 2.1.30 2

E S

Walkthrough comments

1.

Changed initial cue, (If Asked) You have a Locked Valve Key.

2.

Changed step 1 cue, to Engine speed indicates 900 RPM, vice running.

3.

Eliminated Train 1 option due to Protected Train NRC: The JPM is SAT.

P3 (JPM 226)

SF 2 -

K/A 006 A4.05 2

X E

S NRC: Performance Standard for JPM step 3 mis-spelled DISABLE (Left out E) for train 1.

Licensee:

Corrected Walkthrough comments

1.

Added a cue to step 3, (If asked) NVDH64

ES-301 Operating Test Review Worksheet Form ES-301-7 Red Light is ON

2.

Eliminated Train 2 option due to ALARA NRC: The JPM is SAT.

S1 (New JPM)

SF 1 -

K/A 004 A4.10 2

X E

S NRC: Add a cue at JPM termination indicating that another operator will complete emergency borating.

Licensee:

Added cue as requested Walkthrough comments

1.

Changed validation time to 10 minutes

2.

Added note to JPM Step 2, Alt path starts here.

3.

JPM Step 7, changed batch size amount to 5000 gallons

4.

JPM Step 13, changed standard to, Adjust HC MU23, while observing flow indication on the upper display of the Batch Controller OR FIMU41 to control approximately mid-scale.

NRC: The JPM is SAT.

S2 (JPM 291)

SF 2 -

K/A 006 A4.05 3

X X

E S

EARLY SUBMITTAL NRC:

1.

Clarify for JPM step 1 - would it be expected procedurally to press all 4 BLOCK pushbuttons?

2.

Clarify for JPM step 7 - what would the impact be if any additional Train 2 SFAS Level 5 Output Modules were tripped?

Step 1 is necessary as the valves need to be repositioned to support an ESFAS level 5 (low BWST level) and therefore the signal for ESFAS level 2 (Safety Injection) needs to be overridden. 2 still needs to be addressed.

ALSO - The procedure indicates that it is a time critical action to open a sump suction valve from when 9 feet in the BWST is achieved. Since the 9B valve opens without having to implement alternate path actions, it seems like this can still be tested. Please explain this.

Licensee:

1.

Yes, it would be expected to press all 4 BLOCK pushbuttons by procedure. Changed standard to depress all 4 pushbuttons. Added a comment that its only critical to verify all 4 valves are blocked.

2. There are no other Level 5 Output Modules. If the wrong output modules are tripped, then DH9A and DH7A will not reposition.

3. Not tested as a time critical action since its an Alternate Path JPM. Time critical steps will be added just for DH9B.

Walkthrough comments

1.

Changed task standard to: Transfer LPI Suctions to the Emergency Sump Time critical JPM to transfer Train 1 Suction to the Emergency Sump within 2 minutes.

2.

Validation time to 10 minutes

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

3.

Deleted, This is a Time Critical JPM. I will inform you when the Time Critical Clock begins from the initial cue. Changed cue to (Unfreeze simulator and mark Time Critical Clock start time when examinee is ready to start JPM)

4.

Deleted Cue Time critical clock starts now from the Start Time box. Changed start time box to, Time Critical Clock START TIME:_________

NRC: Two issues remained - we need to indicate that this is a time-critical JPM in the cue (per Appendix E, page E-4) and change the validation time to 10 minutes as stated above. Both items Corrected - The JPM is SAT.

S3 (JPM 275)

SF 3 -

K/A 010 A4.01 2

X E

S NRC: Add a cue to respond to the applicant to remain in section 4.3 if based on the note and step 4.3.2, they recommend performing the equalization in accordance with section 4.8.

Licensee:

Added a cue as requested.

Walkthrough comments Validation time to 10 minutes NRC: The JPM is SAT.

S4 (New JPM)

SF 4S -

K/A 045 A4.14 3

E S

Walkthrough comments

1.

Added a NOTE and cue to JPM step 9 NOTE: The candidate may recommend tripping the Turbine if he knows the trip setpoint.

CUE: IF THE CANDIDATE RECOMMENDS, THEN GIVE THE COMMAND TO Trip the Turbine.

OR IF THE CANDIDATE PULLS THE ALARM PROCEDURE, (hand candidate a copy of DB-OP-02015 Annunciator 15-2-E, T-G BEARING VIB HI.)

