ML24120A191

Ile Form 2.3-3 Operating Test Review Worksheet

ML24120A191
Person / Time
Site:	Point Beach   (DPR-024, DPR-027)
Issue date:	04/05/2024
From:	NRC/RGN-III/DORS/OB
To:	Point Beach
B. Bergeon
References
Download: ML24120A191

Text

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 RO Admins 1

Perform Shutdown Margin Calculation A

3 X

X E

NRC:

1)

Whats the purpose of providing a range in step 2? The applicant is doing math but will not be rounding. The +30 MWD/MTU error seems arbitrary As a result, step 4 should have a tighter range (11.018% - range could be 11.0 -

11.02%).

2)

References on page 4 of the JPM do not list ROD 7, ROD 5, or ROD 3.1.

3)

It appears that step 12 should be critical, as dropped rod worth is not a provided value and is determined from ROD 5 (which can be determined incorrectly due to incorrectly determining burnup range).

Licensee:

1)

Removed band on Step 2 and tightened up band on step 4.

2)

Added Unit 1 Rod book as reference.

3)

Changed to critical.

NRC:

1)

JPM sat as revised.

2 Perform a Pressurizer Heater Group Input Test Calculation A

2 E

Requires Simulator NRC:

1)

Marked up copy of TS-43 1T-1D is not included in the JPM. Table of voltage and current data is obtained in step 5.1.8; applicant begins JPM at step 5.1.14 and has to calculate averages to complete said table.

2)

Why is the simulator required for this JPM when the applicant starts the JPM at step 5.1.14 - all sim data necessary is obtained

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 and provided. Applicant is simply performing math in steps 5.1.14 - 5.1.17 Licensee:

1)

Created a marked up copy of TS-43 using data from the JPM.

2)

Simulator is not required, can be done in simulator or classroom.

NRC:

1)

JPM sat as revised.

3 Calculate and Adjust PPCS Forebay and Pump Bay Alarm Setpoints A

3 E

S Requires Simulator NRC:

1)

Id like to have the applicants show that they know how to navigate the website to obtain the lake level report. Once they get to the point to populate the report, we can provide them the table.

2)

Does any procedural guidance exist to change PPCS alarm limits? PBF-2124 step 8 just says adjust PPC alarm limits to value calculated Licensee:

1)

The STA does the tables, the ROs dont do this, sometimes the STA does the calculations and the ROs only change PPCS. If the mean lake level changes from when JPM was created it would also change the calculations.

2)

No procedural guidance NRC:

1)

JPM sat as submitted.

4 Start a Containment Forced Vent Source Check 1/2RE-305 Low Range Noble Gas A

3 E

Free Look Requires Simulator NRC:

1)

Add OP 9C to cue - continue with OP 9C, starting at Step 5.1.1.h.

2)

Add expected values for RE-211 & 305 in steps 1 & 2.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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

3)

Based on the outline comments, the applicant was to initiate the vent as part of the JPM.

That appears to have been removed. JPM is sat without initiating the vent (also see comment 4 below)

4)

JPM title should be something to the effect of source check 1/2RE-305 (see task standard).

5)

Does the PPC high alarm annunciator response need to be provided to the applicant when the alarm 1/2C20 comes in? Are there any alarm response actions?

6)

Step 6, to record the correct high alarm setpoint appears it should be critical.

7)

Validation of the high alarm less than the ODCM setpoint (identifying the correct ODCM value) in step 5 should be critical as well.

Licensee:

1)

Complete

2)

Complete

3)

Changed title and standard to state task is to source check.

4)

Changed title and standard to state task is to source check.

5)

No action needed but added a cue another operator will look at the ARBs.

6)

No actions by the examinee or changes in how the plant responds so this remains a not critical step.

7)

No actions by the examinee or changes in how the plant responds so this remains a not critical step.

NRC:

1)

JPM sat as revised.

SRO Admins 1

Verify shutdown margin calculation for an operating reactor A

3 E

NRC:

1)

References on page 4 of the JPM do not list ROD 7, ROD 5, or ROD 3.1.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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)

How will handouts within the JPM, such as the marked up copy of PBF-2513 at the end of the JPM, be delineated as the applicants copy?

3)

Performance step 2 states correct value should be -3940pcm. Appears to be a transposition error as -5540 + 1200 + 600 + 250 = -3490pcm

4)

Recommend adding an error to rod worth in step 8 or similar (ensure the applicant can properly use the supporting data & curves).

