ML20329A141
| ML20329A141 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/17/2020 |
| From: | Operations Branch I |
| To: | Exelon Generation Co |
| Shared Package | |
| ML19309E375 | List: |
| References | |
| CAC 000500 | |
| Download: ML20329A141 (21) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Exam Date: October 5 - 29, 2020 1
2 3
Attributes 4
Job Content 5
6 Admin JPMs ADMIN Topic and K/A LOD (1-5)
U/E/S Explanation I/C Cues Critical Scope Overlap Perf.
Key Minutia Job Link Focus Steps (N/B)
Std.
SRO-A1.a Conduct of Operations 2.1.25 Determine Time to Boil for a Loss of Shutdown Cooling 2
X E
S NRC:
Sub steps contained in JPM Steps 1 and 2 that identify the correct Tables within Attachment E for Time to Boil determinations should be flagged with an asterisk for designation as Critical Steps. Revise the Critical Step Justifications on Page 3 of the JPM accordingly.
Confirm that Time to Boil determinations are performed by the SROs, and not the ROs, at Ginna.
GINNA:
Designated second sub step of JPM Steps 1 and 2 as Critical Steps and annotated with an asterisk. Critical Step Justifications on page 3 of JPM updated accordingly.
OU-AA-103, Step 4.10.1.3 states The Shutdown Safety Manager (or designee) shall COMMUNICATE the Unit status in a highly visible manner to each shift during outage execution, including: PROVIDE Control Room personnel with information such as Time to Boil and Key Safety Function Status for use in Operator shift briefings and/or postings in the Control Room. IP-OUT-2, step 4.2.A states that the Shutdown Safety Coordinator Position shall be filled by SRO assigned on shift with no other collateral duties.
SRO-A1.b Conduct of Operations 2.1.18 Determine Reportability Requirements 3
X E
S NRC:
Performance Standard for the Notifications Section of NRC Form 361, Reactor Plant Event Notification Worksheet, states that a checkmark or X will be placed in the NO and/or WILL BE box associated with each of the 5 notification types. It appears that checking only the NO box would be an incorrect response, given
ES-301 Operating Test Review Worksheet Form ES-301-7 that the specified Notifications are required to be made. Checking only the NO box means that the Notification(s) will not be made.
Enhance the Performance Standard and Form 361 Answer Key to address this item.
GINNA:
Changed the KEY to accept WILL BE or NO for the final four notification check blocks (non-critical).
Changed the KEY to accept WILL BE for the Site Resident notification check block (critical).
Revised the Performance Standard for the applicable JPM Steps.
SRO-A2 Equipment Control 2.2.42 A-52.12, Inoperability of a Fire Damper 3
E S
NRC:
Include an Examiner Note that JPM Step 5 for Line 1 column item Log OOS (Y/N) on Form A-52.12-F-03, is being addressed under A-52.12, Step 6.7.4. Intent is to avoid any potential confusion, given that JPM Steps 5 & 6 both reference procedure Step 6.7.4, which reads:
NOTIFY the Fire and Safety Watch (FASW) of the Equipment OR System deemed nonfunctional.
The Examiner Note pertaining to Step 9 of the JPM, and associated Note with double asterisk at the bottom of Form A-52.12-F-03, should both include TR 3.7.5 Action A.1.1 since it has a 1-hour Completion Time.
Editorial: Performance Standard Elements for JPM Steps 2-11 reference procedure A-5.52.12.
Appears that the reference should actually be A-52.12.
GINNA:
Included an Examiner Note that JPM Step 5 for Line 1 column item Log OOS (Y/N) on Form A-52.12-F-03, is being addressed under A-52.12, Step 6.7,4.
Step 9 Examiner Note and Form A-52.12-F-03 Note with double asterisk revised to include TR 3.7.5, Action A.1.1.
Procedure reference in JPM Steps
ES-301 Operating Test Review Worksheet Form ES-301-7 corrected to A-52.12.
