ML22158A146
| ML22158A146 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/05/2021 |
| From: | Randy Baker NRC/RGN-III/DRS/OLB |
| To: | DTE Energy |
| Baker R | |
| Shared Package | |
| ML19128A199 | List: |
| References | |
| Download: ML22158A146 (17) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7
[1]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Review SLC Sodium Pentaborate Monthly SRO-A1.1 (JP4101.426)
COO 2.1.25 2
E S
NRC: Add TS compliance verification to Initiating Cue. Add data to KEY to support use of the graph (Enclosure A) to determine LTV. Give a tolerance range for determined LTV.
Response
Added TS verification to initiating cue. Added evaluator key with enclosure A plot and provided tolerance ranges for calculated values.
Review Mode 5 Shiftly/Daily PMT SRO-A1.2 (JP4101.440)
COO 2.1.40 3
E S
NRC: When calculating the SNR for SRM B & D, procedure 24.000.01 Att 37, Steps 1.10.1 is not clear as the format of the equation has the denominator indented to the left and not under the numerator.
Provide copy of 24.000.01 Att. 37.
Are the operators expected to know from memory which quadrant of the core each specific SRM is located? The core map nor the surveillance indicated which specific SRM was located at which core location. This obviously impacts the applicants ability to determine whether the fuel moves would be permitted with one SRM not operable.
Provide Evaluator Note for Step 1 stating what constitutes a SAT channel Check between the Operable SRMs.
Recommend reversing the order of steps 4 & 5, and during OV, determine if Steps 5 adds value to the JPM.
Response: 7 of 24.000.01 is printed exactly as the original procedure is formatted. Theres not much we can do about this since in real life the procedure is formatted in that way.
We can certainly initiate a corrective action item to correct this, but it must wait until the exam is completed due to exam compromise concerns.
The core location of each SRM detector is identified in 23.602, Source Range Monitoring System operating procedure. We havent identified this as a required reference, but we could certainly provide this to applicants as a paper copy, or alternately, they could find it using Fermis on-line controlled document system during performance of the JPM.
This document would be readily available to operators in the Main Control Room. We have revised the JPM to provide this reference upon applicant request.
24.000.01 attachment 37 for both SRM B & D are included in the documents provided to the applicant.
Added note as requested. Reversed steps 4 & 5.
ES-301 Operating Test Review Worksheet Form ES-301-7
[2]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Evaluate Offsite Power Sources Under Degraded Grid Conditions SRO-A2 (JP4101.103)
EC 2.2.37 2
E S
NRC: Having a TS table on the applicants answer/cue sheet is a strong cue that offsite power is inoperable and that they will be entering a TS action statement. Remove the Table from the Cue sheet, and simply have the applicant ask for the proper sheet to document the results from completing Steps B.1 & B.2 if necessary.
Will ODE-12 be available for the applicant to request to determine if they meet the requirements for an external grid problem?
Will the TS Bases be available for the applicants to review? I rarely see ILE applicants make a TS call without referring to the TS Bases.
If the intent of the JPM is for the applicant to use 20.300.GRID to perform the assessment of OPERABILITY, the Initiating Cue should state The SM directs you to perform Step B of 20.300.GRID, and reports the results.
When the applicant reports to the SM that 120kV circuit is inoperable, then have the SM direct performance of RNO Steps B.1 and B.2.
With the TS Table removed from the cue sheet, modify the Initiating Cue and Step 7 Element and Standard to require reporting assessment results to the SM.
Response
The TS table has been removed from the cue sheet. (It is worth noting that on-shift SROs would utilize CORA software to document TS LCO issues, and there is no formal paper-based documentation methodology. The table was included for the convenience of evaluators to grade the JPM. Since the procedure step directs applicants to review TS 3.8.1, we initially determined that providing the table was not cueing.)
ODE-12 and TS Bases are both available to applicants either in the simulator, or via Fermis web-based applications, depending upon where the JPM takes place. Paper copies of TS 3.8.1 bases and applicable pages of ODE-12 can be provided if necessary.
Revised the initiating cue and step 7 as requested.
ES-301 Operating Test Review Worksheet Form ES-301-7
[3]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Approve a Discharge Permit SRO-A3 (JP4101.409)
RC 2.3.6 1 2 E
S NRC: This JPM is LOD =1, as the two Critical Steps include adding data which is cued to the applicant not requiring them to identify it themselves (1) and to sign/date the permit (2).
