ML23115A342

6-CGS-2023-02 Form 2.3-3 Draft Op Test Comments

ML23115A342
Person / Time
Site:	Columbia
Issue date:	03/09/2023
From:	Heather Gepford NRC/RGN-IV/DORS/OB
To:	Energy Northwest
References
Download: ML23115A342 (1)

Text

Facility: CGS Exam Date: 2/20/2023 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/A 2

E Task standard should include determining the value of the difference is 1.8% with an appropriate error band, otherwise they could just guess it is satisfactory. Updated Task Standard with 1.8%

error band. Added error bands for CTPTFSP and (CTPCALC - CTPTFSP) calculations to JPM Step 4 Standard and JPM Answer Key. Added error band for (CTPCALC - CTPTFSP) calculation to JPM Step 6 Standard.

NRC Validation Week Comment:

Add error band for (CTPCALC - CTPTFSP) to calculation itself (JPM Step 4) in addition to Step 4 Standard. Error band added to calculation itself.

A2 A

N/A 2

S NRC Validation Week Comment:

Add error bands for all JPM Steps needing determination of a required value. Error bands added for JPM Steps 1 through 5.

A3 A

N/A 2

E Will this JPM be run one at a time, or are there enough available hoses for each applicant? Will only be able this JPM one applicant at a time due to only having one set of hoses.

A4 A

N/A 2

S A5 A

N/A 3

S Is the band too narrow in the task standard? No.

NRC Validation Week Comment:

Facility: CGS Exam Date: 2/20/2023 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 Remove JPM Step 1 (which has candidate determine Rod Line) and update JPM accordingly.

Modified initial conditions (since Rod Line no longer being determined by candidate) and provided Rod Line directly. Deleted JPM Step 1 and updated JPM Step numbering and Task Standard to reflect change.

A6 A

N/A 3

S NRC Validation Week Comment:

Remove requirement to fill out form and replace with requirement to determined Required Comp Measures for Inoperable hose station. Modified JPM to include expected student actions and Task Standard.

A7 A

N/A 2

S A8 A

N/A 3

S One critical step. Need 2 or more. Split out step 4 NRC Validation Week Comments:

One Critical Step. Need 2 or more. Split Step 4 (containing multiple Critical Steps) into Steps 4 & 5 which both contain Critical Steps.

A9 A

N/A 3

E Add time limit to the task standard. Time added.

NRC Validation Week Comment:

Add Spent Fuel Pool level at 19 feet to JPM Initial Conditions. Initial condition added.

P1 P

Y 3

S NRC Validation Week Comments:

1. Clarify on page 3 (under Safety Items) what portions of JPM should be

Facility: CGS Exam Date: 2/20/2023 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 performed in a Low Dose Area. Add associated Examiner Notes. Added clarification and associated Examiner Notes.

2. Include picture on page 7 (without labels) in student reference. Picture (without labels) added to JPM P-1 ILC-25 Ref 1.

3. Provide student with bright flashlight to use during JPM. Added Bright flashlight to Tools or Equipment listing on page 3.

Added prompt to examiner to provide.

P2 P

Y 3

S NRC Validation Week Comments:

No NRC comments.

P3 P

N 3

S Is this in the stations Time Critical Operator Actions program? Yes (OI-69).

NRC Validation Week Comments:

1. Add Examiner Note to ensure student does not go through door between RSD and ASRD panels. Need to use normal access/egress doors. Examiner Note added.

S1 S

N 3

S Wrong SF. Changed JPM such that SLC is used for reactivity control instead of inventory control.

S2 S

Y 3

S NRC Validation Week Comments:

Facility: CGS Exam Date: 2/20/2023 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. Change validation time to 7 minutes.

Changed.

2. Delete bottom 3 bullets for JPM Step 1.

Deleted.

S3 S

N 3

S Bypassing JPMs not a critical step. Changed to non-critical.

NRC Validation Week Comments:

1. Is step 7.3.4.c critical? No. Changed to non-critical.

2. Add range to Step 7 and Task Standard.

JPM Step 7 is now Step 9. Added range of acceptable values.

S4 S

Y 3

S NRC Validation Week Comments:

1. Add note that throttle pressure mode will not work? Note added.

2. Step 3 is critical. Made step 3 critical.

S5 S

Y 3

S NRC Validation Week Comments:

1. Add failure of SGT-V-5B2 to open failure of SGT-V-5B1 to auto-open. Failures added and guide updated including Task Standard.

2. Change validation time to 10 minutes.

Time changed.

