ML22173A021

Bwd 2018 Ile ES-301-7 Operating Test Comments

ML22173A021
Person / Time
Site:	Braidwood
Issue date:	06/27/2018
From:	Randy Baker NRC/RGN-III/DRS/OLB
To:	Exelon Generation Co
Baker R
Shared Package
ML17164A319	List: IR 05000282/2018301 IR 05000456/2018301 ML17332A026 ML22173A019 ML22173A020 ML22173A021 ML22173A031 ML22173A042 ML22173A045 ML22173A047 ML22173A048
References
Download: ML22173A021 (11)

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ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: BRAIDWOOD STATION UNITS 1 and 2 Exam Date: May 29 - June 8, 2018 1 2 3 4 5 6 Attributes Job Content Admin ADMIN Topic LOD U/E/S Explanation JPMs and K/A (1-5) I/C Critical Scope Perf. Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC: (10 min) JPM is SRO-Only. Need to provide marked-up copy of 1BwOA SEC-8, through Step 5a. (Correct typo in CUE at start of JPM Step 1.)

NOTE: CUES to applicant should reference the applicant back to the initial conditions, if SRO-A1 appropriate, not simply restate the information.

S-106 Determine COO1 Step 4, 2nd CUE, shouldnt the applicant know requirements for a 2 ES Steam Generator 2.1.23(4.4) what type radiation monitors are on the MSLs and Tube Leak where they are located? Why is this information being provided?

Response: Typo corrected in CUE for Step 1. N16 monitors may by positioned on different MSLs.

JPM is SAT.

NRC: (15 min) JPM is SRO-Only. [Need to see a copy of the data sheet provided to the applicant which contains the errors.]

The JPM tasking is for the applicant to perform an SRO-A2 independent review of the surveillance. Why arent COO2 S-205 Review X US all the inserted errors which require identification QPTR Calculation 2.1.20(4.6) marked as Critical Steps?

Response: JPM Tasking Standard modified to limit review scope; critical steps are now accurate.

JPM is SAT.

NRC: (16 min) JPM is SRO-Only. This JPM duplicates the knowledge/ability competence tested on the SRO-Only section of the written SRO-A3 examination (Q-91) by requiring determination of S-203 Apply EC the same fire protection water suppression system GOCAR to Water 2 S Suppression 2.2.42(4.6) actions.

System Response: JPM requires completion of paperwork and the written question focuses on the correct conditions required. JPM is SAT as written.

NRC: (30 min) JPM is SRO-Only. Need to provide marked-up copy of 1BwOP WX501T1, through SRO-A4 Step G.6 and 1BwOP WX501T2.

S-302 RC 3 ES Prepare/Perform a 2.3.11(4.3)

Liquid Release Response: Licensee agrees; copies provided.

JPM is SAT.

EP NRC: (20 min) JPM is SRO-Only, satisfies the SRO-A5 2 S 2.4.30(4.1) New/Mod JPM requirement, and is Time Critical,

ES-301 Operating Test Review Worksheet Form ES-301-7 S-403 Classify and with one Time Critical component (13 min). [Need screen event for to see how this is modified from the bank JPM.

reportability JPM is significantly modified from original.]

JPM is SAT as written.

NRC: (23 min) This JPM is Time Critical (20 min?)

but validated at 23 minutes? Why is it time critical, and if so, is it 45 minutes to meet the TS/TRM requirement?

RO-A1 Also, what determines the error bands used?

R-104 Determine COO1 3 ES SDM is inadequate 2.1.25(3.9)

Response: Based upon the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> LCOAR limit, the time critical portion is 45 min. Also the error bands are based on ability to read graphs. JPM is SAT.

NRC: (10 min) This JPM is modified (for 7300 Mod Changes) and satisfies the New or Mod JPM requirement. [Need to see bank JPM. This JMP is not significantly modified, even if it refers to the new Ovation Mod style controller; still simply RO-A2 requires controller adjustment.]

R-112 Calculate Boron Flow Set- COO2 2 ES Also, what determines the error bands?

point for shiftly daily 2.1.37(4.3) surveillance Response: Corrected ES-301-1 to show that the JPM may be performed in the Classroom (using photo of controller provided) and direct from bank.

Error bands based upon math operations performed. JPM is SAT.

NRC: (30 min)

RO-A3 EC R-203 Verify WTO 3 S Checklist 2.2.13(4.1) JPM is SAT as written.

NRC: (15 min) This JPM satisfies the New/Mod JPM requirement. This JPM is also Time Critical (10 min?) but validated at 15 minutes? What is the 10 min time based on?

Also, the facility should VERIFY that the applicants will only be able to access the TRAINING website RO-A4 for Everbridge, not the Examiners.

R-405 Activate ERO EP using the 3 ES Everbridge 2.4.43(3.2) Response: This JPM is considered Proprietary activation system due to the Everbridge Procedure. Omit from public release in ADAMS.

The 10 min time is based only on a procedural requirement to allow the ERO member to arrive and man the TSC within 60 minutes. Therefore this JPM is not Time Critical. JPM is SAT.