2.

Added Alternate Path starts here. The Main Turbine Trip Pushbuttons fail to trip the Turbine prior to step 10.

NRC: The JPM is SAT.

S5 (JPM 187M)

SF 4P -

K/A 025 AA1.22 2

X E

S NRC: This JPM is listed as modified. Provide the original JPM or indicate what is significantly modified from the original version of this JPM.

The comment regarding HPI flow in JPM Step 8 is awkward and difficult to understand - Reword it to clarify what is being described.

The K/A selected was not the best. AA1.22 obtaining water from the BWST for LPI is not perfect but is better than the one selected as LPI pumps are tripped at the onset of the JPM and the applicant is directed to establish feed and bleed from the BWST. LPI pumps are tangential to the applicants response of this JPM.

Licensee:

1.

Provided original JPM.

2.

Reworded JPM Step 8

3.

Changed K/A to 025 AA1.22

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

1.

Validation time to 10 minutes

2.

Deleted cue from step 4.

3.

Broke step 5 into two steps (5-Close breaker, 6-Open valve)

NRC: The JPM is SAT.

S6 (JPM 219)

SF 5 -

K/A 103 A3.01 3

X U

S NRC: Why are the CV5011 valves not closed as a part of this JPM? They appear to be in direct contact with the containment atmosphere similar to the CV5010 valves which are shut in the JPM?

The cue should correct the word indirect for JPM Step

3. It should be two words in direct to have proper meaning for this situation.

Licensee:

1.

CV 5011 valves are de-energized in this JPM

2.

Indirect changed to in direct in JPM Step 3 Walkthrough comments

1.

Added NOTE: *Indicates step is NOT Critical to perform, to step 4.

2.

Changed step 7. To PERFORMANCE STEP:

Verify that all LLRTs are terminated and isolated (Step 11.1.5.d).

STANDARD: Communication with Field Supervisor.

CUE: When the Candidate reads step 11.1.5.d, The Field Supervisor will complete the remaining steps.

3.

Deleted step 8.

NRC: The JPM is SAT.

S7 (New JPM)

SF 7 -

K/A 012 A4.02 2

S Walkthrough comments Validation time to 5 minutes NRC: The JPM is SAT.

S8 (JPM 15)

SF 8 -

K/A 029 A2.03 2

X E

S NRC: The note for JPM Step 6 incorrectly calls out procedure step 3.3.38 - it should call out procedure step

3.3.8. Licensee

Corrected typo in Note for JPM Step 6 Walkthrough comments

1.

Changed tsk standard to, IAW DB OP 06503, section 3.3, line-up the Containment Purge Supply and Exhaust Fan valves and place system in service.

2.

Validation time to 8 minutes

3.

Deleted cue from step 6.

NRC: The JPM is SAT.

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 9

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

OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

0 8

1 All edits were addressed.

Sim./In-Plant JPMs 11 1

10 1

All edits and unsatisfactory JPMs addressed.

Scenarios 5

0 5

0 All edits were addressed.

Op. Test Totals:

25 1

23 2

4.0 SATISFACTORY submittal overall.

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).

ES-301 1

Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Scenario: 1 Exam Date: February 7, 2022 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

Purification Demin S

Normal Event Walkthrough Changes Added to ES-D-1 Planned Activities.

5 Leaking PORV X

X U

S NRC: Receiving a reactor trip, alone, is not safety significant.

Perhaps the boundary condition can be to close the PORV block valve prior to a loss of subcooling margin.

Licensee: If the PORV Block Valve is not closed, subcooling margin will be lost as pressure continues to lower after the reactor trips. The critical task safety significance will be changed to Prevent a loss of subcooling margin and Failure to meet the critical Task will be changed to The PORV Block Valve is not closed in time to prevent a loss of subcooling margin Walkthrough Changes

1. Moved to Event 5 per NRC request at OV.

2. Added 1-hour Req Action for TS 3.4.11

3. Added TS 3.4.1 if RCS Press.< 2065psig 2

TPCW Hi Temp S

3 YV1 DC X

S 4

TPCW Trip/

Down Power X

E S

Reactivity Event NRC: For this event to be counted as a component failure attributed to the BOP, the event MUST be allowed to continue until Attachment 2 of DB-OP-02514 is complete and/or two condensate pump operation is established per DB-OP-02504.

