ML23247A007

NRC Comments on Draft Licensee-Developed Operating Test

ML23247A007
Person / Time
Site:	Ginna
Issue date:	09/28/2022
From:	Joseph Demarshall NRC/RGN-I/DORS/OB
To:	Constellation Energy Generation
References
EPID L-2022-OLL-0008
Download: ML23247A007 (1)

Text

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to eliminate the words per O-1.2.1.

References to an attached KEY that has been provided are acceptable.

Avoid making references to procedures in the Task Standard.

(RO/CO1 ) E Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure reference is identified, can imply that Perform 1/M Plot A N/A 3 S every step in the procedure is intended to be critical.

LICENSEE:

• Eliminated per O -1.2.1 from the Task Standard.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• JPM A1b summary description on Outline Form 3.2-1 incorrectly references Steps 6.1.1 through 6.1.2 of O-3. The Initiating Cue states:

The US has directed you to perform a Xenon Reactivity Calculation (RO/CO2) in accordance with O-3, HOT SHUTDOWN WITH XENON E PRESENT, up to Step 6.2.2.

Perform a Post-Trip A N/A 3 Revise the Form 3.2-1 summary description to reference the correct Xenon Reactivity S steps.

Determination LICENSEE:

• Revised Form 3.2-1 summary description to read: O -3, HOT SHUTDOWN WITH XENON PRESENT, up to Step 6.2.2.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to include the calculated QPTR value of (RO/EC) 1.028 +/- 0.001 A N/A 3 E Manually Calculate S LICENSEE:

QPTR

• Revised the Task Standard to include the calculated QPTR value of 1.028 +/- 0.001.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 1 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to read as follows:

The task is satisfactorily met when the applicant has (a) determined the type and percent of the release to the Containment Atmosphere to be a 1% Fuel release, and (b) identified that Attachment 1 of S-(RO/RC) 14.3 is the correct attachment for estimating the isotopic concentrations in the Containment Atmosphere.

Respond to a High E Containment Area A N/A 2 S LICENSEE:

Radiation Monitor

• Revised the Task Standard to read as follows: The task is satisfactorily Alarm met when the applicant has (a) determined the type and percent of the release to the Containment Atmosphere to be a 1% Fuel release, and (b) identified that Attachment 1 of S-14.3 is the correct attachment for estimating the isotopic concentrations in the Containment Atmosphere (per the attached KEY).

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 2 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL 2019 GINNA NRC RETAKE EXAM (Previous 2 NRC Exams)

NRC:

• Revise the Task Standard to use the words based on evaluation of O-6.9, Attachment 2, Offsite Power Operability Curves rather than in accordance with Attachment 2 of O-6.9 and more clearly describe the expected outcome (i.e., end state) as it pertains to the four required crew actions for successful completion of the JPM. Avoid making references to procedures in the Task Standard. Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure reference is identified, can imply that every step in the (SRO/CO1) procedure is intended to be critical.

E

• JPM Key contains information that the operator may indicate that offsite Determine Operating A N/A 2 power circuit INOPERABILITY must be reported to the to the NRC Limits for Station 13A S (Step 6.2.4 / P&L 4.6 / JPM Step 7). There is no reference to NRC Transmission Reportability in Step 6.2.4 / P&L 4.6 / JPM Step 7. Clarification required.

LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the Applicant has determined that for the given plant conditions the Offsite Power Circuits are INOPERABLE, based on evaluation of O-6.9, Attachment 2, Offsite Power Operability Curves and identifies four required crew actions per the attached KEY.

• Revised wording on the JPM KEY to read: The operator may indicate that the offsite power circuit INOPERABILITY must be reported to the NRC (P&L 4.6). This is NOT required for full credit.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 3 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Task Standard omits ACTION A.1, which is identified on the JPM Key.

• Revise the Task Standard to read as follows:

The task is successfully met when the applicant, per the attached Keys, (a) determines that TS LCO 3.3.2, Functions 2c and 4c, are NOT met because of the failure of PI-946, requiring implementation of ACTIONs A.1, F.1, and J.1, and (b) determines that a loss of Safety Function does NOT exist based on performance of a Safety Function Determination (Attachment 1 of A-52.4).

