ML17079A523

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2016 LaSalle County Station Initial License Examination Operating Exam Review Comments
ML17079A523
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 11/16/2016
From:
NRC/RGN-III
To:
Exelon Generation Co
Shared Package
ML15274A408 List:
References
Download: ML17079A523 (12)


Text

LaSalle 2016 ILE Operating Exam Review Comments Simulator Scenario Comments

  • General Comments:

o Critical tasks in simulator scenarios must contain measurable performance indicators.

This includes having performance measures that are objective (NUREG-1021 Appendix D Section D.1.c). Specifically, this requires including (for each critical task) limits for when the opportunity for successful completion of the critical task no longer exists. For example, a critical task to perform action X should also include detail within the critical task summary specifying that action X must be completed prior to threshold Y. Update the critical task summaries of all scenarios to include this additional information (also references and other important details - acceptance criteria).

Comment incorporated by facility. Criteria included as appropriate.

o All scenarios except for scenario #5 list an approximate runtime of 90 minutes. This information is missing for Scenario #5.

Comment incorporated by facility. Runtime added.

  • Scenario 1:

o Scenario includes a change from the submitted outline to raise the starting power level of the initial condition to 7% from the original value of 4%. The facilitys justification for this change was to align the scenario with a later timeframe on the rod pull sequence in which higher worth rods would be operated in order to better support the ATC reactivity change.

NRC reviewer agreed with change as incorporated.

o Scenario includes a change from the submitted outline in Event 4. Specifically, a change has been made making the IRM failure an INOP failure instead of an UPSCALE failure.

NRC reviewer agreed with change as incorporated.

o On Events 1 and 2, remove the initiation cue of on direction of lead evaluator. The direction to carry out these activities is provided on the applicants turnover sheets.

Comment incorporated by facility.

o Event 3 has a simulator operator role play cue in quotations (implying that it is to be read verbatim) that is written in the second person. This report should be presented in the first person for realism and clarity (i.e. say I discovered instead of you discovered).

Comment incorporated by facility.

o Event 6 states in the floor instructor notes that an automatic turbine trip will occur if the standby EHC pump is not started by 1100 psig EHC pressure (about 2 minutes). Since this turbine trip has the potential to occur due to a delayed applicant response, it would be desirable to move this event to being immediately prior to Event 9 (the major transient). This will minimize the likelihood of an unplanned turbine trip during this event interfering with the applicants receiving credit for the subsequent actions of Events 7 and 8.

Accepted by NRC based upon minimal plant effects of turbine trip for existing plant conditions.

LaSalle 2016 ILE Operating Exam Review Comments o Event 6 states in the floor instructor notes that if an automatic trip of the turbine occurs, then a reactor scram will result. Based upon the initial conditions of the scenario and the preceding reactivity manipulation is expected that power should be approximately 9% at the time of this event. Since power should be significantly less than the turbine valve closure scram setpoint (25 %?), why would an automatic reactor scram be expected in this instance? Correct the simulator guide if this is an error.

Comment incorporated by facility.

o Events 3 and 7 terminus should include OR at the direction of lead evaluator.

Accepted as is.

o Event 8 does not contain verifiable action (as defined in NUREG-1021 ES-301 Attachment 2). Specifically, the criteria for verifiable action is that the applicant must actually operate equipment controls and control the system response. Furthermore, it states that when the applicant is on the phone directing an operator to take some action in the field while the applicant is observing control room indications is NOT performing a verifiable action, this is directing. In Event 8 the applicant will be unable to control the CRD FCV manually to restore parameters and will need to direct local manual operation by an operator in the field. This does not satisfy the criteria for verifiable action. This event also has a step for the operator to throttle the CRD PCV.

Based upon the CRD flowpath being affected by the closed FCV, it appears that this throttling will be ineffectual and therefore it will not constitute a verifiable action either.

Based upon these considerations, Event 8 does not in its current form present a basis for being counted as a component failure for the ATC applicant.

Comment incorporated by facility. Event modified appropriately.

  • Scenario 2:

o Scenario included a change from the submitted outline in Event 6. Specifically, a change has been made making the B VR Exhaust Fan trip a Supply Fan trip instead.

