ML22250A448

Initial Exam 2022-08 Draft Operating Test Comments

ML22250A448
Person / Time
Site:	South Texas
Issue date:	09/08/2022
From:	Heather Gepford NRC/RGN-IV/DORS/OB
To:	South Texas
References
Download: ML22250A448 (1)

Text

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL A1 A

N 3

E NRC:

1) Based on the task standard and the critical steps 2 and 3, circling the out of tolerance data points is a critical part of the critical steps. It appears its acceptable if the applicant documents these abnormalities in the remarks section (Logsheet page 1), despite not being in compliance with 0POP01-ZQ-0022 section 4.3.9.

2) Headings on student handouts should be bolded and/or larger heading font.

3) Delete and/or and reference to circling TI-0432B being critical from task standard, key, and JPM standard step 2. Applicant may circle it, but it is not critical and applicant must explain why it was circled (not due to it failing the OPDT channel check).

Licensee:

1) A circle is required by the task standard and by procedure. Additionally a comment needs to be placed in the remarks section.

2) Bolded and changed to 16 pt

3) Changed task standard and key to reflect TI-0432B May be circled and that if it is it requires a comment in the remarks section.

A2 A

N 3

S NRC:

1) Headings on student handouts should be bolded and/or larger heading font.

Licensee:

1) Bolded and changed to 16 pt

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL A3 A

N 3

X E

NRC:

1) Reference the equipment EPN (part number -

CV-NFR-101B) in the initiating cue.

2) Do any other P&IDs reference the RC filters?

Something to require the applicants to determine which schematics to use rather than only have one option.

3) Applicant may also tag PI-0141B root valve (CV0144B)

4) Based on the note (and task standard), only one of 1-CV-0142A or B is required to be identified as a boundary, however, both JPM steps 3 and 4 are marked as critical. This is contradictory. Also, the sequence requires that the vent valve be tagged prior to the drain valve, which appears to be critical. JPM steps 3 and 4 should clarify this.

Licensee:

1) Added Equipment label

2) No other P&IDs reference the RC Filter

3) Added note on page 6 that it may be tagged but not required.

4) Clarified JPM Steps 3 and 4 and notes on required tagging and sequence.

A4 A

N 3

E Free Look Submittal NRC:

1) Ensure final outline is updated to address JPM from draft outline this replaced. Ensure JPM is documented on final outline as BANK JPM.

2) Split task 1 of the JPM into two separate tasks (both are critical) - 1 being the minimum dress reqs and the other being the max duration allowed

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL

3) Does the site have an admin dose limit (ex, 80% of max RWP allowed dose)? Concern is that applicant could determine 4-hour stay time to hit an admin limit that, while may not be contained in the RWP, but an applicable RP procedure.

Licensee:

1) JPM coded as D on outline

2) JPM step 1 split into 2 separate critical steps.

3) STP does not have an admin dose limit, as discussed.

A5 A

N 3

S NRC:

1) Is the assumption made that no fuel assemblies are loaded into grid locations G6 through G10 based on student handout 2?

2) Add F/A ID #s to key & JPM standard.

Applicant may reference fuel assembly ID #s rather than or in addition to grid location.

Licensee:

1) With no information in the core location chart, it is assumed no fuel assembly is loaded. (HO3)

2) Added F/A ID #s as requested.

A6 A

N 3

E NRC:

1) Separate procedure and data sheet package

2) Check/initial prereqs on provided handout p.3

3) JPM step 1 should be marked as critical and include an explanation of what errors the applicant is to determine such that the acceptance criteria is not met (as written, applicant can pass the JPM by saying acceptance criteria is not met for the wrong reasons). Update task standard to reflect this.

Licensee:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL

1) Will separate handouts

2) Initialed and N/Ad steps as required

3) JPM step 1 marked critical, step 1 task standard enhancement to include two errors that cause the surveillance to be unacceptable, and task standard updated.

A7 A

N 3

E NRC:

1) What purpose does student handout 5 have to the JPM? Appears it could be eliminated.

2) Applicant may determine the root valve FC0002 for PI-1402 should be isolated. This would be non-critical.

3) Add WAN # to key Licensee:

1) During SRO review of ECOs, if a question arises they look at the Work Order to ensure the ECO covers job scope.

