ML23160A173
| ML23160A173 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/18/2023 |
| From: | NRC/RGN-III/DORS/OB |
| To: | Constellation Energy Generation |
| Gregory Roach | |
| Shared Package | |
| ML22007A051 | List: |
| References | |
| Download: ML23160A173 (1) | |
Text
Form 2.3-3 Operating Test Review Worksheet (JPMs) 1 Facility: Dresden Exam Date: April 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 SRO ADMIN LOD REF IC TSK CUE CS TL A1.1 Reactivation of SRO License A
N 2
X E
S NRC: Based on the task standard statement, JPM Step 6 should be a critical step as here the applicant makes the determination that the individual does not meet the requirements for reactivation.
Response: Made Step 6 critical A1.2 Initiate a Firewatch A
N 3
X E
S NRC: Outline K/A shows 2.1.5, which is not applicable. Recommend 2.1.20, Ability to interpret and execute procedure steps.
Outline updated to show this as a modified JPM.
Why is barrier functionality in JPM step 3 non-critical?
Response: Updated K/A to 2.1.20 Outline has been updated The candidate could decide either on function determination of the door. They could decide it is functional and just propped open for this task or decide is not-functional due to the cords going through. There is no hard set rule for this determination.
This is why step 3 is not critical.
NRC Validation Comments:
Cables through 125VDC battery room door ONLY JPM Step 2 fire areas 70A1 and/or 70A2 JPM Step 13 N/A or No both acceptable answers Dresden Response:
Changed cue to state only 125VDC Battery Room north door Changed step 2 fire areas to 7.0A.1 and/or 7.0A.2 and changed key to reflect this as well.
Changed step 3 to allow both NA or No as acceptable answers and changed the key to reflect this as well.
Form 2.3-3 Operating Test Review Worksheet (JPMs) 2 Facility: Dresden Exam Date: April 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 SRO ADMIN LOD REF IC TSK CUE CS TL A2 Review ACPS A
N 3
X E
S NRC: Key has incorrect ACPS Number (20-124 instead of 23-124) on EST Log.
Response: Corrected ACPS Number on Key NRC Validation Comments:
Change validation time to 15 minutes On answer key the following items are NOT critical:
System number Will the change question answers Normal component position Dresden Response:
Changed validation time to 15 minutes Changed answer key for the following to NOT be critical:
System number Will the change question answers Normal component position A3 Select Personnel for Radiation Work A
N 3
S A4 Initiate a Fire Watch A
N 2
U NRC: This JPM is a change to what was submitted during the 150 day OPTEST Outline which indicated the determination of an emergency classification was the topic of this JPM.
(U) NUREG 1021 Rev 12, ES 3.2, B.2.(b) specifically indicates that Admin JPMs specifically associated with the Emergency Plan topic must be related to the Emergency Plan and its implementation procedures. Addressing a fire impairment would not test the Emergency Plan or its implementing procedures.
(E) JPM Step 2 standard should indicate 8.2.7 not 8.27
Form 2.3-3 Operating Test Review Worksheet (JPMs) 3 Facility: Dresden Exam Date: April 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 SRO ADMIN LOD REF IC TSK CUE CS TL A4 Authorize Use of KI A
N 1
2 U
E S
Response: Replaced JPM with a JPM which tests emergency plan actions.
NRC: This JPM is a little too easy and is an LOD 1. The determination they will have to make is that an inplant worker must perform work when a loss of RCS Barrier is present. I would argue perhaps having the applicant perform sections 4.3 and 4.4 with the given info provided would be a better JPM with a more appropriate LOD.
Title of EP-AA-113-F-02 Form is Authorization for Emergency Exposure, incorrectly called Authorized for Emergency Exposure on examiner and applicant cue sheets.
Response: Expanded JPM to include performing section 4.3 as well as 4.4.
Candidate will have to fill out EP-AA-113-F-02, that line from the cue has been removed.
NRC Validation Comments:
Remove JPM Step 3 and associated cue as the applicant was informed that the emergency workers were briefed previously by RP Dresden Response:
Removed JPM step 3 and associated cue Early Look Unsat Enhancement Satisfactory
Form 2.3-3 Operating Test Review Worksheet (JPMs) 4 Facility: Dresden Exam Date: April 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 RO ADMIN LOD REF IC TSK CUE CS TL A1.1 APRM Gain Adjustment A
N 2
E S
NRC Validation Comments:
Add OD-9 to the initial cue for what documents to provide to the applicant Dresden Response:
Added Core Thermal Power Edit (OD-9) to what documents to hand to the applicant A1.2 Torus Water Level Correction A
N 2
E S
NRC Validation Comments:
5 minute validation time Dresden Response:
Changed validation time to 5 minutes A2 Verify SLC Heater Surveil.