NRC reviewer agreed with change as incorporated.

o Are ALL Critical Tasks required to be done, or just a subset of the 3 CTs? (AND or OR)

Clarified by licensee during validation.

o On Event 1, remove the initiation cue of on direction of lead evaluator. The direction to carry out this activity is provided on the applicants turnover sheets.

Comment incorporated by facility.

o Event 4 requires a power reduction and constitutes the reactivity event for the ATC.

The expected operator response provides no detail on the expected actions of the ATC to accomplish this power reduction operation however (i.e. lower Recirc flow, insert rods, etc.). Add details of expected ATC actions during the reactivity manipulation.

Comment incorporated by facility.

o Event 6 has a TS 3.3.6.1 entry (signify T (SRO) on Form ES-D-1?).

Clarified during validation.

o Events 2 and 5 terminus should include OR at the direction of lead evaluator.

Accepted as is for Event 2. Comment incorporated by facility for Event 5.

LaSalle 2016 ILE Operating Exam Review Comments o Event 7 is listed as giving component failure credit to the ATC applicant. This event does not meet the requirements of NUREG-1021 to be credited to the ATC applicant in this manner. Event 7 is a complete loss of RBCCW that follows a loss of a RBCCW pump earlier in the scenario. Per the scenario guide the diagnosis of the complete loss of RBBCW is expected to be performed by the applicant in the BOP role. The applicant in the ATC role is only expected to scram the reactor as directed by the Unit Supervisor.

Additionally, since Event 7 results in a scram, it is considered a major transient by NUREG-1021 Appendix D Section C.2.e which states A major transient is one that has a significant effect on plant safety and leads to an automatic (or manual, if initiated by an operator) protective system actuation, such as a reactor trip or an engineered safety system actuation. This event does not count for ATC component failure credit since NUREG-1021 ES-301 Section D.5.d states With the exception of the SRO TS evaluations, each event should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation and, similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.

Comment incorporated by facility. Event no longer credited for ATC.

o Event 8 has an ATC component failure occurring after the major transient (electric ATWS with failure of ARI). NUREG-1021 ES-301 C.5.d states An applicant should only be given credit for those events that require the applicant to perform verifiable actions (refer to Attachment 2) that provide insight to the applicants competence. The required instrument and component failures are normally complete before starting the major transient; those that are initiated after the major transient should be carefully reviewed because they may require little applicant action and provide little insight regarding their performance. For some plant types it may be necessary to have instrument and/or component failures after the major transient. This may be acceptable IF they can be properly evaluated. With the exception of the SRO TS evaluations, each event should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation and, similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.

Event evaluated as adequate during validation.

Form D-1 contains lists this event as Event 8 versus Event 9. Form ES-301-5 lists this as Event 9.

  • Scenario 3:

o Form ES-D-1 includes no TS evaluations. Typically, we have 2 TS opportunities per scenario for evaluation fairness and to avoid the need to utilize the spare scenario.

(NOTE: Scenarios 4 and 6 have only 1 TS evaluation, so this comment also applies in those scenarios also).

Evaluation during validation resulted in TS event being added as part of Event 4.

o On Event 1, remove the initiation cue of on direction of lead evaluator. The direction to carry out this activity is provided on the applicants turnover sheets.

Accepted as is.

LaSalle 2016 ILE Operating Exam Review Comments o Event 4 requires a power reduction and constitutes the reactivity event for the ATC.

The expected operator response provides no detail on the expected actions of the ATC to accomplish this power reduction operation however (i.e. lower Recirc flow, insert rods, etc.). Add details of expected ATC actions during the reactivity manipulation.

Comment incorporated by facility.

o Event 6 has a typo in the section for Unit Supervisor actions (Direst vs. Direct).

Correction not incorporated by facility.

o Event 6 indicates that the crew will be inserting a manual scram due to the criteria associated with the suppression pool leak. Event 5 says that the crew will be scramming based upon the criteria associated with condenser backpressure however. This needs to be corrected/clarified in both events guides.

Comment incorporated by facility.

o Event 7 has an initiation cue of on direction of lead evaluator. This event (an ATWS) will be initiated by the crew attempting to scram as a result the prior event however.