Therefore, the NOTE (on page 10) should be removed.

Licensee: Removed the referenced NOTE

ES-301 2

Form ES-301-7 6

Steam Leak X

S ATC throttles HPI flow to maintain PZR Level per SR3 and uses PZR spray to depressurize the RCS while maintaining SCM.

BOP controls AVV1 to maintain RCS temperature constant or slightly decreasing.

7 AFP Trip S

7 0

0 1

0 2

2 7

E S

NRC: Address concerns raised above.

Walkthrough Changes Minor editorial changes/enhancements not noted on this form.

NRC: The scenario is now SAT

ES-301 3

Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Scenario: 2 (EARLY SUBMITTAL) Exam Date: February 7, 2022 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

MUP Oil Pump X

E S

NRC:

1. Add One Boron System flow path Nonfunctional for TNC A

2. Spell out TNC and other non-standard acronyms the first time they are used in an event.

Response: Added One Boron System flow path Nonfunctional and defined TNC.

Walkthrough Changes Added to ES-D-1 Planned Activity 2

PZR Temp Inst S

3 MFP Oil Drain S

BOP manually starts MFP Drain Pump 4

SFP Pp Trip E

S NRC:

Spell out CTRM and other non-standard acronyms the first time they are used in an event.

Response: Done.

5 Dropped Rod X

E S

Reactivity Event NRC:

1. Is establishing two Condensate pumps in operation to be expected in the given conditions for this event?

2. Spell out HBP, RSLLV, and other non-standard acronyms the first time they are used in an event.

3. The Scenario Event Summary must include TSs entered.

Response: Lowering power to 50% will establish plant conditions to turn off 1 condensate pump. Acronyms were defined as requested. Added TS references to all Event summaries.

Final Review Changes

1. Spelled out HBP on page 10.

ES-301 4

Form ES-301-7

2. Renumbered events on form ES-301-7 to address new event added after the 75-day review.

6 ATWS X

E S

NRC:

1. Add per DB-OP-02000, step 3.3 RNO to the critical task verifiable action.

2. Please add Event 7 begins on the next page to the bottom of this event.

Response: Added per DB-OP-02000, step 3.3 RNO and Event 7 begins on the next page.

7 Open MSSV X

X E

S ATC depressurize RCS with PZR Heaters and Spray maintain pressure above RCP NPSH limits.

2020 NRC Exam (Scenario 3)

NRC:

1. Please provide D-Bs Annunciator Response Procedures (ARPs) as additional references to the BOX.

2. Separate Events 7 and 8 after the note about closing AF 3870 and add Event 8 begins on the next page to the bottom of the last page of this event.

3. Include DB-OP-02000 specific step information to the applicable Applicants Actions or Behavior portions of this event.

Response: ARPs added; Event 8 begins on the next page added; added specific section information for DB-OP-02000 to the Applicants Actions or Behavior.

8 SFRCS Failure X

E S

2020 NRC Exam (Scenario 3)

NRC:

1. Include procedure and specific step information to the applicable Applicants Actions or Behavior portions of this event.

2. Spell out AVV and other non-standard acronyms the first time they are used in an event.

Response: Added specific section information for DB-OP-02000 to the Applicants Actions or Behavior and defined AVV.

8 0

0 0

0 2

2 6

E S

NRC: Address outstanding concern above for event 5. This Scenario only includes 1 component or instrument failure for the

ES-301 5

Form ES-301-7 ATC operator to respond to. This is not sufficient if SRO I6 only serves one board operator watch (and does so during this scenario) and needs to be tested with at least 2 component/instrument failures as the ATC if they are not also performing a watch as BOP during the scenario set per ES-301-5 Note 1.

Licensee: An additional malfunction was added. Event 2 is a failure of the pressurizer temperature instrument..

Walkthrough Changes Minor editorial changes/enhancements not noted on this form.

NRC: The scenario is now SAT

ES-301 6

Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Scenario: 3 Exam Date: February 7, 2022 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

Remove MFP1 X

E S

Normal Event NRC: Include specific actions of DB-OP-06224, Step 3.8.10 in the D-2 for placing the warmup valve in service.