A N
2 E
S NRC: Confirm that an RO would be expected to review this TS surveillance performed in the field by an NLO.
Which SLC temp is referred to in step I.9.g? Step does not specify suction or recirc temp; recirc temp is within 5 deg and would satisfy the step.
Response: Confirmed that yes an RO would be expected to review this surveillance.
SLC temp being referred to is in Step I.1 the SBLC storage tank solution temperature NRC Validation Comments:
Make value of heater ON temperature 98oF in procedure step I.10.f Dresden Response:
Changed value of heater ON temp to 98°F in procedure step I.10.f in both the key and the applicant handout.
Form 2.3-3 Operating Test Review Worksheet (JPMs) 5 Facility: Dresden Exam Date: April 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 RO ADMIN LOD REF IC TSK CUE CS TL A4 Determine Actions for Fire A
N 2
E S
NRC: If the applicant is to complete DOA 0010-10 Att A (per step D.1.f), wouldnt the steps be complete in that procedure up to that point? JPM note prior to step 1 states that a clean copy of DOA 0010-10 should be provided. If the procedure is continuous use, the applicant would have to perform the steps to get to D.1.f in order to perform the task as referenced in the initiating cue.
Recommend providing marked up copy.
Response: Marked up procedure to indicate Step D.1.f is the next step to be performed and updated page 4 of JPM to describe what procedure should be made available for candidate.
Early Look Unsat Enhancement Satisfactory
Form 2.3-3 Operating Test Review Worksheet (JPMs) 6 Facility: Dresden Exam Date: April 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 CONTROL ROOM/SIM LOD REF IC TSK CUE CS TL
- a. CRD Overtravel S
Y 3
S
- b. Secure RWCU S
N 3
X E
S NRC Validation Comments:
JPM Step 9 closing 2-1201-9A is a critical step Dresden Response:
Made JPM Step 9 Critical
- c. ERV Acoustic Monitor S
N 3
X E
S RO-only NRC: Is limitation G.1 applicable to the simulator or only the actual plant. (Will time compression be possible?)
Add an initial condition stating the applicant is an extra NSO.
Response: Limitation is for the plant only. Added Note at the beginning of the JPM to allow for time compression.
Added initial condition of being an Extra NSO.
NRC Validation Comments:
JPM Step 16 should record all Relief Valve and all Safety Valve tail piece temperatures Dresden Response:
Changed JPM Step 16 to record all tail pipe temperatures
- d. Alt Depress using IC Vent S
N 2
S
- e. EDG Surv.
S Y
3 X
E S
NRC: Add an initial condition stating the applicant is an extra NSO.
Applicant may ask if DOS 6600-14 is being performed concurrently (caution prior to Att A step 7). Add cue for examiner to state that it is not being performed.
Form 2.3-3 Operating Test Review Worksheet (JPMs) 7 Facility: Dresden Exam Date: April 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 CONTROL ROOM/SIM LOD REF IC TSK CUE CS TL Response: Added initial condition of being an Extra NSO.
Added cue to state DOS 6600-14 is not being performed.
NRC Validation Comments:
Initiating Cue and provided procedure to indicate that the JPM will start with procedure step I.19.e Dresden Response:
Updated the Document Preparation description for DOS 6600-01 be singed off through I.19.d.
Changed Initiating Cue to start at step I.19.e Removed JPM Step 1 and associated Cue and renumbered the rest of the JPM appropriately.
- f. Withdraw SRM S
Y 2
S NRC: KA importance ratings for A2.03 are 2.9/2.7 per Rev 3 of NUREG 1123. Update the JPM summary page. Forms 3.2-2 updated by NRC.
Response: Verified per NUREG 1123 Rev 3 SRMs K/A 215004.A2.03 Importance Ratings are 3.1/3.2 NRC: NRC reviewer in error. Outlines have been corrected for importance ratings of 3.1/3.2.
- g. Swap CW S
Y 3
E S
NRC: If cueing the applicant that the EO field actions are complete, the procedure should reflect that, with those steps (G.3.d) marked up.