S6 S

N 3

S NRC Validation Week Comments:

1. Make Step 5 critical. Change made.

General Comments for All JPMs:

1. Add to the task standard for all simulator JPMs the following statement, The applicants actions did not degrade the condition of the plant beyond that introduced by the JPM as developed.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

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.

Facility: CGS Exam Date: 2/20/2023 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

2. Change validation time to 15 minutes.

Change made.

S7 S

N 2

E Is there failure criteria that can be added to the task standard? Added general Plant degradation statement to address criteria.

Is matching flags critical (Step 5)? No - Made non-critical.

S8 S

N 2

E Is there failure criteria that can be added to the task standard? Added general Plant degradation statement to address criteria.

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.

NRC General Comments for All Scenarios:

1. To be consistent with other exams, change the note following the Critical Tasks on page 3 (for all scenarios) to read, NOTE: (Per NUREG-1021, Appendix D) If an operator or the Crew significantly deviates from or fails to follow procedures that affect the maintenance of basic safety functions, those actions may form the basis of a CT identified in the post-scenario review.

2. For all events, all scenarios - craft the transition statements to follow the general format of when event/activity x is complete or at the NRC lead examiners discretion trigger next event. For the event transitions that are built in or on a timer, the way the guides are written is fine.

3. Lets remove the entire Tech Spec pages from the guides and leave the sentence about specifications that are actually entered.

Facility: CGS Scenario: 1 Exam Date: 2/20/2023 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS NRC:

1. The instructional coversheet has the program title as Requalification Training.

Corrected.

NRC Val Week - R5 leakage high alarm came in at beginning of scenario. Corrected the level of R5 sump in base IC set which should prevent future spurious alarms in future runs.

1 Power Ascension E

NRC:

1. This event also counts as a Reactivity manipulation for the ATC. Ensure form 3.4-1 and 3.3-1 reflects this. Per NUREG guidance instructions for Table 3.4-2 Note (7) The power change can be counted as a normal evolution or as a reactivity manipulation, but not both. For this event I chose to credit the crew with a normal evolution.

2. Does governor valve optimization count as a Reactivity manipulation for the BOP? See above

3. Annotate that step 12 is the beginning of Event 2.

Increased Event header font size that shows up at the top of every page which annotates which event

1. you are in and annotated applicable steps with an examiner note for the beginning of next event.

NRC Val Week - Corrected typo in event header.

Changed power ascention to 95-100% power following GV optimize.

should we delete T.S. 3.5.1.a and add T.S. 3.3.3.1?

Deleted TS 3.5.1 and added guidance as to why they are not required to enter the PAM spec 3.3.3.1 2

RHR-V-17A control power failure S

NRC:

Lets remove the entire Tech Spec and leave the sentence about specifications that are actually entered. Removed snip its from the actual TS.

NRC Val Week - Highlighted the MOV network power loss from Annun response 3

Benton 115kV open phase S

NRC:

2. For transition to event 4 change to When TS call is complete or at lead examiners discretion.

Corrected NRC Val Week - Corrected guide from CB-TRB fails to trip to CB-TRB is manually tripped. Added field operator report for TR-B phase loss.

4 MSE / ABN-Exhauster S

1. For transition to event 5 change to At lead examiners discretion. Corrected.

2. Form 3.4-1 incorrectly credits Event 4 as a Major for the BOP. Corrected.

3. Event 4 is credited for both a Component failure and as a Major. Corrected.

4. Event 4 in Scenario is a Component event only.

Event 6 is the Major Event.

Corrected.

5 Increasing MT Vibrations E

NRC:

1. Annotate step 40 is the beginning of Event 5.

Corrected.

2. Only the ATC should be given credit for R What does the CRS get for credit for this event? If not R ? previous exams, the CRS was given credit for a reactivity manipulation for this type of event where power change is directed based on plant conditions.

- ASK NICK 6

Scram on high vibrations /

MG fail to trip E

NRC:

1. The Safety Significance of CT-1 is questionable.

Tripping the MT on a high vibration condition is protecting generation related components, not safety related components require to mitigate an accident/transient condition. Manually scramming the reactor instead of an automatic scram does not constitute a safety concern, its a competency issue.

Justification could be made that a catastrophic MT failure could result in a challenge to safety related function - ultimate heat sink if SW/ESW lines are potentially at risk. Could not establish this tie.

SW/ESW lines are in a different building.

If failure to trip Main Generator will cause generator to motorize and prevent fast transfer, and EDG fail to start because generator breakers closed, then this might also be a case for safety significance Generator breakers closed does not impact EDG fail to start.

Neither of above examples are called out to bolster safety significance.