Comment incorporated by facility.

o Event 7 has an ATC component failure occurring after the major transient (post-scram five control rods stuck out). NUREG-1021 ES-301 C.5.d states An applicant should only be given credit for those events that require the applicant to perform verifiable actions (refer to Attachment 2) that provide insight to the applicants competence. The required instrument and component failures are normally complete before starting the major transient; those that are initiated after the major transient should be carefully reviewed because they may require little applicant action and provide little insight regarding their performance. For some plant types it may be necessary to have instrument and/or component failures after the major transient. This is acceptable provided they can be properly evaluated. With the exception of the SRO TS evaluations, each event should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation and, similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.

Evaluated to be adequate during validation.

o Event 8 has an initiation cue of on direction of lead evaluator. This event (RPV Blowdown) will be initiated by the crew based upon procedure direction however.

Comment incorporated by facility.

  • Scenario 4:

o Scenarios 4 and 6 have only 1 TS evaluation. 2 is typical.

Accepted as is.

o On Event 1, remove the initiation cue of on direction of lead evaluator. The direction to carry out this activity is provided on the applicants turnover sheets.

Accepted as is.

o Event 2 requires a power reduction and constitutes the reactivity event for the ATC.

The expected operator response provides insufficient detail on the expected actions of the ATC to accomplish this power reduction operation however (expected operator

LaSalle 2016 ILE Operating Exam Review Comments response detail is limited to reduce reactor power using reactor recirculation flow or control rods). Add details of expected ATC actions during the reactivity manipulation.

Accepted as is.

o Event 2 simulator operator actions direct the malfunction to be ramped to 0 over a period of two minutes once the crew lowers reactor power. How is this to be coordinated with the lead evaluator to ensure that an appropriate power change has been observed?

Comment incorporated by facility.

o Event 5 is the TS Evaluation opportunity, not Event 6 as per Form ES-D-1.

Comment incorporated by facility.

o Terminus should include OR at the direction of lead evaluator.

Accepted as is.

o Event 9 has a BOP component failure occurring after the major transient (HPCS failure to auto-start). NUREG-1021 ES-301 C.5.d states An applicant should only be given credit for those events that require the applicant to perform verifiable actions (refer to Attachment 2) that provide insight to the applicants competence. The required instrument and component failures are normally complete before starting the major transient; those that are initiated after the major transient should be carefully reviewed because they may require little applicant action and provide little insight regarding their performance. For some plant types it may be necessary to have instrument and/or component failures after the major transient. This is acceptable provided they can be properly evaluated. With the exception of the SRO TS evaluations, each event should only be counted once per applicant; for example, a power change can be counted as a normal evolution or as a reactivity manipulation and, similarly, a component failure that immediately results in a major transient counts as one or the other, but not both.

Additionally, it seems probable that the ATC applicant could potentially perform this actions resulting in an inadequate number of I/C malfunctions for an applicant.

Evaluated during validation and found to be inadequate as an event for BOP credit. Comment incorporated by facility. No longer credited as a BOP event.

Form 301-5s verified to contain adequate events for applicants effected by change.

  • Scenario 5:

o Approximate runtime duration for scenario is not included.

Comment incorporated by facility.

o On Events 1 and 2, remove the initiation cue of on direction of lead evaluator. The directions to carry out these activities are provided on the applicants turnover sheets.

Accepted as is.

o Event 4 terminus should include OR at the direction of lead evaluator.

Comment incorporated by facility.

o Event 5 (primary containment pressure controller fails) has a note in the section for BOP actions stating that venting of containment will not be allowed. The floor instructor notes have guidance to tell the crew that Unit 2 will handle venting if the crew pursues

LaSalle 2016 ILE Operating Exam Review Comments this route however. The simulator guide should clarify the feedback to be given to the applicants since not allowed and will be performed by Unit 2 have different meanings.

Comment incorporated by facility.

o On Event 6, the simulator operator role play instructions for reporting the oil leak do not provide any detail as to the general location of the oil leak (i.e. in the vicinity of the 1A TDRFP). This direction should be clarified to reduce the chances of the incorrect equipment being secured by the crew due to unclear communications with the simulated field operator.

Comment incorporated by facility.

o Event 8 has an initiation cue of on direction of lead evaluator. This event (an ATWS) will be initiated by the crew attempting to scram as a result the prior event however.

Comment incorporated by facility.

  • Scenario 6:

o Scenarios 4 and 6 have only 1 TS evaluation. 2 is typical.

Accepted as is.

o The summary of events contains a typographical error. Item #8 says The crew ill manually scram the Reactor.

