ML22199A176
| ML22199A176 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/05/2022 |
| From: | Randy Baker NRC/RGN-III/DRS/OLB |
| To: | Constellation Energy Generation |
| Baker R | |
| Shared Package | |
| ML20140A267 | List: |
| References | |
| BW220023 | |
| Download: ML22199A176 (13) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7
[1]
Facility: Braidwood Exam Date: 3/7-3/16/22 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
SRO-A1.1 S-107b COO 2.1.20 3
X E
S NRC: Range for the Unit 2 minimum switchyard voltage does not envelop the correct answer. The upper edge should be 344.4 not 344.0.
Response: Acceptable range modified to read 344.1 to 344.3 for JPM Step 3. JPM is now SAT.
SRO-A1.2 S-109 COO 2.1.25 2
E S
NRC: Task standard should state determines maximum reactor head venting time based upon the given venting termination criteria..
Response: Task Standard modified. JPM is now SAT.
SRO-A2 S-204 EC 2.2.40 3
X X
E S
NRC: Completed surveillance (1BwOSR 3.8.6.5-2) not provided. Unable to validate Critical Steps match the JPM task standard. Task standard should identify review surveillance, identify 5 incorrect data sheet items, and determine the correct applicable TS/TRM entries.
Provide a copy of the marked-up completed surveillance, and update the JPM task standard.
Response: Task Standard modified and marked-up completed surveillance provided. JPM is now SAT..
SRO-A3 S-301 RC 2.3.11 2
X X
X E
S NRC: Completed release package (BwOP GW-500T1) not provided. Unable to validate Critical Steps match the JPM task standard. Task standard should be modified to require the applicant to approve the release once the two errors are corrected (match the initiating cue). Then step D.22 would also be a critical potion of performance step 4.
Provide a copy of completed release form. Also provide completed surveillance (0BwOS RETS 2.2.B-1).
Response: Task Standard modified and completed release form and completed surveillance provided. JPM is now SAT.
SRO-A4 S-409 EP 2.4.38 2
E S
NRC: The 301-1 will need to be changed as this is a more appropriate SRO Admin JPM for the EP area than was originally proposed on the outline submittal.
What is the purpose of the 2nd initiating Cue? (no step in JPM)
Response: The SRO ES-301-1 form has been updated. 2nd initiating Cue removed. JPM is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7
[2]
Facility: Braidwood Exam Date: 3/7-3/16/22 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 R-104 COO 2.1.25 3
X E
S NRC: A Reference copy of the surveillance (1BwOSR 3.1.1.1-2) along with the required references (BwCB-1 Figures & Table) was not provided to verify if values and specified ranges were correct.
Provide a copy of the surveillance and reference material.
NOTE: This is NOT considered a TIME CRITICAL JPM since the required JPM task is only a portion of the actual actions required to meet the TS/TRM requirements.
Response: A copy of the surveillance and reference material provided. Updated JPM-not Time Critical. JPM is now SAT.
RO-A1.2 R-109 COO 2.1.4 2
S NRC: None.
RO-A2 R-205 EC 2.2.13 3
S NRC: None.
RO-A4 R-407 EP 2.4.43 2
X E
S NRC: A copy of the (partially?) completed NARS was not provided to verify the data and appropriate critical steps.
The JPM steps, as written, are confusing and should state which are completed as input on the computer.
If using EONS, as written, delete Notes for booth operator.
Provide completed NARS form for review.
TIME CRITICAL Response: Completed NARS form provided. Which steps are computer inputs clarified. JPM is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7
[3]
Facility: Braidwood Exam Date: 3/7-3/16/22 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.
S1 SIM-105 1
004 A4.07 3
X X
E S
NRC: Provide a copy of the reference material (1BwCB-1) to verify if values and specified ranges were correct..
Based upon the Task Standard, a portion of Step 5 may be Critical (Adjust setpoint on 1FK-0111 to 67 to 69 gpm.)
Correct Critical Step designation and provide a copy of the reference material to validate critical step values/ specified ranges.
Response: Reference material provided. Task Standard modified; Step 5 is not Critical. JPM is now SAT.
S2 SIM-202 2
006 A1.13 3
X X
E S
NRC: Task standard should be more detailed about stopping the fill to within TS level limits.
Why cant the last 2 cues of Step 2 also be placed in the ICs?