JPM does not reflect notifying chemistry in step G.3.f (needs examiner acknowledgement cue).
With JPM steps 10 and 11 being immediate operator actions of DOA 4400-01, is the applicant required to reference the procedure?
Form 2.3-3 Operating Test Review Worksheet (JPMs) 8 Early Look Unsat Enhancement Satisfactory Facility: Dresden Exam Date: April 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 CONTROL ROOM/SIM LOD REF IC TSK CUE CS TL Response: DOP 4400-02 has been marked up fully with the next step is starting the pump.
Added cue regarding contacting Chemistry.
Added info to Note about Immediate Operator Actions do not need to reference the procedure prior to taking the actions.
- h. Off Gas Charcoal Ads S
Y 2
E S
NRC Validation Comments:
Add an examiner cue indicating that, Another operator will perform DOP 5750-12 if asked.
Dresden Response:
Added cue after JPM Step 8 that, If the candidate starts looking for DOP 5750-12 inform them another NSO will perform DOP 5750-1212 and temperature controllers inside 2223-46a(b) have been set properly.
Form 2.3-3 Operating Test Review Worksheet (JPMs) 9 Facility: Dresden Exam Date: April 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 INPLANT LOD REF IC TSK CUE CS TL
- i. Fire Actions
- i. SBLC Alt Water Injection P
N 2
X E
S NRC: Overlap with RO Admin 4. Admin JPM directs performing these actions and this JPM performs the actions in the field.
Oversampling the same fire response actions on two separate JPMs is unnecessary. RECOMMEND REPLACING THIS JPM.
JPM step 1 [Step G.1 identifies the bypass for Drywell Cooler Trip is located in G.3] appears to be a copy and paste from JPM J.
Why is JPM step 10 critical?
Are these RO responsibilities (K/A 2.4.34)? K/A 2.4.35 for nonlicensed operator responsibilities may be a better K/A match.
Response: Replaced JPM
- j. Trip of DW Coolers P
N 2
S NRC Validation Comments:
Consider making this JPM usable on either unit. I very much want this JPM to be performed on Unit 3 so as to test applicants on both units, but if exam week work schedule results in protective pathways interfering with Unit 3 equipment we will want to be prepared Dresden Response:
Discussed with Chief Examiner and there will be a Unit 2 version of this JPM ready in standby if for some reason this JPM cannot be performed on Unit 3.
- k. IA Cross Tie P
N 2
E S
NRC: If were cueing the applicant that the procedure is completed up to step G.8, we should provide them a marked up a copy to reflect that, rather than a clean copy as indicated in the JPM.
Correct the KA importance rating to 3.2 on JPM summary page.
Response: Marked up DOP 4700-03 complete up to step G.8.
Form 2.3-3 Operating Test Review Worksheet (JPMs) 10 Facility: Dresden Exam Date: April 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 INPLANT LOD REF IC TSK CUE CS TL Importance Rating updated to 3.2 NRC Validation Comments:
Remove clean from the examiner cue regarding providing DOP 4700-03. This procedure should be marked up per the initiating cue Dresden Response:
Changed NOTE at beginning of JPM to Provide the candidate with the marked up copy of DOP 4700-03 Early Look Unsat Enhancement Satisfactory
Form 2.3-3 Operating Test Review Worksheet (JPMs) 11 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) 12 Facility: Dresden Scenario: # 1 100% Rx. Power SPARE SCENARIO Exam Date: April 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 Validation Comments:
Add No failed fuel in the core to the turnover sheet Dresden Response:
Added No failed fuel in core to turnover sheet.
Circ Water Flow Reversal E
S Normal Event NRC: This event was a change from the outline submitted at the 150-day submittal. Ensure updated outline is submitted at the 75-day exam submittal.
I would expect the BOP to perform step 5.d to verify valve positions, please include in the 3.3.-2.
Response: Step 5.d added to the scenario guide.
Outline updated for new normal event.
Stuck Control Rod S
Recirc Runback X
E S
NRC: Remove may from CRS actions regarding direct performance of DOP 0202-03. In addition, add a SM inject to drive the crew to reset the runback if they do not elect to do this on their own. This ensures the ATC has a verifiable action that has a feedback mechanism during this event. Starting the Aux Oil Pump will not be successful and has no effect on the course of the event.