Comment incorporated by facility.

o On Event 1, remove the initiation cue of on direction of lead evaluator. The direction to carry out this activity is provided on the applicants turnover sheets.

Accepted as is.

o On Event 4 (A RR Pump loss of cooling water flow), include in the section for ATC actions the expected action for the applicant to trip the A RR Pump when the second R-point is reached.

Comment incorporated by facility.

o Event 4 is listed as being a reactivity manipulation for the ATC applicant. In this event the ATC trips a running Recirc pump in response to a loss of cooling water. NUREG 1021 ES-301 Section D.5.d states Any normal evolution, component failure, or abnormal event (other than a reactor trip or other automatic power reduction) that requires the operator to perform a controlled power or reactivity change will qualify as a reactivity manipulation. This includes events such as an emergency borating, a dropped rod recovery, a significant rod bank realignment, or a manual reactor power reduction in response to a secondary system upset. Tripping a recirculation pump does not reduce power in a controlled manner, and therefore the actions of Event 4 does not count for ATC reactivity manipulation credit (although it may count as a component malfunction for the ATC however). In Event 5 (single loop operation) one of the expected ATC applicant actions is to insert control rods to reduce Rod Line to <65.7%. Based upon this, Event 5 may potentially count for ATC applicant reactivity manipulation credit provided that the resultant power change is large enough for evaluation purposes.

Comment incorporated by facility. Events renumbered and re-categorized accordingly.

  • Scenario 7:

LaSalle 2016 ILE Operating Exam Review Comments o On Event 1, remove the initiation cue of on direction of lead evaluator. The direction to carry out this activity is provided on the applicants turnover sheets.

Accepted as is.

o Event 6 terminus should include OR at the direction of lead evaluator.

Comment incorporated by facility.

o Event 7 terminus should include OR at the direction of lead evaluator.

Comment incorporated by facility.

o Event 7 (loss of 135X-2-B-4) is listed as being a component malfunction event for the BOP applicant. The BOP applicants action is limited to dispatching an operator and entering LOP-CX-03 however, which does not meet the requirements of NUREG-1021 for verifiable action. NUREG-1021 ES-301 C.5.d states An applicant should only be given credit for those events that require the applicant to perform verifiable actions (refer to Attachment 2) that provide insight to the applicants competence. NUREG-1021 ES-301 Attachment 2 in turn states that when the applicant is on the phone directing an operator to take some action in the field while the applicant is observing control room indications is NOT performing a verifiable action, this is directing. Based upon these considerations, Event 7 cannot be counted towards component malfunction credit for the BOP applicant.

Evaluated during validation and found to be inadequate as an event for BOP credit. Comment incorporated by facility. No longer credited as a BOP event.

Form 301-5s verified to contain adequate events for applicants effected by change.

o Event 7 has an empty bullet with no information listed in the section for ATC actions.

Comment incorporated by facility.

o Event 7 required the SRO to enter TS 3.8.1; this is the same as the SRO technical specification determination that is made by the SRO applicant in Scenario 2 Event 2.

(Overlap concern?) Additionally, a required action is to perform SR 3.8.1.1; Scenario 2 Event 2 contains a floor instructor note providing guidance in the event that the crew attempts to perform this SR, however Scenario 7 Event 7 contains no such guidance.

Technical specification call accepted as is. Facility incorporated change to floor instructor note.

JPM Comments

  • General Comments:

o All in-plant JPMs should be formatted so as to be generic to either unit. Currently JPM I appears to be specific to Unit 1.

Comment incorporated by facility.

o JPM performance steps do not always include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o It is VERY advantageous to have Admin JPMs that do not require use of the simulator!

LaSalle 2016 ILE Operating Exam Review Comments Facility modified administrative JPMs where appropriate to minimize the degree of coordination that will be needed with control room/simulator JPMs.

  • JPM a (S-FP-01):

o No comments.

  • JPM b (S-RM-02):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o JPM performance steps 3, 4, 7, and 8 are not listed as critical steps. NUREG-1021 Appendix C Section B.3 states Every procedural step that the examinee must perform correctly (i.e., accurately, in the proper sequence, and at the proper time) to accomplish the task standard shall be identified as a critical step and shall have an associated performance standard. Since these steps involve physical actions that must be performed correctly in order to accomplish the task standard, they should be listed as critical steps. Conversely, step 9 is listed as a critical step; since in this step the applicant is only verifying an indication, this step should not be listed as a critical step.