2) Added - candidate may add FC0002 for PI-1402, it is not required but acceptable to add

3) Added WAN to Key A8 A

N 3

E NRC:

1) Why is the added information in the release permit of the student handout in red font? This makes it appear to be a key, as all JPM keys contain red font. Recommend changing info in student handout to normal black font for consistency.

2) Since the task standard has three separate critical aspects, recommend separating critical step 1 into THREE separate critical steps - one for procedure step 5.11, one for procedure step 5.14, and for procedure step 5.26.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL

3) Math on key & handout p.16 (step 5.19) is incorrect. Not 0.79. 0.28 is the correct answer, which directs applicant to perform Section 7.0.

Licensee:

1) We print in black and white, the red helps in development and will not be seen by the candidates.

2) Created 3 separate critical steps.

3) Fixed math to preclude going to section 7.0 A9 A

N 2

E NRC:

1) Is it operationally valid to have RT-8050 and 8051 reading different values? Example - 8050 reading 47,000 and 8051 reading 42,000. This would require the applicant to apply that only one monitor is reqd to be > 45,000 to meet the RPSA definition.

2) Will the applicant need any other references for the JPM, such as EAL bases (to potentially determine if containment is lost, as FG.1 can exist with a potential loss of containment)?

Licensee:

1) Changed RT-8050 and 8051 readings.

2) Should not need the basis document but if requested we could provide.

S1 S

N 3

E NRC:

1) Desired letdown flowrate provided in step 10 cue could be included in the initiating cue of the JPM rather than an examiner cue when establishing letdown flow via the orifice isolation valves.

2) Cue sheets do not match - ensure examiner cue sheets includes direction of flowrate to establish.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL Licensee:

1) Moved desired orifice valve to initiating cue and referenced initiating cue in the step

2) Ensured both cue sheets match S2 S

Y 3

E NRC:

1) The applicant can perform step 11 to direct throttling 1-CS-0009A directly with the booth operator as the signal to the booth operator to throttle the valve.

2) Is the applicant expected to use the annunciator response procedure in the sim since no handout is being provided?

3) Typo on 0POP07-CS-0001 handout, page 7.

Mode should be mode 3, not mode 4.

4) Add to JPM standard step 15 & to task standard that pump must be tripped within 1 minute (per procedure precaution).

Licensee:

1) We do not use the radio for JPMs since 2 candidates are performing JPMs at the same time. The cue to the Booth operator can be worked out prep week.

2) Yes any unexpected annunciator responses will be addressed with the simulator 0POP09s.

3) Now read Mode 3

4) Note added to step 15 and to task standard S3 S

Y NRC:

1) Sim setup instruction page and examiner initial conditions/initiating cue pages run together.

2) Is the RCP start permissive in step 11 modeled in the sim (any operational concerns with using time compression as noted in the step)?

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL

3) Add no RCP maintenance has been performed to the cue sheets.

Licensee:

1) Put in page break.

2) The start permissive is modeled in the simulator for the blue light to come on. There is an administrative requirement for 2 minutes so time compression is acceptable.

3) added to cue sheets S4 S

N 2

S S5 S

Y 3

S NRC:

1) Is there an alarm or sugar cube light for low flow (i.e. any indication outside of an analog indicator) that will be received when MOV-0031A is closed (step 11)?

Licensee:

1) No but there is a digital value on a graphics page to provide flow indication if the candidate pulls it up.

S6 S

N 2

E NRC:

1) Update task title to Isolate Accumulators (appears to be a holdover from the alt path version that vented the accumulators).

Licensee:

1) Task title updated as requested.

S7 S

Y 3

E NRC:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL

1) Is it not critical to isolate the B train exhaust flowpath with A in service (step 7)?

Licensee:

1) Added Step 7 as a critical step.

S8 S

N 2

S P1 P

N 3

E NRC:

1) Clean up initiating cue - eliminate you have been handed the procedure and

2) Will the applicants be allowed to open the cabinet housing the tools such as the 2.5 fire house and spanner wrench? Is this cabinet locked (key)?

3) The draft schedule shows this JPM being run on both units, but 0POP04-ZO-0001 requires them to open common unit valves. Are steps 6

& 7 of Add 9 actually until specific (i.e. hydrant 7 on U1 side and hydrant 20 on U2 side)?