The expiration time/date cued to the applicant appears to have violated step 5.1.13 of the procedure which states that it is not intended to exceed the duration of the task. The cue sheet indicates that pumping will stop at 1400 on Friday and the applicant is cued by the examiner that the FIN team will stop pumping at close of business on Friday. These seem to conflict and beg consideration as to why the cue in the initial conditions of pumping stopping at 1400 wasnt enough information by itself.
FREE LOOK Why is CST/CRT dike water not considered potentially contaminated? (Step 5.1.2) Was Chemistry sample already taken? If so, put in the I/Cs, and modify JPM Steps to include applicable conditions.
Provide revised JPM to reflect required critical steps to meet the Task Standard to complete/approve a discharge permit.
Response
Modified the cue to remove the indicated pumping stop time.
The candidate will now have to evaluate a permit and determine which condition of step 5.1.13 (and associated discharge stop time) applies for the specific release being planned.
Revised JPM I/C and step 2 to identify actions taken for potentially contaminated water.
Event Classification SRO-A4 (JPER0001.425)
EP 2.4.41 2
X X
U S
NRC: This is a TIME CRITICAL JPM. NRC regulations require EAL declarations to be made within 15 minutes of the alarm/indications of the condition available to the control room operators. The JPM is not characterized as TIME CRITICAL nor is the applicant instructed that the JPM is TIME CRITICAL.
What is the difference in the critical step associated with identifying the correct sheet and identifying the correct EAL on that sheet? Are there really two critical steps for this JPM? If so, justify For Step 1, simple state EP-101. Change NOTE 1, prior to Step 1, to read Once applicant acknowledges understanding of the I/Cs, mark the time to begin Time Critical portion.
ES-301 Operating Test Review Worksheet Form ES-301-7
[4]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Remove the references for Enclosures A & B; simply state Locate and obtain EP-101.
Change Step 4 Element to Declare the Emergency Classification.
Consider adding an additional critical step to simulate making the required Site Announcement. (LOD=<2?)
Response
The JPM has been revised to identify it as time critical, and the incorrect critical step identified above has been reclassified as not critical.
(It is worth noting that a similar EAL classification JPM was administered on the 2015 NRC exam and was NOT identified as time critical)
Revised JPM as requested. Will review LOD and potential step 5 during OSV.
Added critical step to review notification form with errors.
ES-301 Operating Test Review Worksheet Form ES-301-7
[5]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Determine Availability of RPV Level Instruments RO-A1.1 (JP4101.447)
COO 2.1.45 3
E S
NRC: Explain why instruments B21-R610 and R615 are associated with reference leg runs with the 3rd floor of the RB and 604A/B and 623A/B are associated with the 2nd floor when all reference legs initiate on the 3rd floor at elevation 648/9ft. Specifically, reference leg run temperatures when comparing these instruments are linked to EECW for 604/623 and Hydrogen Recombiner for 610/615. Explain how this can be determined by the applicant.
Modify Evaluators Initiating Cue to match the applicants.
Verify I/Cs are not confusing during onsite validation.
Response
This JPM was originally developed by NRC for the Fermi 2010 ILE. Since that time, it has been used and validated for several LOR annual operating exams with significant success. Additionally, the procedure has been enhanced somewhat since the 2010 exam and has been trained extensively in both LOR and ILT.
Fermi exam team recommends using this JPM as is. We will ensure that NRC examiners are briefed and fully understand the process used to arrive at the correct result during OSV week.
Revised initiating cue as noted. Will verify I/Cs during OSV.
Perform DW Air Temp Calc RO-A1.2 (JP4101.408)
COO 2.1.7 2
E S
NRC: Update the JPM Safety Function listed. (Where does 10 come from?) Modify the Terminating Cue (page 3 of JPM) to read... Attachment 2, Step 13.0 complete.
Per Step 6.1.4 of 24.000.02, Reverse JPM Step 8 & 9, since this particular Surveillance Item is SAT. Also, add 13.0 a to Step for Initialing SAT/completed Steps.
Response
Revised JPM safety function, terminating cue, and steps 8 &
9 as noted.
Obtain and Interpret Electrical Drawings RO-A2 (JP4101.193 EC 2.2.41 2
X X
X U
S NRC: This JPM is listed on the 301-1 as modified. What JPM is this modified from? Please provide the original JPM.