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 13 Facility: Dresden Scenario: # 1 100% Rx. Power SPARE SCENARIO Exam Date: April 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 Response: Removed may from scenario guide regarding performance of DOP 0202-03.
NRC Validation Comments:
Add may place 2B RFP and Aux Oil Pump in PTL Dresden Response:
Added May place 2B RFP and Aux Oil Pump in PTL FP Rad Monitor Fail X
S BOP manually closes SCIVs which failed to close automatically HP Heater Trip S
Reactivity Event IC Tube Leak Isolable LPCI Leak X
E S
NRC Validation Comments:
Swap IC tube leak to Scenario 4 and replace with LPCI Leak event for balanced TS difficulty between applicants Dresden Response:
Swapped Swap IC tube leak to Scenario 4 and replace with LPCI Leak event Recirc Leak in DW S
Loss of FRV, HPCI Degraded, ED XX U
NRC: CT PC-1.1 requires initiating DW Sprays before 6 minutes or PSP. Will PSP be achieved if DW sprays not initiated? How much time will it take? If PSP will be exceeded, then that is the only boundary condition needed. If it will not then this is not a CT for this particular scenario. The 6 minutes does not appear
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 14 Facility: Dresden Scenario: # 1 100% Rx. Power SPARE SCENARIO Exam Date: April 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 S
defensible in this instance as there is no particular plant degradation tied to it.
Combine CTs RPV-1.1 and RPV-2.1. Effectively the CT should be ED with minimum number of available ADS valves when RPV level is between TAF and MSCRPVL or within 2.5 minutes whichever is longer.
Based on the scenario and the requirements of OP-DR-103-102-1002, I would expect the applicants to operate both trains of CS to restore level > TAF and they should be able to establish conditions to keep LPCI lined up in its DW/Torus spray and cooling modes if still needed.
We will need to be very (more) clear what is acceptable in the CT description.
Response: CT RPV-1.1 and RPV-2.1 have been combined and OP-DR-103-102-1002 requirements for minimum injection have been incorporated in the scenario guide.
NRC: CT PC 1.1 completion time of 6 minutes remains UNSAT. That completion time is associated with chugging during ATWS conditions. This not an ATWS scenario, a 10 minute completion time is based on LOCA conditions would be acceptable if the candidates would start seeing feedback from the simulator that chugging is occurring after 10 minutes or that the PSP
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 15 Facility: Dresden Scenario: # 1 100% Rx. Power SPARE SCENARIO Exam Date: April 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 curve has been violated based on the LOCA conditions given in this specific scenario.
Response: Removed Critical Task PC 1.1.
NRC Validation Comments:
Add CT to Inhibit ADS prior to ADS valves automatically opening.
Remove CT to inject with at least 2 CS pumps as no verifiable action is required for operators to perform this action as they auto start on high DW pressure and will inject when operators depressurize the plant.
Add torus cooling steps to scenario guide.
Dresden Response:
Added CT to inhibit ADS prior to ADS valves automatically opening (RPV-1.5).
Removed CT to inject with at least 2 CS pumps.
Added torus cooling steps to scenario guide (in Recirc Leak Event, Event 7)
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 16 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 Swap Service Water Pumps S
Normal Event Raise Power with Rods E
S Reactivity Event NRC Validation Comments:
Start at Rod Sequence Step 16 Rod L13 Dresden Response:
Changed turnover and setup pages to reflect starting at Step 16 Rod L-13 Rod Drift X
E S
NRC: Credit both the ATC and BOP with a component malfunction for this event as both have verifiable actions. Update Scenario outline accordingly.
Response: Gave credit to both ATC and BOP for this event.
Trip of Bus 28 X
X E
S NRC: Add, Enters DOA 6700-07, 480V BUS FAILURE to both the list of CRS and BOP actions. This procedure is referenced in the event termination criteria but not explicitly called out in the required operator actions section of the event.
DOA 0500-05 Step D.5.a calls out bypassing APRM 1 for a loss of RPS Bus B. Is the ATC expected to perform this action?
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 17 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 Response: Added DOA 6700-07 to both BOP and CRS actions.
Added bypassing APRM 1 to ATC actions.
NRC Validation Comments:
Add, is open to booth communication regarding the status of the Bus 28 feed breaker at Bus 23-1 Add NO regarding there being NO change DW CAM reading for booth communication.
Add open bullet steps for BOP to vent the DW if required.
Add booth communication for RB D/P value of -0.4 if asked.