Comment incorporated by facility.

  • JPM c (S-RH-28):

o The initial conditions of the JPM say that LOP-RH-13 is complete up to step 1.3 and there is a cue in the JPM to hand the examinee a marked up copy of this procedure. The applicant handout copy of the procedure is not marked up accordingly however.

Clarified during validation.

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o JPM performance step 3 (starting the A RHR pump) is not listed as a critical step.

NUREG-1021 Appendix C Section B.3 states Every procedural step that the examinee must perform correctly (i.e., accurately, in the proper sequence, and at the proper time) to accomplish the task standard shall be identified as a critical step and shall have an associated performance standard. Since this step involves a physical action that must be performed correctly in order to accomplish the task standard (RHR pump flow is a necessary part of establishing suppression pool cooling), it should be listed as a critical step.

Comment incorporated by facility.

o A note says that the alternate path begins while 1E12-F048A is being closed. This is done in step E.1.5.1 of LOP-RH-13. However, there is no corresponding step in the JPM performance standard for this action by the applicant.

Comment incorporated by facility.

  • JPM d (S-NR-12):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

LaSalle 2016 ILE Operating Exam Review Comments Accepted as is.

o The simulator setup instruction specify to provide a copy of LOP-RM-01 pages 1-22 and 31-32 complete through step E.1 (consistent with the initial conditions provided for the task). However, the applicant handout copy of LOP-RM-01 contains pages 1-16 and 28-

30. Step E.1 is not included among this and the main body of the procedure is omitted until step E.4 on page 28.

Comment incorporated by facility.

o Performance step 3 of the task standard contains a typographical error (examinee place vs. examinee places).

Comment incorporated by facility.

o Performance step 4 of the task standard is missing wording (Examinee CRD drive flow trip circuit test switch is in the normal position).

Comment incorporated by facility.

o JPM performance step 12 (select uncoupled control rod) is not listed as a critical step.

NUREG-1021 Appendix C Section B.3 states Every procedural step that the examinee must perform correctly (i.e., accurately, in the proper sequence, and at the proper time) to accomplish the task standard shall be identified as a critical step and shall have an associated performance standard. Since this step involves a physical action that must be performed correctly in order to accomplish the task standard it should be listed as a critical step (this step may still be marked N/A per the note if previously completed).

Comment incorporated by facility.

  • JPM e (S-VG-01):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o This JPM is only for RO applicants. It will also need to be performed in the simulator concurrently with another JPM due to scheduling constraints. Since this JPM will involve SBGT system operation, the other JPM needs to be one that will not interfere with this JPM. (When the draft schedule was made G was RO only - IMPACT?)

Clarified during validation.

  • JPM f (S-DG-12a):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

  • JPM g (S-RI-14):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o The simulator setup instruction specify to provide a copy of LOS-RI-Q3 marked up to step 5 of attachment 1A (consistent with the initial conditions provided for the task).

However, the applicant handout copy of this procedure is not marked up accordingly.

LaSalle 2016 ILE Operating Exam Review Comments Clarified during validation.

  • JPM h (S-HP-06):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o The simulator setup instruction specify to prepare a copy of LOS-HP-Q1 Attachment A; the attachment used for the JPM is Attachment 1A.

Comment incorporated by facility.

o The simulator setup instruction specify to prepare a copy of LOS-HP-Q1 Attachment A marked up to and including step 8 (consistent with the initial conditions provided for the task). However, the applicant handout copy of this procedure is not marked up accordingly.

Clarified during validation.

  • JPM i (P-VP-04):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o All in-plant JPMs should be capable of performance on either unit. This is necessary because applicant class size will necessitate each in-plant JPM being administered simultaneously on both units by separate examiners in order to complete the JPM for the entire class in a single workday. JPM I setup instructions indicate that this JPM is specific to Unit 1. The JPM performance standard should be modified accordingly to accommodate this and the applicant handout for LGA-VP-01 should include both Attachments 1A and 2A. It appears that the only point of potential overlap might be examinees performing the JPM on separate units going to the same equipment locker to simulate obtaining their equipment bags, however the facility should verify this.

Comment incorporated by facility.