• Appears that the Performance Standard in JPM Step 2, pertaining to the operator placing a YES in the Entered? Column for LCO 3.6.6, should also be designated as a Critical Step. This step is necessary for successfully determining the combination of LCOs that result in a (SRO/CO2) Potential Loss of Safety Function in JPM Step 4 (A-52.4, Attachment 1, E Step 3.0).

Perform a Safety A N/A 3 Note: The Critical Step Justification for JPM Step 2 (Page 3 of the Function S JPM) would have to be appropriately revised to include the LCO Determination 3.6.6. information if designated as a Critical Step.

LICENSEE:

• Revised the Task Standard to read as follows: The task is successfully met when the applicant, per the attached/provided Keys, (a) determines that TS LCO 3.3.2, Functions 2c and 4c, are NOT met because of the failure of PI-946, requiring implementation of ACTIONs A.1, F.1, and J.1, and (b) determines that a loss of Safety Function does NOT exist based on performance of a Safety Function Determination (Attachment 1 of A-52.4).

• Designated JPM Step 2 Performance Standard for LCO 3.6.6 as a Critical Step and revised Critical Step Justification for JPM Step 2 to include LCO 3.6.6.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Enhance the Key by providing a corrected version of the Tagout (SRO/EC) Request sheet with the corrections identified in RED, instead of what E was initially provided in the JPM.

Review a Clearance A N/A 3 and Tagging S LICENSEE:

Boundary for Work

• Revised the JPM KEY to include a corrected version of the Tagout Request sheet with the corrections identified in RED.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 4 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL

(SRO/RC) NRC Early Review JPM Determine if a A N/A 3 S Radioactive Release is in Progress

NRC Early Review JPM NRC:

• Enhance the Task Standard to read:

The task is satisfactorily met when the applicant has declared a Site Area Emergency based on EAL FS1 within 15 minutes and completed the GNP NY STATE RADIOLOGICAL EMERGENCY DATA FORM (PART 1) per the attached key, within 15 minutes of the time of event (SRO/EP) classification.

Classify an E

• Editorial: JPK Step 12 Performance Standard contains a spelling error.

Emergency Event A N/A 3 Should be ANY instead of ANT.

and Complete the S Notification Form LICENSEE:

• Enhanced the Task Standard to read as follows: The task is satisfactorily met when the applicant has declared a Site Area Emergency based on EAL FS1 within 15 minutes and completed the GNP NY STATE RADIOLOGICAL EMERGENCY DATA FORM (PART

1) per the provided KEY, within 15 minutes of the time of event classification.

• Changed ANT to ANY in JPM Step 12.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words in accordance with AR-PPCS-T2108, AR-PPCS-T2119 and/or AR-PPCS-T2120 and per P-17.22. Avoid making references to procedures in the Task Sim A Standard. Statements such as using, IAW, or per a procedure, E regardless of whether the specific procedure reference is identified, can Swapping S Y 3 imply that every step in the procedure is intended to be critical.

Condensate Booster S Pumps LICENSEE:

• Revised the Task Standard to eliminate the words in accordance with AR-PPCS-T2108, AR-PPCS-T2119 and/or AR-PPCS-T2120 and per P-17.22.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 5 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to eliminate the words per Step 7 of ECA-0.0. Avoid making references to procedures in the Task Standard.

Statements such as using, IAW, or per a procedure, regardless of Sim B E whether the specific procedure reference is identified, can imply that S Y 3 every step in the procedure is intended to be critical.

Start the EDG During S a Station Blackout LICENSEE:

• Revised the Task Standard to eliminate the words per Step 7 of ECA -

0.0.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words per Section 6.2 of O-7; per Section 6.3 of O-7; per AR-AA-23, RCS OVER-PRESS PROTECTION TRAIN B HI PRESS and more clearly describe the expected outcome (i.e., end state) for successful completion of the JPM. Avoid making references to procedures in the Task Standard.

Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure reference is identified, can imply that Sim C E every step in the procedure is intended to be critical.