Add booth communication for local annunciator report regarding the U2 EDG due to the loss of the circulating oil pump.
Remove step to start a Condensate Transfer pump as B pump is running to start the scenario and not affected by loss of Bus 28.
Add CRS May enter DOA 6600-03 Open bullet and state may enter DOA 0500-05 and steps like bypassing APRM 1 would be open bulleted.
Dresden Response:
Added is open to booth communication regarding the status of the Bus 28 feed breaker at Bus 23-1.
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 18 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 Added NO regarding there being NO change DW CAM reading for booth communication.
Added open bullet steps for BOP to vent the DW if required.
Added booth communication for RB D/P value of
-0.4 if asked.
Added booth communication for local annunciator report regarding the U2 EDG due to the loss of the circulating oil pump.
Removed step to start a Condensate Transfer pump as B pump is running to start the scenario and not affected by loss of Bus 28.
Added CRS May enter DOA 6600-03 Opened bullet and stated may enter DOA 0500-05 and steps like bypassing APRM 1 would be open bulleted.
Trip of RFP Vent Fan S
ATC manually starts RFP Vent Fan Steam Leak in DW E
S NRC: 2-1501-11A, 20A and 38A will not be able to be opened for Torus cooling with Bus 28 faulted. Update BOP required actions in scenario guide that only B pathway is available.
Response: Updated BOP actions to reflect only B pathway available.
Leak Worsens, Electrical ATWS XX U
NRC: Critical Task PC-1.1 is UNSAT for this specific scenario. Since this a low power scenario with an electrical ATWS which will not last for long (operator action to remove fuses is 4 minutes), be mitigated to the
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 19 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 E
S condenser (MSIVs open), and with power most likely below APRM downscale while in the ATWS the boundary condition of exceeding PSP will not be reached even if no action to spray the DW is taken. In addition, as the ATWS is low power ATWS the 6 minute chugging time critical action would not be appropriate for this condition. The 10 minute LOCA chugging limit could arguably be more applicable with a large steam leak present in containment.
List hard card actions for lining up and operating DW and Torus Sprays in the scenario guide.
Response: Removed the PSP reference in the critical task. The 6-minute bounding criteria used in CT PC-1.1 is based on TCA19 from OP-DR-102-106, OPERATOR RESPONSE TIME PROGRAM AT DRESDEN. Added delay time for pulling the scram fuses to ensure the time in the ATWS is sufficient for this critical task.
Added hard card actions for DW & Torus sprays in event in SEG.
NRC: Will there be indications of chugging in the containment 6 minutes after 11psig is attained if DW spray is not initiated?
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 20 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 Response: No operationally valid indications of chugging are available to program into the simulator NRC Validation Comments:
Remove step to place MSIV Key Locks in Bypass.
Remove booth note lift leads on Off gas Hi Hi rad isolations.
Adjust note regarding fuse pullers for Scram fuses to not delay action if DW sprays have already been actuated.
Closed bullet for CT action to secure DW sprays before DW pressure reaches 0 psig.
Dresden Response:
Removed step to place MSIV Key Locks in Bypass.
Removed booth note lift leads on Off gas Hi Hi rad isolations.
Added NOTE regarding not delaying action if DW sprays have already been actuated.
Closed bullet for CT action to secure DW sprays before DW pressure reaches 0 psig.
Since there is no event in this scenario which requires manual control action by the BOP, SROI-3 does not perform a manual control action during the exam according to the Form 3.4-1 Event and Evolutions Checklist. This is UNSAT. RECOMMEND ADDING 1
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 21 Facility: Dresden Scenario: # 2 ~5% Rx. Power Exam Date: April 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 MORE C/I MALFUNCTION FOR THE BOP WHICH INCLUDES A MANUAL CONTROL ACTION.
Response: Swapped positions for the operators, now the number of beans works out for the required events for SROI-3
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 22 Facility: Dresden Scenario: # 3 90% Rx Power Exam Date: April 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 Secure Torus Cooling E
S Normal Event NRC Validation Comments:
Closed bullet for CRS direction to perform Dresden Response:
Closed bullet for CRS direction to perform CRD Pump Trip X
E S
NRC Validation Comments:
Add booth communication regarding status of RVLIS reference leg fill if CRD pump running or not Dresden Response:
Added booth communication regarding status of RVLIS reference leg fill if CRD pump running or not High Temp on MPT X
E S
NRC: It is not clear what equipment will be secured by the BOP. The scenario starts with only 2 RFPs and 3 CD/CBPs running, so it is not a secondary pump. The BOP must have a verifiable action for this event to count as a component failure. Confirm what verifiable actions you expect the BOP to take and add them to the scenario guide with a closed bullet.