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Scenario will still contain the required 2 CTs with this critical task removed. Removing the critical task associated with this event.

2. Event 6 requires the BOP to manually trip the Main Generator. This should be credited as a Manual Control action.

Corrected 7

Startup flow control valves fail S

NRC:

1. For transition to event 8, add or at lead examiners discretion.

Corrected 8

OBE / LOCA

/ RHR-P-2A broken shaft S

9 Ground on SM-3 E

NRC:

1. Event 9 is credited as Manual Control event for the BOP; however, Form 3.4-1 lists Event 10 as the Manual Control. There is no Event 10 in Scenario Corrected

Facility: CGS Scenario: 2 Exam Date: 2/20/2023 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS General NRC Validation Week Comment Resolutions:

Update cover page LESSON TITLE to reflect NRC scenario type and number. All scenario guide cover sheet lesson titles updated as CGS 2023 Initial License NRC Exam Scenario X. Updated page 2 header in each guide to include brief description of scenario.

1 Power Reduction and BPV 2 fails to open E

NRC:

1. For transition to event 2, annotate it as when directed by NRC lead examiner. Updated guide.

2. Reactivity should be for ATC only Updated guide. Updated NRC Form 3.3-1. Updated NRC Form 3.4-1 (Min requirements remain met).

NRC Validation Week Comment Resolutions:

Start scenario at 97% power and remove need to enter MT GV Sequential Mode (will already be there when crew takes shift). Guide updated to include candidate

references and turnover to support new initial conditions. Updated NRC Form 3.3-

1. Resolution also addresses official Validation Week Op Test Comments from NRC CE.

Pre-flag annunciators needed to support OSP-MS-Q702 (eliminates need for crew to do so - saves time). Guide scenario setup guidance updated. Resolution also addresses official Validation Week Op Test Comments from NRC CE.

Identified new OSP-MS-Q702 revision (post-NRC Validation Week). Updated simulator guide and candidate references to reflect new revision (Rev 4). No impact on expected crew actions for scenario.

2 Control Rod 22-23 drifts out E

NRC:

1. In step 33, add a sentence stating that the CRS should enter TX 3.1.3.

C.1 and C.2. Step 33 is now Step 30 in updated guide. Updated Step 30 (HCU disarming step) to reflect specific Tech Spec requirement of step (LCO 3.1.3 C.2). Placed full Tech Spec Actions Statements CRS should enter on Step 29 (LCO 3.1.3 C.1 and C.2).

3 CAS Leak with standby CAS compressors E

NRC:

1. Standby Air Compressor fails to start. BOP starts standby AC. This should be credited as a Manual Control event. Updated guide.

Updated NRC Form 3.3-1. Updated

failing to auto start NRC Form 3.4-1 (Min requirements remain met).

4 Manual Scram with Electric ATWS E

NRC:

1. Lets discuss the examiner note prior to step 61. Is this something the applicants are expected to know?

Step 61 is now Step 59 in updated guide. Yes, applicants understand (and are expected to use) the alternative methods provided on the SOP-RFW-FCV-QC which can be used to feed. Updated Examiner Note before Step 59 to reflect this.

2. On page 52 at step 100, clarify the Examiners Note, May have to prompt the CRS. The booth would prompt the CRS? Is that cueing?

Step 100 is now Step 96 in updated guide. Discussed with CE. Accepted as is although Examiner Note updated to clarify intent of original note.

NRC Validation Week Comment Resolutions:

Add SLC-P-1A trip one minute after start (to ensure scenario meets outline objectives for ATWS actions). Added SLC-P-1A trip to scenario schedule file. Added communication from field when trip investigated. Updated NRC Form 3.3-1.

Resolution also addresses official Validation Week Op Test Comments from NRC CE.

Remove Critical Task (CT) 3 from simulator guide. Falls under the generic crew-created CT statement. CT-3 removed from guide. Updated NRC Form 3.3-1.

Remove Step 73 (from original guide) which had crew perform RPV pressure reduction to 550 psig to support CD/CB injection (should use HPCS or reset feed pump instead). Scenario guide step removed from guide.

5 FDR-V-4 fails to auto close S

6 TR-S lockout and DG-3 breaker failure E

NRC:

1. On page 60 at step 114, clarify the Examiners Note, May have to prompt the CRS. The booth would prompt the CRS? Is that cueing?

Step 114 is now Step 110 in updated guide. Discussed with CE.

Accepted as is although Examiner Note updated to clarify intent of original note.

7 MS-RV-1C inadvertently opens E

NRC:

1. On page 65 at step 123, clarify the Examiners Note, May have to prompt the CRS. The booth would prompt the CRS? Is that cueing?