Currently, the only errors are the total control rod negative reactivity, which is a math error &

a carry forward error in the calculated SDM.

Licensee:

1)

Added Unit 1 Rod book to required references.

2)

Paperwork the examinees cannot see will be in PINK. Examinee turnover papers will be yellow and procedures they need will be on associated color paper, for example Unit 1 is TAN.

3)

Fixed transposition error.

4)

Added error to step 8.

NRC:

1)

JPM sat as revised.

2 Complete a calculation review of TS 32 A

3 X

U S

NRC:

1)

Task standard cut off on page 4. Margin issue in formatting?

2)

Why the range in values in performance step 3? How was the range in values (603.7-604.8) determined? Applicant is adding provided values (totaling 2417.6) and averaging (604.4)

- all values are to the tenth for significant digits; no rounding necessary.

3)

Errors in procedure steps 2.b & 3.b are combined under performance step 3. These can be separated out, as two critical steps, since theyre two separate procedure steps.

4)

Marked up copy of TS-32 attached to JPM is not complete - only includes pages 1-11 (of 18). Missing key steps of Att B to validate

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 performance steps 4 & 5, which are critical steps.

Licensee:

1)

Fixed margin issues.

2)

Removed band from the step.

3)

Split out critical steps.

4)

Corrected missing 2 pages to the JPM.

NRC:

1)

JPM sat as revised.

3 Approve a Clearance Order Authorize Performance of a Surveillance on Shift A

1 X

U S

NRC:

1)

If the applicant is to be reviewing the C/O, shouldnt Form 1 of OP-AA-101-1000 be partially completed with the preparer boxes checks and signed?

2)

How is this JPM not direct lookup / LOD=1 when OI-103 section 5.1 provides the isolation and position for the applicant? The applicant is comparing section 5.1 to the C/O to validate correct transposition.

Licensee:

1)

Form will be filled out as required.

2)

Generated a new JPM associated with CCW to approve performance of a surveillance NRC:

1)

Replacement JPM sat.

4 Remove an RMS channel from service A

2 X

X U

S Requires Simulator NRC:

1)

Does the RO complete steps 1-4 of PBF-2068g

- 1RE-215? Wondering why this is marked up and provided to the SRO applicant. Also, why are PBFs associated with 1RE-315/214/225 marked up and provided?

2)

Why is step 6 of PBG-2068g - 1RE-215 marked up with 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, providing the answer to the applicant?

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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

3)

Applicant should determine that no redundant channel exists and the comp actions in step 5 are required (each of which is critical)

4)

Determining most limiting time requirement in step 6 should be a critical step

5)

Placing channel into maintenance in step 12 should be critical (required by task standard)

6)

Need cue in case applicant questions restoration of RE-215 to service within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (CAMP 014 section 5.1.1)

7)

Required materials (references) should include CAMP 014 & TRM (listed under general references)

Licensee:

1)

The other RMS channels that are OOS would have the forms available in the CR.

2)

Removed the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, was left in error.

3)

Made step critical.

4)

Made step critical.

5)

Leave as is, to be conducted in classroom.

6)

Added cue.

7)

Added references.

NRC:

1)

JPM sat as revised.

5 Formulate protective action recommendations A

2 X

X X

U Requires simulator NRC:

1)

JPM says its to be completed in the sim - cant we provide the references in the classroom and do it in a classroom setting?

2)

The only dose information given is that cnmt high range monitors indicate 625 R/hr. This eliminates one of the two rad indications for rapidly progressing severe accident, but the initial conditions provide no information regarding PAGS are exceeded at the site boundary. A cue exists to inform the applicant that PAGS have not been exceeded. This data should be provided in the initial conditions so the applicant can use the Att F flowchart to

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 determine whether or not the limits were exceeded.

3)

How is performance step 1 critical to the JPM, when the release in progress is not necessary to use the Att F to determine the 5 mile radius evacuation requirement?

4)

Recommend modifying the JPM to make this a rapidly progressing severe accident, such that the applicant has to use the wind direction to determine what 10 mile downwind sectors to evacuate (see comment 2)

5)

Initiating cue says to complete the NARS form, however, that is not part of the task standard and the JPM only has release status, met tower data, and PARS, missing all other form information. If the NARS form is to be required to be completed, task standard and JPM steps should reflect this - also, a completed key of the NARS form should be included.

Licensee:

1)

Simulator or classroom JPM, sim not required.