NOTE: This is NOT considered a TIME CRITICAL JPM since the required JPM task is only a portion of the actual actions required to meet the TS/TRM requirements.
Clarify the Task Standard.
Response: Step 2 Cues placed in the ICs Task Standard modified and JPM updated to not be Time Critical. JPM is now SAT.
S3 SIM-300 3
006 A4.02 2
E S
NRC: Although the original JPM (SIM-301) was SAT, it was replaced with this JPM to match the required Safety Function.
S4 SIM-411P (Alt Path) 4P 003 A4.01 2
X E
S NRC: A Reference copy of the surveillance (1BwOSR 3.1.1.1-2) was not provided to verify if values determined in Step 3 were correct.
Based upon the Task Standard, portions of Step 3 are Critical (Determine point plotted is NOT acceptable.)
Correct Critical Step designation and provide a copy of the surveillance/Flow/DP plot to validate critical step values.
Response: Surveillance provided and appropriate portions of Step 3 annotated as Critical. JPM is now SAT.
S5 SIM-513 5
2 X
X E
S NRC: The 301-2 lists this as a low power JPM. If correct, the ICs must be more specific; there is no indication that this JPM occurs at low power.
ES-301 Operating Test Review Worksheet Form ES-301-7
[4]
Facility: Braidwood Exam Date: 3/7-3/16/22 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.
(Alt Path) 007 A1.01 Clarify either the ICs or the ES-301-2.
Response: ICs updated. JPM is now SAT.
S6 SIM-614 (Alt Path) 6 064 A4.02 2
X E
S NRC: Based upon the Task Standard, an additional portion of Step 2 is Critical (Turn Sync Selector switch to ON for ACB 1423.) to permit paralleling the DG in Step 2.
Correct Critical Step designation.
Response: Updated the appropriate portions of Step 2 as Critical. JPM is now SAT.
S7 SIM-704 7
073 A4.02 2
X X
E S
NRC: The 301-2 lists this as a low power JPM. If correct, the ICs must be more specific; there is no indication that this JPM occurs at low power.
Task standard should be modified to include requiring the applicant to restart the 0PR05J Rad Monitor (match the initiating cue). I dont believe enough information is provided in the ICs and Cues for the ROs to evaluate the operability of the Rad Monitor. Also, a portion of Step 5 would then be Critical with the current Task Standard Clarify the Task Standard and either the ICs or the ES-301-2.
Response: ICs and the Task Standard were updated. JPM is now SAT.
S8 SIM-800 (Alt Path) 8 008 A4.01 2
E S
NRC: What is the purpose of the Final Note after Step 10?
Validation time does not appear consistent with the expeditious shutdown of 1A CC pump given in the ICs.
Response: Modified ICs for clarification. JPM is now SAT.
P1 IP-100 (Alt Path) 1 001 A4.08 3
S NRC: Must the RESET pushbutton be depressed before the MG Set Motor Breaker will close? (If so this is also Critical.)
Response: RESET only required if OC flag is activated.
ES-301 Operating Test Review Worksheet Form ES-301-7
[5]
Facility: Braidwood Exam Date: 3/7-3/16/22 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.
P2 IP-207 2
062 AK3.03 2
S NRC: None.
P3 IP-604 6
057 AA1.01 2
S NRC: None.
ES-301 Operating Test Review Worksheet Form ES-301-7
[6]
Facility: Braidwood Exam Date: 3/7-3/16/22 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
[7]
Facility: Braidwood Exam Date: 3/7-3/16/22 Scenario: 1 (90% Rx Pwr) 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 RCFC Surveillance S
Normal event 2 - C(B), TS VC Rad Mon Failure X
S 3 - C(B) 1A HD pp Trip E
S NRC: Exam outline ES D-1 indicates this event was supposed to be a RX cavity vent fan trip.
Response: ES D-1 corrected to indicate event is a 1A HD pump trip.
4 - C(A)
RCP 1A Standpipe S
5 - TS Loop 1C Tave Low X
S 6 - R TS 303 Ramp S
Reactivity event 7 - C(A) 1B RCP #2 Seal Fail X
S ATC will manually control RCDT level with manual control of the RCDT pumps 8 - M SBLOCA X
E S
NRC: Boundary condition for tripping RCPs during SBLOCA is prior to exiting BwEP-1 which would occur well after the termination criteria of the scenario.