Licensee: All actions associated with placing the MFP warmup valve in service are completed in the field. There are no controls for the MFP warmup valve in the control room.

2 CCW2 Trip X

X S

Walkthrough Changes

1. This is now a critical task since the STBY CCW pump does NOT auto start.

2. Added PZR Level TS if > 228 in.

3 Bus F7 Fails X

S 4

SAC2 Fails X

S 2020 NRC Exam (Scenario 5) 5 Rising Condenser Pressure S

Reactivity Event 6

RX Trip on loss of feed S

7 AFP2 Trip and MUP2 Fails to Start X

XX E

S NRC: CT associated with aligning the HPI cooling lists Measured By criteria on page 17 as:

- 1 Makeup Pump piggybacked from LPI

- All available HPI Pumps piggybacked from LPI

- PORV Locked Open The D-2 only identifies the action of opening the PORV as the critical task. The steps associated with aligning HPI and MU should also highlighted as actions required to complete the critical task. Simply opening the PORV by itself would not accomplish

ES-301 7

Form ES-301-7 the cooling method being attempted following a loss of all feedwater.

Licensee: Annotated steps necessary to support core cooling while the PORV is locked open as part of the required actions to complete the Critical Task. The additional actions support the required actions of the Critical Task justification.

Walkthrough Changes Changed Critical tasks to Train 1 components only when aligning for MU/HPI/PORV cooling 7

0 1

0 0

2 3

6 E

S NRC: Address concerns raised above. Note that this scenario, while a discriminating tool, does not require either the ATC or BOP to manually control a parameter which is normally controlled automatically or start a component which is normally automatically started. This may have an adverse impact on the examiners ability to assess all candidates in the rating factors of Competency 3.

Licensee: ATC: An additional malfunction was added to prevent the automatic start of the standby CCW pump after the in-service pump trips. This will require ATC to take manual action after the automatic action fails.

This should be evaluated as a critical task. Will determine during NRC Walkthrough per Lead Evaluator.

BOP: Station Air Compressor 1 will NOT automatically start on lowering instrument air header pressure. BOP is expected to manually start SAC 1 AND verify instrument air header pressure is rising.

Walkthrough Changes Minor editorial changes/enhancements not noted on this form.

NRC: The scenario is now SAT

ES-301 8

Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Scenario: 4 (SPARE) Exam Date: February 7, 2022 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

ESFAS BWST Level Fail Hi X

S 2

Seal Inj Xmtr fail S

Added Seal Injection Flow Transmitter Failure 3

Cond Pp Bearing Hi Temp S

Reactivity Event 4

SGTL X

U S

Reactivity Event Component Failure NRC: The D-2 does not indicate that TS 3.4.17, Condition B for SG Tube Integrity not met MUST be entered. Per the TS Bases document, TS 3.4.17 is contingent on SG Performance Criteria, one of which must be met to meet the LCO is the Operational Leakage Spec of <150 gpd in any one SG. This spec is not met, so the SG performance criteria is not met and therefore, 3.4.17, Condition B should be entered.

Licensee: Added entry into Condition B Actions B.1 and B.2 of LCO 3.4.17 to the guide along with LCO 3.4.13 5

MFP Trip S

ATC runs unit back in SGRX Manual/Hand 6

SGTR X

X S

2020 NRC Exam (Scenario 4)

BOP manually transfers load to TBVs ATC manually uses heater and spray to depressurize the RCS while maintaining adequate SCM.

7 SG1 SU Valve Fails X

S 7

0 0

0 0

2 2

6 E

S NRC: Address concerns raised above. This Scenario only includes 1 component or instrument failure for the ATC operator to respond to. This is insufficient as candidate SRO I7 only

ES-301 9

Form ES-301-7 serves 1 board operator watch (and does so during this scenario) and must be tested with at least 2 component/instrument failures as the ATC if they are not also performing a watch as BOP during the scenario set per ES-301-5 Note 1. (SRO I7 only serves as SRO during scenario 1)

Licensee: An additional malfunction is added to meet the minimum requirements. Event 2 will be a failure of the RCP seal injection flow transmitter, requiring ATC to take manual control of the seal injection flow control valve MU 19.