SRO-A3 Radiation Control 2.3.6 Review and Approve Gas Decay Tank Release Permit 3
X E
S NRC:
The Initiating Cue, as written, is leading. Do not need to tell the applicant to identify all entries that must be changed to permit approval. Suggest revising the Initiating Cue to read as follows:
As Shift Manager, review the release permit for approval authorization and document the results on the cue sheet.
Remove the Table from the cue sheet, along with the accompanying before and after statements.
GINNA:
Revised Initiating Cue to As Shift Manager, review the release permit for approval authorization and document the results on the cue sheet.
Removed Table and accompanying before and after statements from Cue Sheet. Removed the separate Answer Key and all references to the Answer Key in the JPM.
SRO-A4 Emergency Procedures/Plan 2.4.38 Determine if Emergency Dose Limits and Thyroid Blocking Agents (Potassium Iodide [KI]) Should be Approved for Use.
2 X
E S
NRC:
Sub step contained in JPM Step 1 that calculates how much exposure the rescuers will receive in excess of 5 REM should be flagged with an asterisk for designation as a Critical Step.
Editorial: Performance Standard for JPM Step 3, Second asterisk, incorrectly specifies procedure EP-AA-113-F-02; should be EP-AA-113-F-03.
GINNA:
JPM Step 1 sub step annotated as a Critical Step.
Performance Standard for JPM Step 3, Second asterisk, revised to procedure EP-AA-113-F-03.
ES-301 Operating Test Review Worksheet Form ES-301-7 RO-A1.a Conduct of Operations 2.1.5 Determine the Allowable Hours an Operator Can Work 3
X E
S NRC:
For JPM Step 1, enhance the performance standard to show how the 6-Week Average comes out to 51.83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> if the 16-hour period is worked, ensuring compliance with the 54-Hour Rule.
JPM appeared on the 2018 Exam and was randomly selected for use on the 2020 Exam. Explain the significance of adding the following item to the stem for the 2020 Exam:
Your work schedule reveals that over the next five weeks you are scheduled to work an average of 52 hours6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> per week.
GINNA:
JPM Step 1 Performance Standard enhanced to show 6-Week average.
This additional Initial Condition was added to allow the Applicant to perform the 6-week rolling average for the current week plus the following five weeks to verify Work Hour Rules will not be violated in the future RO-A1.b Conduct of Operations 2.1.25 Complete Plant System Checks Inside Control Room (Verify SDM) 3 S
RO-A2 Equipment Control 2.2.41 Determine Leak Isolation Boundaries 3
E S
NRC:
Examiner Cue prior to Step 1 of the JPM gives direction to provide the Applicant with Handout 1. The Handouts field on Page 3 of the JPM does not specify any Handouts.
GINNA:
Added the P&ID Drawings as Handout #1 to be provided to the Applicant initially. The remaining General References will be available when asked for.
This JPM will be administered individually.
ES-301 Operating Test Review Worksheet Form ES-301-7 RO-A3 Radiation Control 2.3.5 Evaluate Steam Generator Tube Leakage from R-47 Reading 3
X E
S NRC:
Sub steps contained in JPM Step 1 that require the applicant to determine the R-47 HIGH and WARNING alarm setpoints should be flagged with an asterisk for designation as Critical Steps.
Examiner Cue prior to Step 1 of the JPM gives direction to provide the Applicant Handout 1, which is a blank copy of AP-SG.1, Steam Generator Tube Leak. The applicant will also need to reference P-9 and Curve #06-004 which will be available for use during the JPM. Why is AP-SG.1 being given to the applicant at the onset of the JPM?
GINNA:
JPM Step 1 sub steps annotated as a Critical Step (asterisk).
AP-SG.1 is initially provided to the Applicant since this is the procedure that the crew is evaluating for entry.
P-9 and Curve #06-004 will be available for the Applicant when asked for.
This JPM will be administered individually.
ES-301 Operating Test Review Worksheet Form ES-301-7 match the font size 11 used throughout the JPM.
IP-J 3
E04 EA2.2 3
S IP-K 4S 061 K4.13 2
S
ES-301 8
Form ES-301-7 Instructions for Completing This Table:
Check or mark any item(s) requiring a comment and explain the issue in the space provided using the guide below.
- 1.