  • JPM j (P-CY-02):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

  • JPM k (P-NB-01):

o The JPM summary page lists an estimated time of completion of 00 minutes.

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o The performance standard has what appears to be a placeholder for a note located prior to performance step 10. Add something here or DELETE it!

Comment incorporated by facility.

  • RO 2.1.a (A-RO-06):

LaSalle 2016 ILE Operating Exam Review Comments o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o This admin JPM requires usage of the simulator to obtain data. It will need to be coordinated around other simulator activities. Since we are providing the OD-20 after the applicant performs the correct Demand actions, is it possible to perform these actions on a PPC simulator or else isolate the PPC so that other simulator actions are possible at the same time?

Evaluated during validation. Not feasible to perform JPM outside of simulator.

o IF LOS-AA-S101 is located, provide a copy to the applicant to document analysis.

Accepted as is.

  • RO 2.1.b (A-RO-43):

o This admin JPM requires usage of the simulator to obtain data. It will need to be coordinated around other simulator activities. Alternatively, would it be possible to utilize handouts of pictures of indications in order to eliminate the need to perform this admin JPM in the simulator?

Comment incorporated by facility. JPM modified to allow classroom performance.

  • RO 2.2 (A-RO-29):

o This admin JPM requires usage of the simulator to obtain data. It will need to be coordinated around other simulator activities. Alternatively, would it be possible to utilize handouts of pictures of indications in order to eliminate the need to perform this admin JPM in the simulator? 25 minutes long! (If 2X time needed - could be a problem)

Comment incorporated by facility. JPM modified to allow classroom performance.

  • RO 2.3 (A-RO-44):

o No comments.

  • SRO 2.1.a (A-SRO-19):

o JPM performance step 2 requires the applicant to reference the ODCM. The appropriate section of the ODCM has not been included in the handout materials for the applicant however. Is it intended that the applicant will be provided a copy of the entire ODCM? (They should, versus being handed the correct section ONLY)

Clarified during validation. Entire reference to be made available.

o Why is the JPM Summary SRO Only box checked NO? It needs to be YES.

Comment incorporated by facility.

  • SRO 2.1.b (A-SRO-13):

o JPM performance steps 3-5 require the applicant to reference Technical Specifications.

The appropriate sections of the Technical Specifications have not been included in the handout materials for the applicant however. Is it intended that the applicant will be provided entire copies of Technical Specifications and bases? (They should, versus being handed the correct section ONLY)

LaSalle 2016 ILE Operating Exam Review Comments Clarified during validation. Entire reference to be made available.

o It is requested that an evaluator note be added to the performance standard explaining the information contained in the COLR Section 10 Modes of Operation, specifically how Note 1 supports the evaluation of JPM performance step 2.

Accepted as is.

  • SRO 2.2 (A-SRO-61):

o JPM performance steps do not include the corresponding procedural step numbers associated with the applicants task.

Accepted as is.

o This admin JPM requires usage of the simulator for computer usage. It will need to be coordinated around other simulator activities, unless a computer that is not located on the simulator floor can be made available to accomplish the task in a manner that maintains exam security.

Comment incorporated by facility. JPM modified to allow classroom performance.

o The completed checklist referenced in the note prior to performance step 8 is missing from the student handout materials.

Clarified during validation.

  • SRO 2.3 (A-SRO-53):

o For the initiating cue, direct the applicant to Identify the Required Actions, if any, Update the Tech Spec Timeclock Sheet, if needed, and Complete the necessary notifications, if required.

Comment partially incorporated and clarified by facility during validation.

o A blank timeclock sheet has not been included in the student handout materials.

Comment incorporated by facility.

o During the onsite validation it is desired to discuss with the facility the difference in applicability between Conditions C and D in more detail.

Clarified during validation.

  • SRO 2.4 (A-SRO-54):

o Add the following statement to the initiating cue handout sheet for the applicant: THIS JPM IS TIME CRITICAL.

Comment incorporated by facility.

o The student handout materials contain the EAL matrix information for HG1 instead of the FG1 declaration that is applicable to this JPM. Is this intended to allow for answering the hostile action-related question in the PAR flowchart?

Clarified during validation. Entire reference to be provided.

o It appears that the applicant may also need a copy of the EAL criteria for RG1 in order to evaluate the information associated with performance step 5.

Clarified during validation. Entire reference to be provided.