2)

Modified to have PAGS exceeded at the SBCC.

3)

Discussed and modified JPM.

4)

Modified JPM to exceed PAGS at SBCC and not 5-miles, which would require 10 miles downwind sectors.

5)

Updated cues and standard.

NRC:

1)

JPM sat as revised.

Walkthrough A

Respond to a charging line leak (U2)

S N

3 X

E NRC:

1)

Recommend modifying task standard to include the valves required to isolate the leak, beyond just IAW AOP-1A

2)

Since the cue provided is that the field operator observed a leak on the charging line, do steps 7-9 need to be completed or can they be N/Ad? The note prior to step 7 says they can

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 be performed in any order - but that doesnt mean they can be marked N/A and not performed. Applicant performs step 9 as part of step 10.b.

3)

JPM step 3 is not critical.

4)

Why isnt JPM step 6 critical?

5)

Should include step 10.g to check leak isolated. Applicant should display knowledge to validate leak isolated (PZR level stable or rising, VCT level dropping at a lower rate due to letdown isolated and still charging through the seals, urgency to restore letdown, etc).

Licensee:

1)

Modified standard to include shutting HC-142 charging flow control valve.

2)

Dont N/A steps in AOPs, can do in any order.

3)

Made not critical.

4)

Leak location and system check valves.

5)

Added step g to JPM.

NRC:

1)

JPM sat as revised.

B Respond to a loss of component cooling water S

Y 2

E NRC:

1)

Trigger for leak rate increase is tied to the B RMUW pump - can applicant start the A pump or is it not aligned for a start?

2)

Why does the JPM stop after the Rx tripped, but the RCPs are not? Shouldnt the trip choreography be Trip the reactor, verify tripped, and secure RCPs? Is there a time requirement in which to secure RCPs with CCW?

Licensee:

1)

RMUW pumps are aligned such that they should start the B pump.

2)

No TCOAs or Bases info with a time restriction as long as you still have charging flow to thermal barrier. Also JPM F is securing an RCP post trip, which would be the same actions with loss of CCW.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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 NRC:

1)

JPM sat as revised.

C Respond to dropped rod S

Y 2

E NRC:

1)

If the applicant has to trip the Rx prior to the RCS low Tave alarm, that should be reflected in the task standard.

2)

JPM title appears misleading. The JPM is a response to dropped rods, not necessarily uncontrolled rod motion.

Licensee:

1)

Updated the task standard.

2)

Changed title to Dropped Rod vs uncontrolled rod motion.

NRC:

1)

JPM sat as revised.

D Transfer an instrument bus S

N 2

S NRC:

1)

Task standard for performance step 8 should ensure the applicant marks 5.1.14 a-f N/A.

Licensee:

1)

Updated as requested.

NRC:

1)

JPM sat as revised.

E Restore PT-431 to service S

N 3

E NRC:

1)

Since section 5.1 (and Attachment A) was performed to remove PT-431 from service, this should be marked up (working procedure in progress).

2)

Performance steps should reference Attachment A.

3)

Applicant is going to start at step 5.2.1 and will need to obtain SM permission and conduct a PJB. Steps 5.2.1-5.2.3 are not reflected in the performance standards (performance standard starts at step 1 in Att A).

Licensee:

1)

Updated as requested.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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)

Updated as requested.

3)

Updated as requested.

NRC:

1)

JPM sat as revised.

F Respond to an RCP malfunction S

Y 2

S G

Adjust containment sump pH S

N 3

S NRC:

1)

Evaluator note in performance step 6 uses the wording critical task. This should be changed to The portion of this critical step is to.

Critical tasks are used in scenarios, not in JPMs.

Licensee:

1)

Updated as requested.

H Limit RCS Depressurization S

Y 2

S Free Look NRC:

1)

Validation time will likely be around 5 minutes.

Will validate during OV week.

Licensee:

1)

Validated at 5 min I

Operate TSC ventilation system P

N 3

E NRC:

1)

Step numbers referenced in performance step 2 and beyond appear incorrect. Ex:

performance step 6 should reference step 2.1.3 and not 2.3.4 (step does not exist in Att B).

2)

Need to validate how control panel matches Figure 3 in Att B, since examiner may be providing the cue.

Licensee:

1)

Updated to reflect correct procedure steps.

2)

Updated JPM after validation week and walking down panels.

NRC:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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)

During OV week, determined that step 2 to place auto/unocc/occupied switch from auto to occupied was NOT critical. Change made.