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

Simulator/In-Plant Safety Function JPMs and K/A S-a NRC: (33 min) This JPM is ALT PATH and also SIM-106 Perform a 1 satisfies the S/D or low Power requirement.

3 S 50-ppm dilution with 004 A4.07 1CV111A failure JPM is SAT as written.

NRC: (11 min) Each of the Simulator JPM must test a different safety function, but each JPM must also test different systems. (ES-301-D.4.a) This is S-b 2 the 2nd CVCS system simulator JPM.

SIM-210 Establish 2 ES excess letdown 011 A4.05 Response: Reference system for Safety Function changed to Pressurizer Level Control.

JPM is SAT.

NRC: (8 min) This JPM is Time Critical (20 minutes) and validated at 8 minutes. This JPM is New and also satisfies the S/D or low Power S-c 3 requirement. Add a final step to report completion SIM-306 Align for 2 S hot leg injection 006 A4.07 of JPM task to the US.

Response: The report of task status is not a critical step. JPM is SAT as written.

NRC: (22 min) This JPM is ALT PATH. The validation time appears to be excessive, for the time sensitive action to swap SX pumps back to S-d original line-up, with no additional follow-up JPM 4

SIM-407S Swap SX 3 S action required.

pumps 076 2.1.20 Response: Validation time based upon extensive interactions with the EO during the initial Standby pump start. JPM is SAT as written.

NRC: (17 min) This JPM is New, is ALT PATH, S-e and also satisfies the engineered safety feature SIM-511 RCFC 5 3 S requirement.

surveillance with 022 A4.01 high vibrations JPM is SAT as written.

S-f NRC: (8 min)

SIM-606 Crosstie 6 2 S ESF to NONESF 062 A4.01 JPM is SAT as written.

bus

ES-301 Operating Test Review Worksheet Form ES-301-7 NRC: (31 min) This JPM is ALT PATH, even S-g though the required alternate path actions are SIM-702 7 required within the same procedure (different step 3 S Calorimetric with 015 A1.01 section).

channel adjustment JPM is SAT as written.

NRC: (18 min) This JPM is ALT PATH. Add a final step to report actions taken to secure the release path to the US. Also, provide a copy of the Bank S-h JPM that was modified.

9 SIM-902 CMT purge 2 S with 1PR01J alarm 071 A3.03 Response: The bank JPM is not Alt Path; this JPM is significantly modified as Alt Path.

The report of task status is not a critical step. JPM is SAT as written.

NRC: (15 min) This JPM is New, is ALT PATH, and also satisfies the requirement to perform IP-i actions within the RCA.

IP-412S Align AF 4 2 ES from the opposite 002 A2.04 unit Response: Added a CUE to Step 4 for valve position indication from the Control Room. JPM is SAT.

IP-j NRC: (13 min) Add a final step to report IP-604 Energize an completion of JPM task to the US.

6 instrument bus from 2 ES the CVT and S/D 057 AA1.01 Response: The report of task status is not a the inverter critical step. JPM is SAT as written.

NRC: 28 min) Add a final step to report completion IP-k of JPM task to the US.

IP-803 Local 8 3 ES Emergency start of 065 AA1.03 Response: The report of task status is not a SAC critical step. JPM is SAT as written.

ES-301 5 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 6 Form ES-301-7 Facility: BRAIDWOOD STATION UNITS 1 and 2 Scenario: 1 (100% Testing 1LT-517) Exam Date: May 29 - June 8, 2018 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap 1-Perform 1BwOS EH-M1 N-BOP, US S

2-Failed PZR Press Low 1PT-457 TS-US X S 3-Trip of 1B EH pump C-BOP, US S

4-Auto Makeup relay actuation I-ATC, US S

5-Dropped Rod B08 C-ATC, US & TS-US X S 6-Down Power to recover dropped rod S R-ATC, US 7-1A SG Level 1LT-519 failed high I-BOP, US & TS-US X S (TS 3.0.3?-Yes) 8-Dropped Rod H08 M-ALL X S 9-Auto Rod Speed failed-8 steps/min C-ATC S

10-1CV8100(8112?) fails open C-ATC X S 11-PZR Safety 1RY8010C opens-SI required S M-ALL 11 Events 0 0 0 - 3 2 11 S

ES-301 7 Form ES-301-7 Facility: BRAIDWOOD STATION UNITS 1 and 2 Scenario: 2 (Free Sample) (90% 1PT-455 OOS) Exam Date: May 29 - June 8, 2018 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap 1-Ramp Unit 1 to 100%

R-ATC, US & N-BOP S

2-Failure of 1PK-131 Setpoint high I-ATC, US S

3-1A GS Exhauster fan trips C-BOP, US S

4-Degraded Bus volt-loss of bus 142 C-BOP, US & TS-US X S 5-1RY455A PORV fails Open C-ATC, US & TS-US X S 6-Turbine trip-failure of auto Rx trip M-ALL X X S Repeat event from 2014 NRC Exam, Scenario 4.

7-Manual Rx trip for M Not C.

C-ATC X S Repeat event from 2014 NRC Exam, Scenario 4.

8-4 Stuck rods; emergency boration If ATWS is present, why is it not a critical task to S/D reactor under C-ATC ES all conditions? (Westinghouse CT-52?)