Response: Raised initial power level to 90% to ensure 3 RFPs and 4 C/CB pumps are running to allow for verifiable actions during this event.
NRC Validation Comments:
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 23 Facility: Dresden Scenario: # 3 90% Rx Power Exam Date: April 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 Add BOP action that they, May lower VARS.
Remove booth communication telling applicants not to adjust VARS.
Ensure BOP actions to secure RFP and CD/CB is closed bulleted and included in the Scenario Guide.
Dresden Response:
Added BOP action that they, May lower VARS.
Adjusted booth communication for TSO to agree with whatever the crew wants to do.
Added actions for securing 3rd RFP and 4th C/CB pump Added to event completion criteria the securing of the RFP and C/CB pumps Lower Power to Unload MPT S
Reactivity Event APRM Upscale X
U S
ATC manually initiates a half Scram NRC: With a failure of RPS to insert a half scram with APRM 5 failed up scale, the CRS will also need to enter TS 3.3.1.1. Condition C with one or more functions with RPS trip capability not maintained. So, I would expect LCO 3.3.1.1 Condition A to be entered for APRM 5 and LCO 3.3.1.1 Condition C entered for the failure of RPS to half scram on fixed neutron flux-high.
Response: Added LCO 3.3.1.1 Condition C to SEG as a required LCO NRC Validation Comments:
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 24 Facility: Dresden Scenario: # 3 90% Rx Power Exam Date: April 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 Ensure LCO 3.3.1.1 Condition C is in the Scenario Guide (REVISION CONTROL!).
Remove annunciator 902-5 D-15 CHANNEL B RX SCRAM.
Dresden Response:
LCO 3.3.1.1 Condition C is in SEG Removed annunciator 902-5 D-15 CHANNEL B RX SCRAM Stator Water Cooling Pp Trip S
BOP manually starts standby SWC Pp Steam Leak in HPCI Room X
E S
NRC Validation Comments:
Remove when condensate and feed from the initiating statement of this event.
Remove CRS action to inject with CRD and SLC.
Dresden Response:
Removed when condensate and feed from the initiating statement of this event Remove CRS action to inject with CRD and SLC ED on Two Areas
> Max Rad X
E S
NRC: The 2021 Quad Cities exam included a 10 minute boundary condition for this CT. Adding time limits is not ideal but we have to have something to consider when assessing how long we allow the applicants to not perform a CT. The wording defining how the CT is not met from TQ-DR-155-1001 was included in the scenario
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 25 Facility: Dresden Scenario: # 3 90% Rx Power Exam Date: April 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 guide and a 10 minute back stop was added to say the CT was not met if the blowdown was not initiated within 10 minutes of exceeding the same max safe parameter in multiple areas.
Response: Took out reference to DEOP 400-5 in CT and added 10 minute bounding criteria.
NRC Validation Comments:
Open bullet for MCR HVAC actions Dresden Response:
Made MCE HVAS actions an open bullet (in Event 6, Steam Leak in HPCI Room)
ERV Fails to Open U
E S
NRC: CT RPV 2.2 is not applicable to this scenario as there is not a challenge to ensuring adequate core cooling. RPV level will be maintained 8-48 inches with condensate and feed during this event. Per TQ-DR-155-1001 the purpose of establishing this CT with less than 5 ERVs open was to ensure timely injection to ensure adequate core cooling, during an ED due to loss of high head injection. That is not the case here, we have a steam leak lowering RPV pressure along with the crew possibly anticipating ED with TBVs and 4 ERVs opening when ED is performed. The reactor will depressurize and adequate core cooling will be maintained at all times. We absolutely will expect the applicants to use alternate depressurizing components IAW DEOP 300-1 Table P2 as required by DEOP 300-1
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 26 Facility: Dresden Scenario: # 3 90% Rx Power Exam Date: April 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 and would be marked accordingly if they did not follow procedure requirements, but this is not a critical task in this instance.
Response: Removed RPV-2.2 as a critical task.