JPM is sat as revised.

J Locally shut MSIVs P

N Y?

3 E

NRC:

1)

Performance step 1 has the applicant check solenoid power, resulting in an evaluator cue, however, initiating cues state that solenoid power has been verified to be on. Therefore, cant they start at step C.2 of the procedure?

2)

Cannot locate IA-636 from pictures - is this inside the cabinet?

3)

JPM appears to be alt-path, starting at performance step 2, when the MSIV local pushbuttons are depressed and the MSIV stays open. (this would make 6 alt-path, within the bounds of 4-6).

Licensee:

1)

Updated as requested.

2)

IA valve on outside of cabinet.

3)

Not making alternate path.

NRC:

1)

JPM sat as revised.

K Start an air compressor to a depressurized receiver P

Y 3

E NRC:

1)

What is the consequence if the applicant opened IA-218&219 prior to removing the caps? Would the system pressure cause the caps to become projectiles upon removal? I.e.

is the order important, as the step is 1 step that says uncap and open.

2)

Requesting the start on the compressor is critical, otherwise the receiver cannot be repressurized.

3)

Need to modify task standard. The compressor started and aligned to the receiver is partially true, but the goal is to repressurize the receiver.

Licensee:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Exam Date: 03/04/2023 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)

System depressurized so no revision required.

2)

Made step critical.

3)

Updated as requested.

NRC:

1)

JPM sat as revised.

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.

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 (JPMs)

Facility: Point Beach Scenario: 1 Exam Date: 03/04/2024 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

Shift control room recirculation fans E

NRC:

1)

Add which fans are being swapped (W-13B2 to W13B1) to planned evolutions on shift turnover information.

2)

Conflicting info on which fans to swap.

BOP/ATC bullet says from W-13B1 to W-13B2, while step 5.2.3 says if shifting from W-13B2 to W13B1. Appears the bullet at the top of the page is incorrect.

Licensee:

1)

Corrected sim guide.

2)

Corrected sim guide.

NRC:

1)

Event is sat as revised.

2 1TE-402B Tcold (white) fails high S

3 A Steam generator tube leak E

NRC:

1)

ATC should receive MC credit for manually controlling PZR level to obtain leak rate. Update scenario outline.

2)

What alarms may come in if the applicants dont identify the leak rate?

PZR level deviation? Rad monitor alarms? Reference initial alarms at the top of page 13.

3)

Need details in AOP-3 steps 10-11 (what valves are being manipulated?). If the BOP is expected to close 1MS-2083 (A SG sample isolation valve), this need to be in the guide so we know theyre operating the correct valve.

4)

Recommend adding time delay in receiving rad monitor alarms (in the NOTES section) to Event 2 as an evaluator note, so we can put this failure

Form 2.3-3 Operating Test Review Worksheet (JPMs) in during Event 2 (likely during a brief), so the crew isnt sitting there for 3 minutes waiting.

Licensee:

1)

Updated

2)

Updated sim guide.

3)

Updated sim guide.

4)

Updated sim guide.

NRC:

1)

Event is sat as revised.

4 Rapid power reduction X

E NRC:

1)

Within AOP-17A details, include ramp rate details (3%/min down to 50%) and boration details (total? Batch size?

Batch rate?).

2)

Action response based on SG leakage from AOP-3 in Event 3 states < 50%

power in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, however, Event 4 on page 15 states < 60% power. Appears 60% is a typo.

Licensee:

1)

Updated sim guide, will depend on crew.

2)

Updated sim guide.

NRC:

1)

Event is sat as revised.

5 A SGTL gets worse, Reactor trip and SGTR X

E NRC:

1)

If the applicant is expected to manually open 1AF-4074A/B as part of E-0 step 6 RNO (manually align valves as necessary), then this should be detailed.

2)

Need details on steps (E-0 steps 8-12, at a minimum), even if applicants arent manipulating components. Ex, E-0 step 8 check RCS temperatures - applicants will be pursuing the RNO for 8.b.

3)

Need details on steps E-0 Att A. Ex:

Verify FW isolation - how does the examiner know the applicant is checking the correct valves?

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Updated sim guide.

NRC:

1)

Event is sat as revised.

6 X

E NRC:

Form 2.3-3 Operating Test Review Worksheet (JPMs) 1AF-4074A/B, 1P-53 MDAFW pump to S/G fails to auto open

1)

Need more detail beyond Performs EOP-0 Step 6 Verify AFW. This is not sufficient guidance to determine whether or not the applicant mitigated the transient, much less satisfied the CT.