Revise/correct the following on the JPM Information Sheet:
System (IRMs not HPCI); Add 23.601 to the available references; Add WebARMS computer access to Tools. Also, correct Safety Function to SF7-Instrumentation. Vs SF1.
Is the I/C of Mode 1 at 100% applicable for an IRM functional test?
Combine identifying correct Revision No. of required drawing into Step 2, make Step 2 a Critical Step, and eliminate Step 7.
ES-301 Operating Test Review Worksheet Form ES-301-7
[6]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
Response
JP4101.192 provided Revised system #, tools, safety function as noted. Changed current plant mode to 4, preparing for startup.
Revised step 2 as noted, and deleted step 7.
Determine RWP Requirements for LHRA RO-A3 (JP4101.453)
RC 2.3.12 2
E S
NRC: Should the survey map include specific contamination values? There appears to be numbered locations which were surveyed but the contamination values are N/Ad.
Provide an explanation of what the circled numbers 1 thru 10 represent - dose rate survey points/contamination swipe locations? How is the data interpreted?
How are the Respiratory Protection requirements determined for a LHRA? Is this a requirement for the Rad Worker or for RP personnel?
Remove the conditional statement if applicable from the applicant Cue Sheet.
20 minutes seems a little long for a validation time for this JPM.
Response
The survey map is an actual map developed by Fermi 2 RP, and we feel it would be unrealistic to modify it for this exam.
We recommend reviewing the validation time during OSV and revising as appropriate.
The circles indicate smear locations, within which sequential smear numbers are entered. Per 68.000.002, RADIATION AND CONTAMINATION SURVEYS (NISP-RP-02),
Enclosure B page 1: - Indicates contamination data. A number should be placed inside the corresponding to referenced smear location. Although the smear count values are not listed on the survey, the data can be retrieved by RP personnel if requested. This data is not required for performance of the JPM.
The need for respiratory protection is determined by RP personnel when preparing to supervise LHRA entry and would be briefed prior to use.
Revised the JPM to remove if applicable JPM is SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7
[7]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Simulator/
In-Plant JPMs Safety Function 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.
Manually Initiate Low-Low Set S1 (a)[Alt Path]
(JP0105.403) 3 239002 A4.01 2
E S
NRC: The JPM was listed as modified. Provide the original JPM to demonstrate how it was modified.
How is LLS initially prevented from opening is the applicants actions are delayed and Rx Press reached 1093 prior to opening an SRV? (Would this be considered a JPM failure?)
Response
JP4101.181 provided LLS will not be armed if pressure were to rise >1093# prior to an SRV being manually opened. The LLS logic requires BOTH an SRV opened AND pressure >1093. If the applicant waited until after pressure rose >1093 to manually open one SRV, LLS would arm immediately and cause both SRVs A &
G to open. Although this would not necessarily have significant negative impact, I believe a failure might be warranted. Follow-up questions would certainly be necessary to understand the applicants unnecessary delay. Its also worth noting that similar variations of this JPM have been used multiple times for LOR over the last several years, and no such delay has been observed.
Rapid Power Reduction S2 (b)[Alt Path]
(JP0104.007) 1 202001 A4.01 2
E S
NRC: Step 1 performance standard has an asterisk indicating it is a critical step. It is not listed as a CS on the JPM Summary page and it is an ineffective step as the pushbutton does not work.
Re-evaluate that Step 1 should be a Critical Step, since, with this being an Alt Path, the failure could not be identified, and manual action taken to mitigate the failure.
What provides the procedural guidance for the response actions to respond to the failure of the Manual Runback?
Is the reference to MOP01 in Step 3 still valid?
Response
Revised step 1 to remove asterisk Step 1 critical status will be re-evaluated during OSV.
Procedural guidance per MOP-01, step 3.27.4, applies in this case. It directs operators to utilize manual control of equipment when automatic control becomes unavailable when required for parameter control. While this direction is not specific to the reactor recirc system, it nonetheless requires operators to take manual action.
The reference to MOP01 JPM step 3 has been revised to indicate the correct MOP01 step #.