Licensee:

1) Cleaned up Cue.

2) Yes they will be allowed to access the cabinets and they are unlocked.

3) All the valves and hydrants are unit specific.

P2 P

Y 3

E Free Look Submittal NRC:

1) Ensure final outline is updated to address JPM from draft outline this replaced. Ensure JPM is documented on final outline as MODIFIED JPM.

2) During onsite validation - consider changing JPM step 6 to a provided cue (breaker closure in a different location).

3) Cannot find this JPM in the 2018 NRC exam (LOT-22) final approved exam submittal.

Appears this is modified from the 2017 NRC

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL exam (LOT-21, JPM P3). Update outline to reflect correct exam.

4) Draft schedule shows this being run on both units, however it is only written for U1. Must ensure it is written to perform on BOTH units in order to fit the schedule.

5) Provide examiner cue for bus current (25 amps), if asked

6) Changed examiner cue to provide bus voltage of 131VDC rather than 130.5VDC.

Licensee:

1) Outline updated with M

2) Considered changing however the MCC is very close by and the breaker would be in the off position following maintenance activities. Will leave as is as discussed during validation week.

3) Updated outline

4) Written for both Units

5) Added bus current in initial conditions operating normally with a charging current of 25 amps

6) Changed cue to 131.0 VDC and deleted step referencing adjustments per section 9 from JPM P3 P

Y 3

E NRC:

1) Examiner provided cues for step 3, for example, will be something to the effect of valve handwheel rotated counterclockwise and rotation has stopped, stem has risen. Improve cues in steps 3, 6, 9, 11, 14, 15

2) Change K/A on JPM & outline to A3.02 (see outline comments & resolution).

3) Add examiner note highlighting differences in how to stop the pump (C/S or pushbutton) and it is not critical to stop the pump using the p/b.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: South Texas Project Exam Date: August 22, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL Licensee:

1) Added info that valves are 90 degree valves to cue

2) Outline and JPM updated.

3) Added note that either method of stopping the pump will constitute meeting the critical step.

Form 2.3-3 Instructions for Completing the JPM Table

1. Enter the JPM number and/or title.

2. Enter the type of JPM(S)imulator, (P)lant, or (A)dministrative.

3. Enter (Y)es or (N)o for an Alternate Path JPM.

4. Rate the level of difficulty (LOD) of each JPM using a scale of 1-5 (easy-difficult). A JPM containing less than two critical steps, a JPM that tests solely for recall or memorization, or a JPM that involves directly looking up a single correct answer is likely LOD = 1 (too easy). Conversely, a JPM with over 30 steps or a JPM that takes more than 45 minutes to complete is likely LOD = 5 (too difficult).

5. Check the appropriate block for each JPM error type, using the following criteria:

LOD = 1 or 5 is unsatisfactory (U).

REF: The JPM lacks required references, tools, or procedures (U).

IC: The JPM initial conditions are missing or the JPM lacks an adequate initial cue (U).

CUE: The JPM lacks adequate evaluator cues to allow the applicant to complete the task, or the evaluator cues are subjective or leading (U).

TSK: The JPM lacks a task standard or lacks completion criteria for a task standard (U).

CS: The JPM contains errors in designating critical steps, or the JPM lacks an adequate performance standard for a critical step (U).

TL: The JPM validation times are unreasonable, or a time-critical JPM lacks a completion time (U).

6. Mark the JPM as unsatisfactory (U), satisfactory (S), or needs enhancements (E). A JPM is (U) if it has one or more (U) errors as determined in step 5. Examples of enhancements include formatting, spelling, or other minor changes.

7. Briefly describe any JPM determined to be unsatisfactory (U) or needing enhancement (E). Save initial review comments and detail subsequent comment resolution so that each exam-bound JPM is marked by a satisfactory (S) resolution on this form.

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: South Texas Project Scenario: 1 (Free Look Submittal)

Exam Date: August 22, 2022 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

Swap CRE HVAC - AHU 11A trips, swap back to C train E

NRC:

1) Scenario guide states that computer room dampers are open - how is the applicant to determine this? Is FV-9699 c/s in the MCR?

2) SRO should be credited with a (N) on this event. Ensure Form 3.4-1 reflects this.

3) Add a note to Event 1, separating the steps to secure C train and to restart C train.