Step 123 is now Step 119 in updated guide. Discussed with CE. Accepted as is although Examiner Note updated to clarify intent of original note.

2. Event 7 is not credited as a Manual Control event; however, BOP takes manual action to close failed open SRV. Updated guide. Updated NRC Form 3.3-1. Updated NRC Form 3.4-1 (Min requirements remain met).

Event 7 was discussed during NRC Validation Week in that failure to close SRV may form the basis of a CT (based on exceeding the Tech Spec cooldown rate limit) post scenario. Examiner Note (just before Step 116) was added to identify this as a possibility.

8 RCIC-V-13 fails to auto open E

NRC:

1. On page 65 at step 123, clarify the Examiners Note, May have to prompt the CRS. The booth would prompt the CRS? Is that cueing?

Step 123 is now Step 119 in updated guide. Discussed with CE. Accepted as is although Examiner Note updated to clarify intent of original note.

Facility: CGS Scenario: 3 Exam Date: 2/20/2023 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS NRC:

1. The instructional coversheet has the program title as Requalification Training.

Corrected 1

DG-1 spurious start S

NRC:

1. In the examiner note on page 8, change use to used.

Corrected NRC Val Week - Added booth operator cue for offsite power alignment.

2 RCIC spurious start S

NRC:

1. BOP not given credit on Form 3.4-1 for Event 2. Scenario credits BOP.

Credit applied to 3.4-1 3

CRD-FC-600 flow controller oscillations S

NRC:

1. Page 14 note at top of page is incorrect: Corrected

2. Following CRS TS call for power loss to RCIC-V-13 Corrected.

3. Incorrect preceding event, this is from Scenario 2.

Corrected.

4 E

NRC:

MSE with loss of instrumentation

1. Clarify the examiner note after step 36 on page 19. Will any technical specifications need to be entered or the CRS just needs to verify that none need to be entered?

If the condition of the plant warrants entering a technical specification, then that needs to be reflected in the guide.

Clarified and added TS evaluation to the guide. Ask Nick due to 38 Instruments required to be analyzed for the loss of 2 EFCVs.

Also noticed a lack of cue from the shift manager which could have resulted in manual reactor scram per ABN-EARTHQUAKE which would result in bypassing a critical task - added Cue NRC Val Week -Needed a better verified action for event 4. Added RBM Numac failure with operator actions. Added explanation for the TS call associated with te loss of EFCVs 5

CRD-P-1A reduced flow /

scram S

NRC:

1. CT-1 requires a manual scram; however, manual scram is incomplete. Five control rods fail to insert. With an incomplete scram, is CT satisfied? Recommend add note that manual scram with a failure of five control rods to fully insert, meets the CT standard.

Added verbiage to critical task standard to signify that 5 rods will be stuck resulting in a 5 rod ATWS with reactor power < 5%

6 S-1 breaker fails to auto close S

7 Aftershock and closure of EFC valves S

NRC:

1. Critical Task not addressed for establishing Flooded Condition.

This is required for Adequate Core Cooling - Injection established and flooded to MSL.

Adjusted critical task and scenario guide to require verification of flooded to the main steam lines per EOP procedures. Updated Form 3.3-1 to reflect critical task change and minor change to event synopsis.

NRC Val Week - Added management position for critical task 2 and added further explanation for the critical task.

Facility: CGS Scenario: 4 Exam Date: 2/20/2023 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS NRC:

1. The instructional coversheet has the program title as Requalification Training.

Corrected 1

WMA-AD-51A1 failure S

2 RWCU-TK-2 overflow /

OC trip SL-63 / RRC-P-1A runback S

3 RRC-P-1A trip S

TS 3.4.1A added to 3.3-1 for RRC single loop.

4 PP-ASD-1/3 trip / ABN-ASD-INV Scram S

Moved Critical task block earlier in the event 5

Bypass valve sticks open S

Corrected scenario guide to reflect that MS-V-146 would be closed to prevent pressure reduction on stuck open bypass valve and removed

steps that discussed closing the MSIVs.

6 RFW-LIC-620 auto function failure S

7 REA-V-1 airline break S

8 OBE Earthquake /

Suppression Pool wall break E

NRC:

1. Add applicable steps from 5.1.3 for ED.can more be added to guide step 112?

2. For the termination cue - is ED performed with 6 or 7 SRVs?

Added CT-2 to 3.3-1.

Termination cue was entirely wrong and has been corrected. ED is not expected to occur, critical task 2 is performed to prevent the need to ED.

ED is normally 7 SRVs when it is needed and applicable to the scenario guide.

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.