Restore 480V ESF Bus 6
2 X
X E
S NRC: Remove the last 3 bullets from the I/Cs, remove the PREQUESITES: Note prior to Step 1, and add a new non-
ES-301 Operating Test Review Worksheet Form ES-301-7
[8]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Simulator/
In-Plant JPMs Safety Function 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.
S3 (c)
(JP0058.003) 262001 A4.01 critical Step prior to Step 1 for the applicant to perform Step 6.7.2.1 and verify the Specific Prerequisites.
Response
Revised JPM as noted above.
RPS Manual Scram Functional Test S4 (d)
(JP0127.101) 7 212000 A2.03 2
E S
NRC: This JPM is characterized as Alternate Path on the 301-2 JPM Outline Form. This JPM is not alternate path.
Correct 301-2.
Add a Cue following Step 16 to state Another operator will complete the Surveillance.
Response: ES 301-2 Updated.
Added cue as noted.
Vent the Drywell S5 (e)
(JP3006.501) 5 295024 EA1.14 2
E S
NRC: The JPM was listed as modified. Provide the original JPM to demonstrate how it was modified.
Add... Section 1.0. on to the end of the Initiating Cue. (per EOP)
Consider adding an additional step to permit the applicant to transition to Step 1.7.8 of 29.ESP.07 to establish control of DW pressure at < 1.68 psig as directed.
Response
JP3006.500 provided Added wording to initiating cue as noted.
Will discuss adding step during OSV.
Startup SBFW after RFP Trip S6 (f)
(JP0118.002) 2 259001 A4.02 2
E S
NRC: The JPM was listed as modified. Provide the original JPM to demonstrate how it was modified.
Add an I/C that plant is operating in Mode 1 (high RPV pressure).
Modify Cue, prior to Step 1, to supply applicant with ONLY the requested procedure (hard card or procedure section).
Add a NOTE prior to Step 2 that if using 23.107.01 Section 6, Steps 2 & 4 will not be completed prior to completing Step 6.
Verify which valves are OPEN with both SBFW pumps running and revise Step 7 ELEMENT and STANDARD accordingly.
FREE SAMPLE
Response
JP0118.002 provided.
Revised JPM as noted.
ES-301 Operating Test Review Worksheet Form ES-301-7
[9]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Simulator/
In-Plant JPMs Safety Function 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.
Depressurize RPV using RCIC S7 (g)[Alt Path]
(JP0043.406) 4 217000 A1.04 3
E S
NRC: The JPM is an Alternate Path JPM but is not characterized as so on the 301-2. Correct the 301-2.
Recommend providing additional I/Cs: 29.100.01 Sheet 1 has been implemented and the plant is stable.
Response
Revised 301-2 for RO and SROI to identify JPM as Alt Path.
Added I/C as noted.
ES-301 Operating Test Review Worksheet Form ES-301-7
[10]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Simulator/
In-Plant JPMs Safety Function 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.
Refuel Floor High Rad S8 (h)[Alt Path]
(JP0150.401) 9 272000 A2.12 2
E S
NRC: The element for step 2 has the applicant check for R605/606 reading > 3mr/hr, annunciator response procedure has the operator check for > 2 mr/hr.
Why doesnt ARP 3D31 list auto start of SBGT in the Auto Actions section?
Consider having alarms 3D31 & 3D35 initially come in following IC Setup, then freeze Simulator until applicant is briefed on plant conditions. Add the Alarms to the I/Cs, and for the Initiating Cue have the applicant Respond to Annunciators 3D31 and 3D35. (Dont make this a mini-scenario but an annunciator response JPM instead.)
Response
The majority of actions required by the JPM are in response to ARP 3D35, not 3D31. Both alarm from the same instruments, but 3D35 alarms at a higher value (>3 mr/hr) and is associated with start of SGTS, etc. No auto actions occur solely from 3D31.
The JPM was not clear in this regard, so we have edited the JPM to clarify the required actions to be taken by applicants are in response to ARP 3D35 (vice 3D31).
Revised JPM as requested above.
Re-sequenced to more closely follow the ARP steps. Added critical step to re-align CCHVAC system per ARP and system hard card.
(JP3006.309) 1 295015 AA1.01 2
E S
NRC: None.
Recommend replacing the Closed/Open Cues with a statement similar to The component is as you have described.
Modify Step 4 Cue to state When requested, report all...
Response
Revised JPM cues as noted.