4) Reword TRM 3.7.7 applicability statement

- TRM is applicable and should be entered, but no actions are necessary to be taken.

Licensee:

1) these dampers are operated from the MCR.

2) Form 3.4-1 updated to reflect SRO event credit.

3) Added note stating US will direct restarting C train.

4) Reworded statement 2

SG 1D controlling level ch LT-0549 fails low S

3 PZR press controller s/p fails to -30psi E

NRC:

1) Recommend adding to the Event 3 description on page 2 that triggering event 3 will take 7 minutes to build in prior to receiving the low PZR pressure alarm (to ensure this is clearly understood by all examiners during pre-scenario brief)

2) Change Event 4 transition to TS call OR Lead examiner discretion, as the DNB TS may not be applicable depending on the crews timely action.

3) Clarify the DNB TS and action (using same format as Event 1 and 2) and specify as applicable Licensee:

1) Added to summary page

2) Event 4 transition modified

3) DNB TS clarification added via note.

4 SGFPT #13 trip and SGFP #14 fails to start.

Downpower to 80%

S NRC:

1) 0POP04-FW-0002 Add 1 states that (for BOL), 117 gal BA per 10% power reduction are necessary. This is approx.

234 gal BA. Scenario guide states 200-400 gal. Why such a wide difference?

2) Include actions to initiate boration Licensee:

1) By the beacon predict on the turnover sheet 380 gallons is needed. The numbers listed in the addendum are for a wide range of fuel burn-up and are close but not precise but can be used.

2) Actions added.

5 SGFPT #12 trips on overspeed.

Manual Rx trip E

NRC:

1) Recommend adding to Event 5 description on page 2 that Event 5 will be triggered automatically at 95% on the operator controlled downpower.

2) Is 90% or 85% the pertinent limit here?

Draft outline highlighted 90%, but it appears that > 85% w/<2 SGFPs running, a Rx trip is reqd. How is 90% pertinent to this situation?

3) Will need to validate 95% auto trigger provides for adequate crew evaluation and a lower setting > 90%, may be better suited.

Licensee:

1) Event 5 trigger at 95% power added to event summary.

2) 85% is the required Rx trip power level.

3) Validation showed that adequate crew evaluation was obtained with trip at 95%.

6 PZR PORV 655A leaking S

NRC:

1) C credit not given to ATC on Form 3.4-1.

Remove MC from RO credit in Event 6.

Ensure Form 3.4-1 is updated.

Licensee:

1) Credit given to ATC and MC credit removed.

7 SBLOCA on Loop B CL E

NRC:

1) Need to determine a consistent scenario termination point and add to the scenario guide. If the crew has accomplished both CTs, we could terminate the scenario upon transition to E-1 Licensee:

1) Termination criteria of completion of Add 5 added (p. 26/44).

NRC:

1) We must be able to see the procedure transition from E-0 to E-1, simply completing Add 5 is not sufficient. Change to reflect the termination criteria in the Event Summary.

2) Ensure scenario termination criteria is well identified in scenario (currently buried in a note under a CT).

3) CT-16 bounding criteria does not appear to be obtainable within a reasonable amount of time in the scenario.

Recommend changing the bounding criteria to transitioning out of E-1.

Licensee:

1) Added to termination criteria in summary.

2) Created new shaded block for termination in body. Also added termination criteria point should crew continue with EO-10 without securing RCP (CT failure point)

3) Changed bounding criteria to prior to transitioning out of EO-10. Also added steps 13 -20 of EO-10 to guide to allow evaluators to follow progress should crew continue with procedure.

8 CCW pumps 1B

& 1C fail to auto start X

E NRC:

1) Does not appear that bounding criteria for starting CCW pump prior to transition to CL recirc is pertinent to this scenario.

RWST low level to transition to CL recirc is not attainable in the anticipated duration of this scenario (SBLOCA). How long would it take to get to RWST low level of 14% at the given RCS leak rate?

Licensee:

1) Changed CT bounding criteria to prior to completion of Add 5.

N/A NRC:

1) Recorded parameters on page 5 must include available pertinent parameters; Example: Rx power, pressure, level (primary and secondary), temperatures (Tave, CETCs), steam & feed flows, ECCS flows, RVLIS, etc. If switch positions are capable of being recorded, this is encouraged. Data needs to be retained until all license decisions are finalized.