Response: With Rx Pwr < 5%, this CT is not applicable.

9-LOOP-Loss of all AC Unit 1 M-ALL X X S Repeat event from 2014 NRC Exam, Scenario 4.

9 Events 0 0 0 - 2 2 6 S

ES-301 8 Form ES-301-7 Facility: BRAIDWOOD STATION UNITS 1 and 2 Scenario: 3 (90% PMT on 1MS018B) Exam Date: May 29 - June 8, 2018 1 2 3 4 5 6 7 8 9 10 Realism/ Required Verifiable Scenario Event LOD TS CTs U/E/S Explanation Cred. Actions actions Overlap 1-Perform PMT on 1MS018B N-BOP & TS-US X S 2-1CV112A diverts to the HUT C-ATC, US S

3-0A PW pump trips C-BOP, US S

4-RWST Lvl 1LT-932 fails low TS-US X S 5-1C HD pump fails C-BOP, US S

6-HD turbine runback R-ATC, US S

7-1PK-455 Setpoint fails high I-ATC, US & TS-US X S 8-1B MSIV fails closed M-ALL S

9-Loss of 1A CV pump C-ATC X S 10-1A & 1C RCFC did not swap to low speed X S C-BOP 10 Events 0 0 0 - 3 2 10 S

ES-301 9 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 10 Form ES-301-7 Facility: FACILITY NAME Exam Date: DATES OF EXAM 1 2 3 4 5 6 7 8 11 Scenario  % Unsat. Explanation Event Events TS TS CT CT Scenario U/E/S Totals Unsat. Total Unsat. Total Unsat.

Elements Scenario 1 11 0 3 0 2 0 0% S If ATWS is present, why is it not a critical task to S/D reactor under all conditions?

Scenario 2 9 0 2 0 2 0 0% S (Westinghouse CT-52?) This appears to be an unidentified pre-identified CT.

Response: With Rx Pwr < 5%, this CT is not applicable.

Scenario 3 10 0 3 0 2 0 0% S Instructions for Completing This Table:

Check or mark any item(s) requiring comment and explain the issue in the space provided.

1, 3, 5 For each simulator scenario, enter the total number of events (column 1), TS entries/actions (column 3), and CTs (column 5).

This number should match the respective scenario from the event-based scenario tables (the sum from columns 1, 6, and 7, respectively).

2, 4, 6 For each simulator scenario, evaluate each event, TS, and CT as (S)atisfactory, (E)nhance, or (U)nsatisfactory based on the following criteria:

a. Events. Each event is described on a Form ES-D-2, including all switch manipulations, pertinent alarms, and verifiable actions. Event actions are balanced between at-the-controls and balance-of-plant applicants during the scenario. All event-related attributes on Form ES-301-4 are met. Enter the total number of unsatisfactory events in column 2.

b. TS. A scenario includes at least two TS entries/actions across at least two different events. TS entries and actions are detailed on Form ES-D-2. Enter the total number of unsatisfactory TS entries/actions in column 4. (ES-301, D.5d)

c. CT. Check that a scenario includes at least two 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.

2+4+6 7 In column 7, calculate the percentage of unsatisfactory scenario elements: 100%

1+3+5 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.

ES-301 11 Form ES-301-7 Facility: FACILITY NAME Exam Date: DATES OF EXAM OPERATING TEST TOTALS Total Total Total  %

Total Explanation Unsat. Edits Sat. Unsat.

1 SRO Admin JPM did not identify all Critical Steps.

Response: JPM Tasking Standard modified to limit review scope; critical steps are now accurate. JPM is SAT.

Admin.

9 1 5 3 1 SRO Admin JPM duplicated the test topic of an SRO-Only JPMs Written Examination Question. (Q-91)

Response: JPM requires completion of paperwork and the written question focuses on the correct conditions required.

JPM is SAT as written.

2 Simulator JPMs use the same system to address two different Safety Functions. (S-a & S-b both use the CVCS to Sim/In-Plant 11 0 4 7 address Safety Function 1 & 2 respectively)

JPMs Response: Reference system for Safety Function changed to Pressurizer Level Control. JPM is SAT.

There appears to be an unidentified pre-identified CT in Scenario 2, Event 8. This is identified on the Sample Scenarios 3 0 0 3 Scenario submitted for pre-review and is considered an enhancement based on facility correction of the error.

Response: With Rx Pwr < 5%, this CT is not applicable.

Op. Test 23 1 9 13 4% Satisfactory Overall Totals:

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.

Enter the total number of (U)nsatisfactory JPMs and scenarios from the two JPMs column 5 and 2.

simulator scenarios column 8 in the previous tables. Provide an explanation in the space provided.

Enter totals for (E)nhancements needed and (S)atisfactory JPMs and scenarios from the previous 3.

tables. This task is for tracking only.

4. Total each column and enter the amounts in the Op. Test Totals row.

Calculate the percentage of the operating test that is (U)nsatisfactory (Op. Test Total Unsat.)/(Op. Test 5.

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%

Update this table and the tables above with post-exam changes if the as-administered operating test 6.

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).