Initiate EDG CO2 P2 (j)[Alt Path]
(JP0272.401) 8 286000 A2.08 2
E S
NRC: Recommend removing the initial condition, You are currently in the EDG Room 11 (13). Most likely the applicant will not be receiving their briefing there and it is a Cue as to where they need to go to perform the JPM.
Add a NOTE prior to Step 5 which states that Time Compression may be used.
Response
Revised the JPM to remove the location cue.
Added time compression NOTE prior to step 5.
ES-301 Operating Test Review Worksheet Form ES-301-7
[11]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 1
2 3
Attributes 4
Job Content 5
6 Simulator/
In-Plant JPMs Safety Function 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.
Spare ESF Battery Charger P3 (k)[Alt Path]
(JP0064.401) 6 263000 K1.02 3
E S
NRC: The JPM was listed as modified. Provide the original JPM to demonstrate how it was modified.
Move the Cue before Step 12 down to follow Step 12.
Recommend replacing with the Bank JPM to simply place the spare charger in service. (Reduce length of in-plant JPMs.)
Response
JP0064.005 provided Moved step 12 cue. Will discuss replacing JPM during OSV.
ES-301 Operating Test Review Worksheet Form ES-301-7
[12]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 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
[13]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 Scenario: 1 (Low Power 3-4%) [FREE LOOK]
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 1a/b (N-B/R-A)
Raise Rx Pressure and Power with Control Rods X
E S
Repeat event from 2018 Scenario 7.
Need to split actions between the Normal (BOP) & Reactivity (ATC) events.
[Events split and D-1 revised.]
2 (I-ATC)
IRM B Fails Upscale X
S Repeat event from 2018 Scenario 3.
3 (C-ATC)
Control Rod drifts (26-31) into the Core - TS X
X S
Repeat event from 2019 Scenario 1.
4 (C-BOP)
RB HVAC Center Exhaust Fan Fails -
TS X
S 5 (M-ALL)
Seismic Event =>
Small Break LOCA
& Subsequent Torus Leak S
6 (C-ATC)
Mode Switch Failure - Manual Pushbuttons Successful S
7 (C-BOP)
Loss of all Cond Pumps and Failure of SBFW to Inject X
S 8 (C-BOP/ATC)
Swap Low Press Injection Sources due to Torus Leak X
S 9 (C-BOP)
Failure of the TWMS to Isolate -
Manual Operator Actions Required X
E S
Repeat event from 2018 Scenario 6.
Validate the Required/Verifiable actions necessary to mitigate this event.
[Actions verified during Onsite Validation.]
10 0
0 0
0 2
2 5
E S Scenario is SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7
[14]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 Scenario: 2 (100% Rx Power) 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 (N-BOP)
Shift Main Circ Water Pumps S
2 (TS-Only)
Condenser Pressure Inst Fails X
S 3 (C-BOP)
Leak on North TBCCW Pump -
Swap to South Pump & Isolate X
S Repeat event from 2019 Scenario 3.
4 (C-ATC)
A CRD FCV Fails; Hi CRD Temps; Swap to B FCV X
S Repeat event from 2018 Scenario 6.
5 (R-ATC)
AVR General Alarm; Reduce Rx Power & Mn Gen Field Amps X
S Repeat event from 2019 Scenario 3.
6 (C-BOP)
Spurious Start of HPCI; Secure HPCI - TS X
S 7 (M-ALL)
AVR Trip of Mn Turbine; RPS Failure; ATWS 2X X
S Repeat event from 2019 Scenario 3.
8 (C-ATC)
RWCU Fails to Isolate when SLC Injection Initiated.
S 8
0 0
0 0
2 2
4 S
ES-301 Operating Test Review Worksheet Form ES-301-7
[15]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 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
[16]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 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
10 0
2 0
20 0
0 E S Editorial Corrections completed - Scenario is SAT.
2 8
0 2
0 2
0 0
S Scenario is SAT as Written.
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 Operating Test Review Worksheet Form ES-301-7
[17]
Facility: Fermi Power Plant, Unit 2 Exam Date: December 7 - 11, 2020 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
2 7
0 2 SRO ADMIN JPMs required changes to be considered SAT-See Table comments.
Sim/In-Plant JPMs 11 0
11 0
N/A Scenarios 2
0 1
1 N/A Op. Test Totals:
22 2
15 3
9.1 Well below the 20% threshold - SAT 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).