Licensee:

1) parameters will be collected and maintained until license decisions are finalized

Facility: South Texas Project Scenario: 4 Exam Date: August 22, 2022 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

Raise power from 95% to 98%

E NRC:

1) Since this is BOL, is this is initial power ascension (i.e. is the fuel conditioned)?

Crew will likely ask regarding fuel conditioning limits for ramping.

Licensee:

1) Added to turnover sheet fuel conditioning requirements are met.

Open loop ACW pump 12 trips, OLACW pump 11 fails to auto start S

NRC:

1) Add C credit from SRO.

Licensee:

1) Added C credit for SRO 3

PZR level controller LK-0665 fails to 100%

S 4

1B SG MS-PT-0524 fails low, affecting in-service steam flow channel for SGWLC E

NRC:

1) Typo on p.16 - FT-0524 (not 523)

2) TS 3.3.2 Function 4.c is not applicable due to being > P-11.

Licensee:

1) FT-523 is the operable channel that is selected. Moved channel selection to make clearer.

2) removed Function 4.c 5

1D cold leg TT-440B fails high E

NRC:

1) Seems that we would need to make sure rod control was back in auto (from Event

1) prior to inserting this event.

2) Typo on p.19 - should reflect loop D cold leg RTD T-440B

Licensee:

1) Students may or may not place rod control back in automatic following power ascension.

2) Fixed typo.

6 Generator output breaker trips, causes Rx trip S

7 Main turbine fails to auto trip on Rx trip and inadvertent FWI S

8 Train B 4160V bus lockout E

NRC:

1) Tripping the 12 EDG is bolded as if its part of CT-13, when it does not appear to be. Is there a time limit on operating an EDG without cooling water?

Licensee:

1) Un-bolded the ESF Bus and EDG 12 since they are not part of critical task.

9 Loss of Heat sink (AFW pump 13 trips, pump 14 overspeed trips)

E NRC:

1) Scenario guide assumes that feed and bleed criteria will be met at FR-1 step 2, tripping RCPs and going to step 11. If feed & bleed is not met, steps are not depicted for the crew to take until that point is reached.

2) Is the 13 AFW pump trip on a timer post-trip or a manual trigger?

3) Need to verify that bounding criteria of orange path on core cooling is obtainable within a reasonable period of time within the bounds of the scenario.

4) Scenario termination should be referenced on p.25 like it is in the event summary (clarify when to terminate the scenario on p.25)

Licensee:

1) Added steps if feed and bleed criteria is not met.

2) It is on an automatic trigger.

3) Changed bounding criteria due to length of time to get to an orange path. The criteria was changed to prior to all S/Gs lowering to < 5% WR level.

4) Termination criteria added and made to correspond to critical task bounding criteria.

NRC:

1) Scenario 4 must be run due to the need to run a scenario including contingency procedures (FR-H.1 in this case).

Licensee:

1) Will run scenario 4 for the exam

Form 2.3-3 Instructions for Completing the Scenario Table

1. For each scenario, enter the scenario event names and descriptions.

2. Review the individual events contained in each scenario, and identify and mark event errors:

The scenario guide event description is not realistic/credibleunsatisfactory (U).

The scenario guide event description lacks adequate crew/operator performance standardsneeds enhancement (E).

The scenario guide event description lacks verifiable actions for a credited normal event, reactivity event instrument/component malfunction, or technical specification (TS) event (or a combination of these) (U).

The scenario guide event description incorrectly designates an event as a critical task (i.e., a noncritical task labeled as critical or a critical task labeled as noncritical). This includes critical tasks that do not meet the critical task criteria (i.e., the critical task does not have a measurable performance standard) (U).

The scenario guide event description incorrectly designates entry into TS actions when not required or does not designate entry into TS actions when required (U).

3. Based on the outcome in step 2, mark the scenario event as unsatisfactory (U), satisfactory (S), or needs enhancements (E). An event is (U) if it has one or more (U) errors as determined in step 2. Examples of enhancements include formatting, spelling, or other minor changes.

4. Briefly describe any scenario event determined to be unsatisfactory (U) or needing enhancement (E). Save initial review comments and detail subsequent comment resolution so that each exam-bound scenario event is marked by a satisfactory (S) resolution on this form.