Recommend changing boundary criteria be changed to within 10 minutes of meeting the trip criteria vs. exiting BwEP-1..
Response: Critical Task boundary criteria modified.
9 - C(A) 1A SI Fail X
X S
BOP manually starts SI pump when it fails to auto start 9
0 0
0 0
2 2
7 E S Scenario is now SAT.
ES-301 Operating Test Review Worksheet Form ES-301-7
[8]
Facility: Braidwood Exam Date: 3/7-3/16/22 Scenario: 2 (75% Rx Pwr) 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 FW Pump Oil Surv S
Normal event 2 - C(B)
CRDM Exhaust Fan Trip S
3 - C(A), TS Dropped Rod X
S 4 - R Downpower for Rod Recovery S
Reactivity event 5 - I(A)
PZR Level Controller Failure S
ATC maintain PZR level control manually by controlling charging flow controller 1CV 121.
6 - C(B), TS OA MCR Supply Fan Trip X
S 7 - M 2nd Dropped Rod, FWI S
8 - C(B)
Turbine Fails to Trip X
X S
BOP manually trip the main turbine when it fails to auto trip 9 - C(A) 4 Stuck Rods S
10 - M 1B SG Feedline Break X
X S
10 0
0 0
0 2
2 8
S
ES-301 Operating Test Review Worksheet Form ES-301-7
[9]
Facility: Braidwood Exam Date: 3/7-3/16/22 Scenario: 3 (100% Rx Pwr) 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 RSV Surv.
S Normal event 2 - R Load Drop S
Reactivity event 3 - C(A)
CV8432A Closed S
4 - I(B), TS 1A SG NR Low X
S BOP controls 1A SG Level in manual 5 - C(B), TS LOOP X
S 6 - I(A), TS PZR Press Control Low X
S ATC takes manual control of pressurizer spray to control pressure.
7 - M Loss of All AC X
S BOP manually restores Bus 141 from U2 cross tie 8 - C(A)
Small RCS Leak X
S 8
0 0
0 0
3 2
8 S
ES-301 Operating Test Review Worksheet Form ES-301-7
[10]
Facility: Braidwood Exam Date: 3/7-3/16/22 Scenario: 4 (Low Power ~10 E-8) 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 - R Withdraw Control Rods S
Reactivity event 2 - N Roll Main Turbine S
Normal event 3 - C(B) 0A PW pp Trip S
4 - TS High RCS Activity X
S 5 - C(B)
RX Cavity Fan Trip S
6 - C(A), TS SG Tube Leak X
S 7 - I(A)
Spurious Auto Makeup S
8 - M SGTR X
X S
BOP operates SG PORVs manually ATC operates PZR PORV manually 9 - C(A & B)
LOOP XX E
S NRC: During the immediate actions of the RX Trip, buses 141 and 142 would initially not be powered or would be powered by the EDGs following EDG starts.
This should be clarified on the D-2 for Event 8&9. As written, there is no Note or Comment which states that LOOP has occurred following the RX trip.
Response: Examiners NOTE added for the subsequent LOOP.
9 0
0 0
0 2
3 8
S
ES-301 Operating Test Review Worksheet Form ES-301-7
[11]
Facility: Braidwood Exam Date: 3/7-3/16/22 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
[12]
Facility: Braidwood Exam Date: 3/7-3/16/22 Scenario 1
2 3
4 5
6 7
8 11 Event Totals Events Unsat.
TS Total TS Unsat.
% Unsat.
Scenario Elements U/E/S Explanation 1
9 0
2 0
2 0
0 E
Update boundary criteria for CT-Event #8. Completed. Scenario is now SAT.
2 10 0
2 0
2 0
0 S
None.
3 8
0 3
0 2
0 0
S None.
4 9
0 2
0 3
0 0
S Clarify D-2 for Events 8 & 9. Completed.
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
[13]
Facility: Braidwood Exam Date: 3/7-3/16/22 OPERATING TEST TOTALS Total Total Unsat.
Total Total Unsat.
Explanation Edits Sat.
Admin.
JPMs 9
0 7
2 Sim/In-Plant JPMs 11 0
8 3
Scenarios 4
0 1
3 Op. Test Totals:
24 0
16 8
0%
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).