Licensee:

1)

Updated sim guide.

NRC:

1)

Event is sat as revised.

7 SGTR response with spray valve failure X

E NRC:

1)

Need more details in steps. Ex: Dump steam at max rate - how? E-3 Step 6.c details. More details needed in steps 7-14, 20, 21.

2)

Need to validate time for SG overfill for CT-20. Achievable within reasonable scenario timing?

Licensee:

1)

Updated sim guide.

2)

Validated NRC:

1)

Event is sat as revised.

General NRC:

1)

Many scenario events need some enhancement to scenario guide step details - examiner needs to validate that what the applicant is diagnosing and manipulating are correct, in accordance with the procedure.

Licensee:

1)

Updated sim guide.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: Point Beach Scenario: 2 (Free Look)

Exam Date: 03/04/2024 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

Fill Unit 1 PRT approx. 2% per OP-4C S

NRC:

1)

Need a space between OPEN & 1RC-508 in step 5.5.4 and between Shut &

1RC-508 in step 5.5.8.

2)

Is the expectation to secure the RWM pump that was previously started?

3)

Outline shows N for ATC & BOP. What is the BOP doing to get normal credit?

Licensee:

1)

Corrected.

2)

Yes

3)

Both positions take the required actions.

NRC:

1)

Event is sat as revised.

2 1P-11A CCW Pump trip and 1P-11B fails to auto start X

E NRC:

1)

Need to add AOP step substeps. Ex:

Step 4a-d. Step 4.c has 6 valves to verify closed.

2)

Typo in step 4.c vales - should be valves Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

NRC:

1)

Event is sat as revised.

3 1P-53 MDAFW Pump control power failure E

NRC:

1)

Scenario outline had BOP receiving C credit for this event - BOP takes no verifiable actions to receive credit. Credit not reflected in updated Form 3.4-1.

Ensure BOP credit removed from updated scenario outline Form 3.3-1.

2)

Typo in loss in step 3.1.1

Form 2.3-3 Operating Test Review Worksheet (JPMs)

3)

Which relay is the applicant supposed to determine is affected using the ARP? Is it a C01 relay (1-74/B03FM) or 1-74/A83FM/CLOSE? This should be included in the guide. Appears to be the 1-74/A83FM/CLOSE based on the booth comms.

Licensee:

1)

Updated outline, malfunction counts did not take this into account.

2)

Updated sim guide.

3)

Updated sim guide.

NRC:

1)

Event is sat as revised.

4 Lowering condenser vacuum / rapid power reduction X

E NRC:

1)

Are there any expected ARB actions prior to implementing AOP-5A & 17A? No ARBs listed.

2)

Need to add AOP step substeps for both AOP-5A & AOP-17A (substeps only listed for steps 4 & 5).

3)

Add to AOP-5A that the applicant is directing local performance of Att A.

4)

Actions under AOP-5A foldout page appear to be misnumbered. Step 8 & 9 is Step 2 in the AOP. Step 10 in the guide is Step 16 in the AOP.

5)

AOP-17A is missing step 2

6)

Why cant the crew place the hogging vacuum pump online? What guidance places this in service (does not appear to be in AOP-5A)? Why does AOP-5A not allow for the use of the hogging vac pump?

7)

Based on the comment that it takes about 10 minutes to receive a vacuum related PPCS alarm upon inserting the malfunction, recommend adding this note to event 3, to input Event 4 during Event

3.

Licensee:

1)

None

2)

Updated sim guide.

3)

Updated sim guide.

4)

Updated sim guide.

5)

Skip this step per usage and scenario parameters.

6)

Not used unless vacuum much worse.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

7)

Updated sim guide.

NRC:

1)

Event is sat as revised.

5 1HC-110 Boric Acid flow controller fails in auto during downpower E

NRC:

1)

Is the crew expected to batch at a set flowrate (ex: 3 batches of 100 gallons at 40 gpm) or establish a continuous boration at a lower flowrate (ex: 1 batch of 300 gallons at 10 gpm)?

2)

ARB 1C04 1C 2-8 not included in references. Used older rev 10 for validation.

3)

We will want to see the crew continue with the downpower after controlling boration flow manually. We dont want them to simply stop the boration and stop the downpower (while allowed by procedure, we need to see them continue to restore condenser vacuum). They may pause the downpower, but theyll have to continue it (SM cue to continue?)