Check each JPM for appropriate administrative topic requirements (COO, EC, Rad, and EP) or safety function requirements and corresponding K/A. Mark in column 1.
(ES-301, D.3 and D.4)
- 2.
Determine the level of difficulty (LOD) using an established 1-5 rating scale. Levels 1 and 5 represent an inappropriate (low or high) discriminatory level for the license that is being tested. Mark in column 2 (Appendix D, C.1.f)
- 3.
In column 3, Attributes, check the appropriate box when an attribute is not met:
The initial conditions and/or initiating cue is clear to ensure the operator understands the task and how to begin. (Appendix C, B.4)
The JPM contains appropriate cues that clearly indicate when they should be provided to the examinee. Cues are objective and not leading. (Appendix C, D.1)
All critical steps (elements) are properly identified.
The scope of the task is not too narrow (N) or too broad (B).
Excessive overlap does not occur with other parts of the operating test or written examination. (ES-301, D.1.a, and ES-301, D.2.a)
The task performance standard clearly describes the expected outcome (i.e., end state). Each performance step identifies a standard for successful completion of the step.
A valid marked up key was provided (e.g., graph interpretation, initialed steps for handouts).
- 4.
For column 4, Job Content, check the appropriate box if the job content flaw does not meet the following elements:
Topics are linked to the job content (e.g., not a disguised task, task required in real job).
The JPM has meaningful performance requirements that will provide a legitimate basis for evaluating the applicant's understanding and ability to safely operate the plant. (ES-301, D.2.c)
- 5.
Based on the reviewers judgment, is the JPM as written (U)nacceptable (requiring repair or replacement), in need of (E)nhancement, or (S)atisfactory? Mark the answer in column 5.
- 6.
In column 6, provide a brief description of any (U)nacceptable or (E)nhancement rating from column 5.
Save initial review comments and detail subsequent comment resolution so that each exam-bound JPM is marked by a (S)atisfactory resolution on this form.
ES-301 10 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 2 Exam Date: October 5 - 29, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1 - A Charging Pump Trip E
NRC:
Editorial: On Page 9 of the ES-D-2, under the Indications Available section, the description for alarm AR-B-10 is incorrect. Should be RCP 1B LABYR SEAL LO DIFF PRESS instead of RCP 1A.
GINNA:
Corrected AR-B-10 description to be RCP 1B LABYR SEAL LO DIFF PRESS.
2 - Fuel Failure /
High RCS Activity TS S
3 - Generator Hydrogen Temperature (Cold Gas)
Instrument Failure S
4 - B RFP Oil Leak CT1 S
5 - Control Rods Fail to Move in AUTO /
Stuck Rod TS E
S Reactivity Manipulation NRC:
TS Required Actions scripted for LCO 3.1.4, Condition B, on Page 41 of the ES-D-2 do not accurately reflect what is currently in the TSs. Required Actions B.4, B.5, and B.6 are incorrect. Specifically:
o There is no B.6.
o B.6 should be B.5.
o B.4 only lists 1 of 3 Surveillance Requirements.
GINNA:
Corrected ES-D-2 for script of Technical Specification LCO 3.1.4 to match Technical Specifications.
6 - Condensate Header Break / Loss of Bus 14 / A MFW Pump Trip /
TDAFW Pump Trip on Overspeed X
E S
Major Event (TDAFW Pump Trip on Overspeed used on 2018 NRC Exam; Scenario 4, Event 7)
GINNA:
During validation week, the NRC requested that the complete loss of AFW be delayed until after the crew has performed substantive actions in ES-0.1.
Consequently, the malfunction for loss of Bus 14 will be inserted after the crew completes ES-0.1, Step 1 RNO AND S/G narrow range level is 12%. Revised ES-D-1 and ES-D-2 to insert the loss of Bus 14 eliminating the only available source (A MDAFW Pump) until after Step 1 of ES-0.1. with S/G narrow range level 12%.