NRC Validation Comments:
Remove HPCI as an alternate depressurization system Dresden Response:
Removed HPCI as an alternate depressurization system
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 27 Facility: Dresden Scenario: # 4 81%
Exam Date: April 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 Validation Comments:
Start scenario at 81% to ensure enough of a downpower for reactivity event Dresden Response:
Starting scenario at 81%
Swap DEHC Pp S
Normal Event MR Level Fail with Partial Half Scram X
E S
ATC manually initiates a half Scram NRC:
- 1. Medium Range Level Instruments Objective 3.b Provide RPS, PCIS, Recirc Pump trip, ATWS, ECCS, ADS, EDG Logic, and Main Turbine and Reactor Feed Pump trip functions. These instruments also provide the operator with an indication band of 60 to +60 inches at the 5 Panel.
Based on the above it appears a loss of 2B MR Level instrument would also affect TS 3.3.2.2 FW and Turb Level Trip, TS 3.3.4.1 for ATWS-RPT, TS 3.3.5.1 for ECCS and ADS Response: Added the other required Tech Specs.
NRC Validation Comments:
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 28 Facility: Dresden Scenario: # 4 81%
Exam Date: April 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 Remove references to TS 3.3.2.2, 3.3.4.1, 3.3.5.1.
Recommend reviewing info provided in ILT lesson plan.
Dresden Response:
Removed references to TS 3.3.2.2, 3.3.4.1, 3.3.5.1.
Will write a Training Request after exam to review info provided in ILT lesson plan.
Isolable LPCI Pipe Break IC Tube Leak X
E S
NRC: Completion criteria should include leak isolated.
Response: Added leak isolated as a completion criteria for the event.
NRC Validation Comments:
Swapped LPCI leak to scenario 1 for IC tube leak.
Ensure event start point statements in the role play section match new scenarios for both events.
Dresden Response:
Swapped LPCI leak to Scenario 1 for IC Tube Leak.
Event starting point statements match the new scenarios.
HSOP Pp Fail S
BOP manually starts ESOP Pp Lower Power S
Reactivity Event
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 29 Facility: Dresden Scenario: # 4 81%
Exam Date: April 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 IAC Oil Leak E
S NRC Validation Comments:
Add note for booth communications that oil is not going into drains Dresden Response:
Added to communication that oil is not going down the drain and the drain is plugged.
RR Speed Controller Failure E
S NRC Validation Comments:
Add note from IMD requesting that the speed hold be reset if a crew not planning on taking that action.
Remove may for reset speed hold ATC actions.
Open bullet for TS 3.4.1 loop flow mismatch. Not expecting condition to be met.
Remove TS indication on the outline for this scenario as it is not expected that crew will enter TS 3.4.1.
Dresden Response:
Added communication from IMD requesting the Speed Hold be reset.
Removed may for resetting Speed Hold ATC action and made it a closed bullet.
Made bullets open for TS 3.4.1.
Removed TS indication on the outline for this event.
NR Level Leg Leak E
NRC: Spell out actions for starting torus cooling in the scenario guide.
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 30 Facility: Dresden Scenario: # 4 81%
Exam Date: April 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 S
Response: Actions included for starting torus cooling.
RPV Flood XX E
S NRC: Per TQ-DR-155-1001, CT RPV 4.1 has the boundary condition of ensuring adequate core cooling is maintained. Are there any simulator parameters which can be used to indicate actual level has gone below TAF if action to initiate RPV Flood has not occurred by then?
A boundary needs to be established and this CT is there to ensure adequate core cooling.
Response: Added bounding criteria of before adequate core cooling is lost as indicated by a rise in Drywell radiation levels to the critical task. If ACTUAL level as determined by a background variable of the simulator drops below TAF a 4 minute timer will start and a Fuel Element Failure will occur.
NRC Validation Comments:
Add RPV 4.2 CT nomenclature to bullet associated with items used to determine that the reactor has been flooded to the steam lines Dresden Response:
Added RPV 4.2 CT nomenclature to bullet associated with items used to determine that the reactor has been flooded to the steam lines
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 31 Facility: Dresden Scenario: # 4 81%
Exam Date: April 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 SRO-I2 will not receive credit for a reactivity maneuver while in the BOP position and will therefore need an additional C/I malfunction while serving in the BOP position. RECOMMEND ADDING 1 ADDITIONAL C/I MALFUNCTION FOR THE BOP, Response: Added another event to satisfy the requirements.
Form 2.3-3 Operating Test Review Worksheet (Scenarios) 32 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.