Licensee:

1)

Depends on crew but typically continuous

2)

Validated up to date rev of ARB during validation

3)

Updated sim guide.

NRC:

1)

Event is sat as revised.

6 Loss of vacuum requiring Rx trip /

Trip malfunction X

E NRC:

1)

List operating limits for condenser vacuum from AOP-5A.

2)

Reference CT-2 in this section.

3)

Is CT-2 bounding criteria before boration per step 4 or before losing the ability to borate due to high RCS pressure and having to open a PORV (i.e. cause a LOCA)?

4)

Need to consistently include EOP substeps. Ex, EOP-0 step 4 should include what parameters & values the applicant is checking to determine SI is not required (PZR pressure, MSL pressure, cnmt pressure)

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Validated

Form 2.3-3 Operating Test Review Worksheet (JPMs)

4)

Updated sim guide.

NRC:

1)

Event is sat as revised.

7 Multiple (4) stuck rods post trip, requires boration X

E NRC:

1)

Need to consistently include EOP substeps. Ex, EOP-0.1 steps 2 & 3 include substeps, but step 1 only includes 1.a and not 1.b.

2)

What is the expected BAST level change per TLB-5? The applicant should determine this in RNO step 3.e, so we will need to ask this if its not done. Guide should include this.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

NRC:

1)

Event is sat as revised.

8 1P-29 TDAFW pump overspeed X

E NRC:

1)

The pump trips on O/S, but the operator is required to trip all running AFW pumps in EOP-0.1 step 2.b.5. When will this failure be inserted?

2)

Need to consistently include CSP substeps (ex. Step 2 for what constitutes bleed & feed criteria, which is necessary to determine CT-43 completion).

Substeps need more detail.

3)

The TDAFW pump O/S condition send the applicant from step 3.a RNO to Att A while proceeding with step 4. No mention of Att A in the guide - O/S device is broken, so Att A will not matter, but they may direct the operator to reset it per the Attachment.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Updated sim guide.

NRC:

1)

Event is sat as revised.

General NRC:

1)

Many scenario events need some enhancement to scenario guide step details - examiner needs to validate that what the applicant is diagnosing and

Form 2.3-3 Operating Test Review Worksheet (JPMs) manipulating are correct, in accordance with the procedure.

Licensee:

1)

Updated sim guide.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Scenario: 3 Exam Date: 03/04/2024 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

1PT-485 turbine first stage pressure fails low High RCS Activity X

U S

NRC:

1)

Need more detail in steps. Ex, AOP-6C step 2 - maintain RCS Tavg - maintain how (540< x < 577 & within 7 deg of Terror)?

2)

Scenario guide references 0-SOP-IC-001 to remove PT-485 from service, however, similar steps (to align steam dumps to steam pressure mode) come from ARP 1C03 1E2 4-2. If we expect the applicant to use 0-SOP-IC-001 WHITE Att A to remove PT-485 from service, the guide should reflect that (step 7-9 to trip bistables).

3)

Overlap with scenario 1 event 2. Actions are the same for ATC & BOP. Need to swap the event.

Licensee:

1)

Updated sim guide.

2)

Applicants will more than likely take the ARB actions.

3)

Changed out event 1 for High RCS Activity NRC:

1)

Event replaced due to overlap. High RCS activity is now EVENT 3. High RCS Activity event is SAT. Event 2 (single up feed trains) is now Event 1.

2 Single up feed trains and down power using normal procedures X

E NRC:

1)

It appears the ATC and BOP are being credited with both N and R for this event.

While there are two pieces to this event and both are valid, it is not apparent what the ATC is doing to receive N credit during singling up feed trains.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

2)

Include steps for borating via OP-5B.

Specify Att D (if a normal boration is correct) and include steps.

3)

For ease of event crediting (see comment 1), recommend splitting out single up feed train as event 2 and the down power as event 3, rather than 2A & 2B. This will make it clearer on the transient event checklist and on the Form 3.3-1 to show that normal & reactivity credit is not being given for a single event, which is not allowed. Update Form 3.3-1 to reflect this.

Licensee:

1)

Split events up into a Normal where BOP gets credit and the Downpower to its own event.

2)

Updated sim guide.

3)

Updated 3.3-1 for Scenario 3 NRC:

1)

Due to event 1 overlap, this event is now event 1. Downpower is now Event 4.

Event is sat as revised.