Placing LTOP in S Y 3

• Enhance the context of the Task Standard by providing the information S that the Wide Range RCS Pressure Channel PT-451 is being defeated Service after failing high.

LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has placed PCV-430 and PCV-431C in the LTOP mode of operation; and after failing HIGH, has defeated Wide Range RCS Pressure Channel PT-451.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 6 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to eliminate the words in accordance with the Annunciator Response Procedures, AP-CVCS.1 and/or AP-CVCS.3. Avoid making references to procedures in the Task Standard. Statements such as using, IAW, or per a procedure, Sim D E regardless of whether the specific procedure reference is identified, can S Y 3 imply that every step in the procedure is intended to be critical.

CVCS Leak S Detection LICENSEE:

• Revised the Task Standard to eliminate the words in accordance with the Annunciator Response Procedures, AP-CVCS.1 and/or AP-CVCS.3.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words in accordance with ES- 0.1 and specify how manual energization of the SR Instruments is attempted (i.e., depressing 2 of 2 P-6 permissive defeat pushbuttons).

Avoid making references to procedures in the Task Standard.

Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure reference is identified, can imply that every step in the procedure is intended to be critical.

• Revise the Task Standard to eliminate the words in accordance with ER-NIS.1 and ensure that the information about reinserting the fuses is Sim E also included. Avoid making references to procedures in the Task E Standard. Statements such as using, IAW, or per a procedure, Manually Energize S Y 2 regardless of whether the specific procedure reference is identified, can the Source Range S imply that every step in the procedure is intended to be critical.

Instruments LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has attempted to manually energize the Source Range instruments by depressing 2 of 2 P-6 Permissive Defeat Pushbuttons, recognized that this was unsuccessful and manually energizes the Source Range instruments by pulling and reinserting the instrument fuses, while maintaining instrument switch position configuration control.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 7 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to eliminate the words per Section 6.2 of ER-RHR.1 and more clearly describe the expected outcome (i.e., end state) for successful completion of the JPM. Avoid making references to procedures in the Task Standard. Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure Sim F reference is identified, can imply that every step in the procedure is E intended to be critical.

Lineup RCDT Pump S N 3 S for Core Cooling LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has aligned the Main Control Board switches and coordinated with the Equipment Operator to align the RCDT Pumps to provide core cooling, started both the A&B RDCT Pumps and established core cooling flow by fully opening FCV-624 and 625.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words per Step 4 of ECA-Sim G 1.1. Avoid making references to procedures in the Task Standard.

Statements such as using, IAW, or per a procedure, regardless of Evaluate CNMT E whether the specific procedure reference is identified, can imply that Spray Flow S N 3 every step in the procedure is intended to be critical.

Requirements and S Reduce Flow in ECA-LICENSEE:

1.1

• Revised the Task Standard to eliminate the words per Step 4 of ECA -

1.1.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 8 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• Revise the Task Standard to eliminate the words per ER -RCC.1 and more clearly describe the expected outcome (i.e., end state) for successful completion of the JPM. Avoid making references to procedures in the Task Standard. Statements such as using, IAW, or per a procedure, regardless of whether the specific procedure Sim H E reference is identified, can imply that every step in the procedure is S N 2 intended to be critical.

Recover a Dropped S Control Rod LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has coordinated with and directed the IMD Technicians and CO to withdraw Control Rod E-7 to the first MRPI transition (8 Steps).

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words in accordance with Attachment 4 of ER-FIRE.1 and more clearly describe the expected outcome (i.e., end state) for successful completion of the JPM. Avoid making references to procedures in the Task Standard. Statements IP-I such as using, IAW, or per a procedure, regardless of whether the E specific procedure reference is identified, can imply that every step in Take Local Manual P N 2 the procedure is intended to be critical.