Walkthrough Changes

1. Minor editorial changes/enhancements not noted on this form.

2. Changed to the SPARE Scenario NRC: The scenario is now SAT

ES-301 10 Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Scenario: 5 (SPARE, LOW POWER) Exam Date: February 7, 2022 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

Raise to POAH S

Reactivity Event 2

HPI Oil X

S 3

Added Deaerator Level Control Failure as Event 3 4

Ni3 Low X

U S

NRC: Why is TS 3.3.9 referred to with an open bullet? Why are TS 3.3.9 LCO Conditions A and B listed when Condition C is the correct condition to enter. The reactor will still be at > 1E-10 Amps and both SRNIs will be turned off so inoperable. If the note applies and Condition C is not entered than I am assuming you are considering that the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action due to TS 3.3.10 drove the applicants to lower power < 1E-10 and then you listed A and B. B would require an immediate shutdown. Please explain in greater detail your intentions with this TS call.

Licensee: Scenario guide was changed to have the Shift Manager direct ATC to lower Reactor Power until Source Range Nuclear Instruments are on scale and NOT de-energize the source range instruments to avoid this concern.

An additional malfunction (Event 3) was added to provide an opportunity for the BOP operator. LT421 for #1 Deaerator will fail high resulting in CD 421 failing closed. #1 Deaerator level will lower. The low-level alarm will actuate at 7.25 feet after approximately 10 minutes. BOP is expected to place CD 421 in manual and control #1 Deaerator level. The failure may be identified by the BOP prior to receiving the alarm.

5 SW Rupture S

ES-301 11 Form ES-301-7 6

AFP2 Fail E

S NRC: On page 11 of 18 of the D-2 this event is incorrectly noted as Event 6 and should be Event 5 (in the header section of the page). BOP manually starts AFP2 Licensee: Modified header to accurately describe the event 7

D2 Lockout X

E S

ATC manually starts CCW2 NRC: Provide detail as to the 5 minute boundary condition for starting CCW2. If the diesel is expected to be damaged by running without cooling water for 5 minutes, then please state that in the critical task analysis. Otherwise, this does not become an issue until SCM is lost later in the scenario.

Licensee: Added the following information from the BASES AND DEVIATION DOCUMENT FOR DB-OP-02000 to the analysis.

The CCW and SW pumps are checked to ensure cooling water is available to the EDG. Operation without CCW or SW will lead to EDG overheating and failure. The EDG is shutdown if SW or CCW is not available. PCAQ 98-1883 reviewed the time available to perform the EDG Shutdown. Based on discussions with EDG vender (documented in the PCAQ), in a loaded condition, the EDG Jacket Water would reach the high temperature shutdown setpoint in approximately 3 minutes. If the EDG continued to run, the cylinder head would likely crack in approximately 6 minutes, and the EDG would likely seize in 11 to 14 minutes. The critical task time of 5 minutes is used to provide margin to possible failure at 6 minutes.

ES-301 12 Form ES-301-7 8

LOCA X

S 9

HPI Flow Balance X

X E

S NRC: The D-2 does NOT properly indicate the ATCs actions on page 14 as a Critical Task. Highlight as Critical Tasks which steps MUST be performed for HPI Flow Balancing.

Licensee: Identified all actions required to properly flow balance high pressure injection as required to complete the Critical Task.

9 0

1 0

0 2

3 9

E S

NRC: Addressed concerns raised above.

Walkthrough Changes Minor editorial changes/enhancements not noted on this form.

NRC: The scenario is now SAT

ES-301 13 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 14 Form ES-301-7 Facility: Davis-Besse Nuclear Power Station Exam Date: February 7, 2022 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

7 0

2 0

2 1

9.0 E S CT boundary condition was not safety significant as proposed.

2 8

0 2

0 2

0 0

E S 3

7 0

2 0

3 0

0 E S 4 Spare 7

0 2

1 2

0 9.0 E S TS 3.4.17 was required to be entered due to failing to meet operational leakage specification.

5 Spare 9

0 2

1 3

0 7.7 E S TS 3.3.9 needed to be correctly defined for this scenario event.

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 15 Form ES-301-7 Site name: Davis-Besse Nuclear Power Station Exam Date: February 7, 2022 OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

0 6

3 Sim./In-Plant JPMs 11 1

6 4

Scenarios 5

0 5

0 Op. Test Totals:

25 1

17 7

4.0 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).