3 1CV-200A Letdown orifice outlet CV closes causing loss of letdown flow X

E NRC:

1)

AOP-1D step 54 has 5 substeps but only a-d are listed - step c to ensure 1HC-130 opened is combined under step b.

2)

Steps need more detail; Ex, AOP-1D step 54 - open letdown line containment isolation valves - include 1CV-371 and 1CV-371A.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

NRC:

1)

Due to event 1 overlap, this event is now Event 2. Event is sat as revised.

4 1X-03 transformer lockout X

X U

S NRC:

1)

Per the outline, the BOP is being given C credit for this event, but the BOP actions simply state Address ARPs and validate plant operated as expected.

Either the BOP credit is insufficient or the performance standard in the scenario guide is insufficient.

2)

Are the applicants expected to place the gas turbine in operation (C02 D 1-8 step

Form 2.3-3 Operating Test Review Worksheet (JPMs) 4.4)? Not addressed in scenario guide.

LCO 3.8.1 required action A.2 is to place it in operation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Licensee:

1)

Made TS call only for SRO

2)

Updated sim guide to reflect not starting the Gas Turbine.

NRC:

1)

Event is sat as revised. This event is now Event 5 due to event 1 change.

5 Steam leak from A SG in cnmt req Rx trip & B SG safety fails open post trip, depressurization of both SGs and subsequent reseating of B SG Safety X

E NRC:

1)

Procedure steps in the guide need more detail - Ex: EOP-0 Att A needs to detail steps, such as Verify ECCS flow.

Recommend moving Att A response to between EOP-0 and EOP-2 steps OR at the end of the scenario guide.

2)

With a 3 minute window to hit the 2# in containment, shouldnt the applicants enter AOP-2A for a secondary leak? The crew should take the action to trip prior to the 2# in containment from AOP-2A step 1 RNO, correct? If so, this should be reflected in the guide.

3)

We expect an SI - do we expect the crew to manually actuate the SI on lowering MSL pressure and lowering PZR pressure or will they get an auto SI quickly due to the leak? Guide specifies tripping the Rx but does not specify actuating SI.

4)

BOP/ATC diagnosis actions state the crew will diagnose the failed automatic reactor trip. Based on the scenario outline comments, the crew is supposed to trip the Rx prior to 2# in containment.

5)

Scenario guide does not discuss the crew shutting MSIVs. Will the MSIVs close on low MSL pressure or will the crew close them due to the leak? EOP-2 step 1 checks any MSIVs open and the expected response is NO, but the guide does not discuss the MSIVs being closed prior to this point.

6)

ECA-2.1 step 2 - reducing FW flow to <

275 gpm will cause a red path and entry into H.1, however, due to the note at the beginning of the procedure, H.1 should not be performed. This should be

Form 2.3-3 Operating Test Review Worksheet (JPMs) referenced in the scenario guide, as the applicants must recognize the H.1 red path applicability. Currently, this guidance exists under Event 8, for some reason.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Depending on timing they might manual SI, procedurally would wait until in EOP-0 Step 4.

4)

Updated sim guide.

5)

Depends on timing of pressures and temperatures, crew will probably shut the MSIVs.

6)

Depends on timing and when the crew gets to steps.

NRC:

1)

Event is sat as revised. This event is now Event 6 due to event 1 change.

6 Turbine fails to trip automatically S

NRC:

1)

Event is sat as revised. This event is now Event 7 due to event 1 change.

7 Cnmt accident cooling unit 1W-1A1 fails to auto start S

NRC:

1)

Event is sat as revised. This event is now Event 8 due to event 1 change.

8 B SG safety valve reseat S

NRC:

1)

Need to ensure no applicant credit given for this event, since no updated scenario outline was provided with the scenario.

2)

With Event 8 having no actions, this can be combined under the Event 5 heading.

3)

H.1 details under Event 8 should be moved to Event 5 - see comment 6 under event 5.

Licensee:

1)

Updated sim guide and Form 3.3-1.

2)

Updated sim guide.

3)

Updated sim guide.

NRC:

1)

Event is sat as revised. Event incorporated into major event 5 (now event 6) as this is a continuation of the major event.

General X

NRC:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

1)

Many scenario events need some enhancement to scenario guide step details - examiner needs to validate that what the applicant is diagnosing and manipulating are correct, in accordance with the procedure.

2)

Need to validate the bounding criteria for an orange path on integrity - possible within the bounds of the scenario?