Control of Charging S Pump LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has taken local control of and started Charging Pump A, stabilizing speed at 1,360 +/- 10 RPM.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 9 of 19 Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: R. E. Ginna Nuclear Plant Exam Date: October 17, 2022 1 2 3 4 5 6 7 JPM # or Title Type ALT LOD JPM Errors U/E/S Explanation (S/P/A) (Y/N) (1-5) LOD REF IC TSK CUE CS TL NRC:

• LOD=1. JPM consists of two Pushbutton manipulations, both located at the CRDM control panel. JPM, as written, limits the ability of the Examiner to perform an effective and proper evaluation of the applicants. Replace JPM and update the Form 3.2-2 Outline. Ensure selection of appropriate Safety Function and that all License Level Criteria are satisfied if any change to the Type Code information.

• Avoid making references to procedures in the Task Standard.

IP-J Statements such as using, IAW, or per a procedure, regardless of 1 U whether the specific procedure reference is identified, can imply that Locally Open the P N every step in the procedure is intended to be critical.

Control Rod Drive 2 X S MG Set Breakers LICENSEE:

• Replaced with Bank JPM and updated Form 3.2-2. No change in Safety Function, K/A, or Type Code. Replacement JPM is time critical.

• The JPM Task Standard reads as follows: The task is satisfactorily met when the applicant has tripped the Control Rod Drive Motor Generator Set Breakers by depressing the TRIP pushbutton for 52-1/MG1A and 52-1/MG1B within 10 minutes of the start of the JPM, and then locally trips the Main Turbine.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

NRC:

• Revise the Task Standard to eliminate the words in accordance with ATT-16.0, ATTACHMENT RUPTURED S/G and more clearly describe the expected outcome (i.e., end state) for successful completion of the JPM. Avoid making references to procedures in the Task Standard.

Statements such as using, IAW, or per a procedure, regardless of E whether the specific procedure reference is identified, can imply that IP-K P N 3 every step in the procedure is intended to be critical.

S LICENSEE:

• Revised the Task Standard to read as follows: The task is satisfactorily met when the applicant has locally isolated the B S/G by closing the B MSIV locally and the TDAFW Pump Steam Root Valve from the B S/G.

JPM determined to be Satisfactory based on Chief Examiner evaluation.

Page 10 of 19 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.

Page 11 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 1 Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions

1 Shift Electric Plant S

2 Master Pressure S Controller (431K)Fails High

3 25 GPM RCS Loop A S Cold Leg Leak

4 Rapid Downpower S

5 Failure of Turbine S Control/EHC

6 1000 GPM Loop A Leg S SBLOCA (CT-2)

7 Failure of A SI Pump to S Auto Start, Trip of C SI Pump (CT-1)

Page 12 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 2 (NRC Early Review Scenario) Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions 1

Swap Service Water S Pumps (SWP)

2

SWP C Check Valve S Sticks OPEN/SWP D Trips

3 S

Pressurizer Level LT-427 Fails LOW 4

Letdown Pressure S Control Valve F ails CLOSED in AUTO 5

Turbine Control Valve S CV-L4 Drifts Closed/Downpower 6

Steamline Break in S Intermediate Building/Delayed Closure of MSIVs

Page 13 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 2 (NRC Early Review Scenario) Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions 7

Automatic Rx Trip S Fails (Manual Pushbutton Available)

(CT-1)

NRC:

• Enhance the Measurable Performance Standard Expected Actions statement for CT-2 on the Critical Task Sheet to read:

Trips both RCPs, Opens both PRZR PORVS using ATT-12.0, BEFORE the Pressurizer Code Safety Valves open.

8 Ensure the Measurable Performance Standard Expected Actions statement is updated on Forms MDAFW and TDAFW E 3.3-1 and 3.3-2.

Pumps Fail to START (CT-2) S LICENSEE:

• Enhanced the Measurable Performance Standard Expected Actions statement for CT-2 on the Critical Task Sheet to read: Trips both RCPs, Opens both PRZR PORVS using ATT-12.0, BEFORE the Pressurizer Code Safety Valves open.

• Ensured the Measurable Performance Standard Expected Actions statement is updated on Forms 3.3-1 and 3.3 -2.

Scenario Event determined to be Satisfactory based on Chief Examiner evaluation.