ES-301 12 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 3 Exam Date: October 5 - 29, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1 - Load Ascension /
MRPI System Failure TS S
Reactivity Manipulation 2 - Main Generator Voltage Regulator Fails High S
3 -Letdown Temperature Control Valve (TCV-130)
Controller Failure S
4 - Leak in the NRHX to CCW System S
5 - Loss of Offsite Circuit 767 / Restore 4160 Bus 12B TS X
E S
2019 NRC Retake Exam; Scenario 1, Event 3 (Loss of Bus 12B only).
NRC:
Agree with LCO 3.8.1, Condition C. However, questioning the applicability of Condition A, Required Action A.1, Declare required feature(s) inoperable when its redundant required Feature(s) is inoperable. What is the redundant required feature that is inoperable on associated safeguards Buses 14/18? Provide an explanation on the TS Page of the ES-D-2 explaining the applicability of LCO 3.8.1, Condition A, Required Action A.1.
GINNA:
In accordance with Technical Specification LCO 3.8.1 Basis (page 3.8.1-5) One qualified independent offsite power circuit connected between the offsite transmission network and the onsite 480V safeguards buses and separate and independent DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Therefore, while offsite power is NOT connected to Buses 16 and 17, LCO 3.8.1, Condition A applies. Required Action A.1, though not currently necessary for plant conditions, must be entered due to a potential future event.
Revised ES-D-2 to include this explanation on page 43.
6 - B EDG Trips
/ Loss of 7T Circuit CT3 S
Major Event
ES-301 16 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Scenario: 5 Exam Date: October 5 - 29, 2020 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scenario Overlap U/E/S Explanation 1 - Load Ascension /
Bus 18 UV Relay Failure TS S
Reactivity Manipulation 2 - VCT Divert Control Valve (LVC-112A)
Failure X
S 2018 NRC Exam; Scenario 3, Event 1.
3 - PR N42 Upper Detector Failure TS S
NRC:
Comment: TR 3.2.3, Axial Flux Difference (AFD) Monitor, Condition A, Action A.1, requires performance of TSR 3.2.3.2 every 15 minutes. Applicants will be expected to demonstrate/ensure compliance with this TR action during the course of the scenario, given the short 15-minute Completion Time.
GINNA:
Understand that the Applicants will be required to comply with the 15-minute action.
Added an Examiners NOTE on page 20.
4 - Hotwell Level Controller Fails to Full Makeup X
S 2018 NRC Exam; Scenario 4, Event 4.
5 - Circ Water Pump A Trips
/ Loss of Vacuum E
S NRC:
Comment on Page 27 associated with Step 2 RNO for AP-CW.1, Loss of A Circ Water Pump, states that Rapid Load Reduction guidance per AP-TURB.5 is provided on Page 28. Guidance is provided on Page 29.
Comment on Page 29 associated with AP-TURB.5, Step 1, states that rods cannot be inserted in AUTO due to a previous malfunction. Is this accurate? What is the previous malfunction that precludes automatic rods insertion?
GINNA:
Corrected Comment on page 27 to reference page 29 for AP-TURB.5.
The rods are in MANUAL due to the load ascension. If not, rods would have been placed in MANUAL due to the Power Range Channel failure. The NOTE is not helpful and has been removed.
6 - Inadvertent Steam Line Isolation Signal S
Major Event 7 - Failure of Rx to Trip From Control CT1 S
ES-301 18 Form ES-301-7 Instructions for Completing This Table:
Use this table for each scenario for evaluation.
2 Check this box if the events are not related (e.g., seismic event followed by a pipe rupture) OR if the events do not obey the laws of physics and thermodynamics.
3, 4 In columns 3 and 4, check the box if there is no verifiable or required action, as applicable. Examples of required actions are as follows: (ES-301, D.5f) opening, closing, and throttling valves starting and stopping equipment raising and lowering level, flow, and pressure making decisions and giving directions acknowledging or verifying key alarms and automatic actions (Uncomplicated events that require no operator action beyond this should not be included on the operating test unless they are necessary to set the stage for subsequent events. (Appendix D, B.3))
5 Check this box if the level of difficulty is not appropriate.
6 Check this box if the event has a TS.
7 Check this box if the event has a critical task (CT). If the same CT covers more than one event, check the event where the CT started only.