Should be without automatic turbine trip, but need to validate it during OV week.

3)

Need to ensure applicants that see scenario 1 do not see scenario 3 due to overlap on event 1 OR swap one of these events.

Licensee:

1)

Updated sim guide.

2)

Validated

3)

Swapped event 1 out

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: Point Beach Scenario: 4 Exam Date: 03/04/2024 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

Stroke open test 1SI-852A low head SI core deluge E

NRC:

1)

It appears that, based on the turnover information and the first step in Event 1 being step 5.6.5 of IT 03, that the crew is starting IT 03 with a procedure in progress. If so, the turnover information should reflect that - IT 03 is in progress at step 5.6.5 with 1P-10A RHR pump in PULLOUT.

2)

Include Att C acceptance criteria for the valve strokes in the guide.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

NRC:

1)

Event is sat as revised.

2 1NI-41 power range NI fails low X

U S

NRC:

1)

While this is the spare, its recommended to swap this event due to the ATC event credit being response to automatic rod motion. This is overlapping with Scenario 1 Event 2 and Scenario 3 Event 1. If the spare were to be run for the ATC missing beans, we would not be able to credit this event.

2)

Scenario guide does not address any actions from 1C04 1A 1-7, 3-3, or 4-5.

Are there any actions required that are not covered by AOP-6C, AOP-24, or 0-SOP-IC-001 RED?

Licensee:

1)

Swapped event 1 in SEG 3

2)

Not intended to remove instrument from service. Updated sim guide to reflect procedures being completed.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

NRC:

1)

Event is sat as submitted. Scenario 3 modified due to overlap.

3 RCS bypass loop approx. 15 gpm leak then increase until PZR level cannot be maintained X

E NRC:

1)

Events 3 and 4 are swapped in the event summary at the front of the scenario guide. It appears that the summary at the front has the events swapped.

2)

Scenario summary has the event title state then increase until PZR level cannot be maintained, however, that does not appear in the body of the scenario guide.

3)

AOP-1A actions in scenario guide need more detail.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Updated sim guide.

NRC:

1)

Event is sat as revised.

4 1W-3A control rod shroud fan trips E

NRC:

1)

See comments in Event 3 for Event 3 & 4 placement.

2)

Add requiring rapid power reduction to the event title.

3)

ARP 1C04 1C 2-9 not included in documents. Since the fan tripped on O/C, can the applicant take the fan to pullout?

4)

Format for Event 4 does not match the rest of the events - no symptoms and indications, BOP/ATC, SRO, or Crew headings.

Licensee:

1)

Updated sim guide.

2)

Updated sim guide.

3)

Not required but possible.

4)

Updated sim guide.

NRC:

1)

Event is sat as revised.

5 SBLOCA X

E NRC:

1)

EOP-0 actions are listed under AOP-1A.

Need an EOP-0 heading (similar to AOP-1A and EOP-1).

Licensee:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

1)

Updated sim guide.

NRC:

1)

Event is sat as revised.

6 SI fails to auto actuate X

E NRC:

1)

Scenario summary on page 5 states the B SI pump fails to auto start, however, the scenario guide states that the applicant must manually start the A SI pump due to the auto start failure.

Discrepancy needs correcting. Scenario summary also states a failure of the Train A SI sequencer causes some Train A ECCS equipment not to actuate. What equipment does not actuate?

2)

Is there a preferred bounding criteria we can consider in lieu of the alternate bounding criteria of transitioning out of EOP-0?

Licensee:

1)

Updated sim guide.

2)

Cleaned up validation week. Failure to actuate SI prior to exiting EOP-0 would result in a change to the overall mitigative strategy.

NRC:

1)

Event is sat as revised.

7 RCS Hot leg CIVs fail open X

E NRC:

1)

Scenario guide needs more detail within many steps, particularly EOP-A Att A.

2)

Is there a preferred bounding criteria we can consider in lieu of the alternate bounding criteria of transitioning out of EOP-1?

Licensee:

1)

Updated sim guide

2)

Addressed during validation NRC:

1)

Event is sat as revised.

General NRC:

1)

Many scenario events need some enhancement to scenario guide step details - examiner needs to validate that what the applicant is diagnosing and manipulating are correct, in accordance with the procedure.

Licensee:

Form 2.3-3 Operating Test Review Worksheet (JPMs)

1)

Updated sim guide.

Form 2.3-3 Operating Test Review Worksheet (JPMs)

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.