Page 14 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 2 (NRC Early Review Scenario) Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions NRC:

• There is no Event 9 Component Failure associated with the Start of D SAFW Pump once Bleed & Feed has been established. The malfunction preventing the start of D SAFW Pump to ensure implementation of Bleed & Feed is removed upon completion of these actions (see Sim Driver Instructions on Page 57 of 71 for removal of MALF FDW15B). No impact to the scenario resulting from one less Post-EOP Entry Malfunction.

Ensure that Forms 3.3-1, 3.3-2, 3.4-1, and 2.3-2 (Target Quantitative Attributes per Scenario section) are appropriately revised / updated.

• Form 3.3-1 Event Summary states that the crew 9 will start D SAFW Pump to restore a feed source E to the B S/G. In this scenario, it appears that the D SAFW Pump can be used to restore feed to both D SAFW Pump is S the A and B S/Gs, as indicated by the Note started associated with Step B of EOP-ATT 5-1, Attachment SAFW from SW, on Page 67 of Form 3.3-2. Make any necessary changes to ensure alignment between Forms 3.3-1 and 3.3-2.

LICENSEE:

• Deleted Scenario Event No. 9 from Form 3.3-1 and Form 3.3-2. Ensured that Forms 3.4-1 and Form 2.3-2 (Target Quantitative Attributes per Scenario section) are appropriately revised /

updated.

• Revised Form 3.3-1 and Form 3.3-2 Event Summary to state Upon successful implementation of RCS Bleed and Feed, the crew will start SAFW Pump D restore a feed source to at least one S/G in accordance with ATT-22.0, ATTACHMENT RESTORING FEED FLOW.

Include the following statement with Form 3.3-1:

NUREG 1021, ES-2.3, Form 2.3-2, Target Quantitative Attributes per Scenario Section, specifies a Target Range of 1-2 for Table item #4, EOPs

Page 15 of 19 entered/requiring substantive actions. A detailed review of Scenario #2 confirms that the scenario is built to directly transition from E -0 to Functional Recovery Procedure FR-H.1, Response to Loss of Secondary Heat Sink, and that no Westinghouse Primary EOP (E-1, E-2, or E-3) will be entered/used. Consequently, a value of 0 will be assigned for Table Attribute Item 4 on Form 2.3-2, which is outside of the specified Target Range.

NUREG-1021, ES-3.3, Section B.2.g, EOP Operating Procedures Used, states Moreover, the primary scram response procedure that serves as the entry point for the EOPs is not counted. A value of 0 for Table Attribute Item 4 on Form 2.3-2 was determined to be acceptable by the Chief Examiner on the basis that (a) Scenario #2 is a complex scenario that exercises Contingency EOP Procedure FR -H.1 for the Loss of Secondary Heat Sink, (b) FR-H.1 requires the use of alternate decision paths and prioritization of actions within the EOP to mitigate the CSFST Heat Sink Red Path condition, and (c) FR-H.1 has measurable actions that must be taken by the crew.

LICENSEE: The above statements have been included on Form 3.3-1 following the Critical Tasks.

Page 16 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 3 Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions

1 Leak on the CCW S System/CCW Pump B Trips

2 FRV A Oscillations S

3 Condensate Booster S Pump C Trips/Downpower

4 Dropped Rod S

5 Subsequent 2nd S Dropped Rod

6 Steam Generator Tube S Rupture in S/G A (CT-1, 2,3)

7 RCS Depressurization S Valve Fails OPEN After Depressurization

Page 17 of 19 Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: R. E. Ginna Nuclear Plant Scenario: 4 SPARE (Not Used) Exam Date: October 17, 2022 1 2 Scenario Scenario event errors 3 4 Event Realism/ Performance Verifiable Critical Task TS U/E/S Explanation ID/Name: Credibility Standards Actions

1 Load Ascension S

2 VCT Level LT-112 Fails S Low

3 Steam Generator B LT - S 471 Fails Low

4 Open Phase 7T Line S

5 Turbine Trip with One S Stop Valve Failing to Auto Close

6 B Feed Line Rupture in S Containment (CT-1)

7 MDAFW Pump A Fails S to Start in Auto (CT-2)

Page 18 of 19 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 standards needs 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.

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