8 Check this box if the event overlaps with another event on any of the last two NRC examinations. (Appendix D, C.1.f) 9 Based on the reviewers judgment, is the event as written (U)nacceptable (requiring repair or replacement), in need of (E)nhancement, or (S)atisfactory? Mark the answer in column 9.
10 Record any explanations of the events here.
In the shaded boxes, sum the number of check marks in each column.
In column 1, sum the number of events.
In columns 2-4, record the total number of check marks for each column.
In column 5, based on the reviewer's judgement, place a checkmark only if the scenario's LOD is not appropriate.
In column 6, TS are required to be 2 for each scenario. (ES-301, D.5.d)
In column 7, preidentified CTs should be 2 for each scenario. (Appendix D; ES-301, D.5.d; ES-301-4)
In column 8, record the number of events not used on the two previous NRC initial licensing exams. A scenario is considered unsatisfactory if there is < 2 new events. (ES-301, D.5.b; Appendix D, C.1.f)
In column 9, record whether the scenario as written (U)nacceptable, in need of (E)nhancement, or (S)atisfactory from column 11 of the simulator scenario table.
ES-301 19 Form ES-301-7 Facility: GINNA NUCLEAR POWER PLANT Exam Date: October 5 - 29, 2020 Scenario 1
2 3
4 5
6 7
8 11 Event Totals Events Unsat.
TS Total TS Unsat.
% Unsat.
Scenario Elements U/E/S Explanation 1
9 0
2 1
3 0
7.14%
E S
RHR Pump A was inoperable at the start of the scenario (Turnover Sheet item).
Accordingly, entry into LCO 3.5.2, Condition A, had already been made. Event requires the crew to enter Condition B of the same LCO. Unable to evaluate the applicant in accordance with NUREG-1021, ES-303, under TS Competency Rating Factors 6(a) and 6(b), given that the LCO was previously entered. The event only requires the applicant to demonstrate competence in Rating Factor 6(c) by identifying and complying with the correct Condition and Action Statement.
2 8
0 2
0 3
0 0%
E S
3 8
0 2
0 3
0 0%
E S
4 SPARE SCENARIO - INFORMATION REDACTED 5
8 0
2 0
2 0
0%
E S
Instructions for Completing This Table:
Check or mark any item(s) requiring comment and explain the issue in the space provided.
1, 3, 5 For each simulator scenario, enter the total number of events (column 1), TS entries/actions (column 3), and CTs (column 5).
This number should match the respective scenario from the event-based scenario tables (the sum from columns 1, 6, and 7, respectively).
2, 4, 6 For each simulator scenario, evaluate each event, TS, and CT as (S)atisfactory, (E)nhance, or (U)nsatisfactory based on the following criteria:
- a.
Events. Each event is described on a Form ES-D-2, including all switch manipulations, pertinent alarms, and verifiable actions. Event actions are balanced between at-the-controls and balance-of-plant applicants during the scenario. All event-related attributes on Form ES-301-4 are met. Enter the total number of unsatisfactory events in column 2.
- b.
TS. A scenario includes at least two TS entries/actions across at least two different events. TS entries and actions are detailed on Form ES-D-2. Enter the total number of unsatisfactory TS entries/actions in column 4. (ES-301, D.5d)
- c.
CT. Check that a scenario includes at least two preidentified CTs. This criterion is a target quantitative attribute, not an absolute minimum requirement. Check that each CT is explicitly bounded on Form ES-D-2 with measurable performance standards (see Appendix D). Enter the total number of unsatisfactory CTs in column 6.
7 In column 7, calculate the percentage of unsatisfactory scenario elements: 2 + 4 + 6 1 + 3 + 5100%
If the value in column 7 is > 20%, mark the scenario as (U)nsatisfactory in column 8. If column 7 is 20%, annotate with (E)nhancement or (S)atisfactory.
9 In column 11, explain each unsatisfactory event, TS, and CT. Editorial comments can also be added here.
Save initial review comments and detail subsequent comment resolution so that each exam-bound scenario is marked by a (S)atisfactory resolution on this form.