ML18080A008

2018-02-DRAFT Operating Test Comments

ML18080A008
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/07/2018
From:	Vincent Gaddy Operations Branch IV
To:	Entergy Operations
References
Download: ML18080A008 (7)

Text

ES-301 Operating Test Review Worksheet Form ES-301-7 1

2 5

6 I/C Focus Cues Critical Steps Scope (N/B)

Overlap Perf.

Std.

Key Minutia Job Link A1 2.1.19 2

E S

I think the error band of 660 - 690 gallons is too large. 30.86 gal/in is included in procedure 1103.004, so calculating using a band of 30 - 31.36 is too large. I think 675 - 681 gallons is adequate. This would also change the PMS display in step 5 of the JPM. Changed total makeup required to 677.6-679.8, and modified the task standard. All changes made, JPM SAT.

A2 2.1.20 2

S A3 2.2.13 2

U S

If DWD-15B is tagged open, then doesn't DWD-15A need to be tagged closed? What procedure governs whether single or double valve isolation is required, as I don't see it in EN-OP-102? There were differing opinions on whether DWD-15A should be tagged closed, so the JPM was replaced with a different pump, P-40B. All changes made, JPM SAT.

A4 2.3.7 1

2 U

S No discriminatory value of this JPM. Replace. Changed the JPM to include the calculational only portion of JPM A8. All changeds made, JPM SAT.

A5 2.1.25 2

S Ensure that entire COLR is included with the handout to the applicant, not just the rod insertion limit figures.

A6 2.1.18 3

X U

S There is a discrepancy between the key and the checklist. They key states that only the bolded information is required for full credit, and that is that a four-hour report is required. The checklist states that step 5, "Applicant references 10CFR50.72 and determines that (b)(2)(iv)(B) requires a Four-Hour report to the NRC Operations Center is required," is a critical step. The key should reference that (b)(2)(iv)(B) is also a critical step, since an SRO must tell the NRC what the reporting criteria is. This would be a better JPM if the applicant had to fill out an NRC 361 form. Changed the initial conditions of the JPM, and also added requirement to fill out the 361 form. Add some distractors that make the applicant think about some of the other time requirements. All changes made, JPM SAT.

A7 2.2.37 2

S A8 2.3.14 1

U S

I am going to call this JPM LOD 1. The SRO portion of this JPM is essentially, "should KI be authorized, yes or no?" If the answer is no, then there is no paperwork to fill out, and the applicant knows that he won't have a JPM that only includes answering something "no." Replaced with bank JPM for authorizing exposure. All changes made, JPM SAT.

A9 2.4.41 2

S See comment on written exam question #77. Oversampling of EALs. Prefer to eliminate question 77.

1 Simulator/In Plant JPMs Safety Function and K/A S1 1

2 E

S Step 8.4 standard remove "or Auto/Manual pushbutton depressed to select MANUAL." Step 8.5 positive cue add "SEQ backlight lamp is on." Step 8.9 positive cue change "Transfer Conform" to "TR CF." Step 8.12 standard change "selected" to "depressed." All changes made, JPM SAT.

S2 2

2 E

S Add alternate path lie to cover sheet. Add "prior to BWST level reaching 6 feet" to the end of the task standard. Step E. 1) add starting the aux lube oil pump to the standard, and add a line for the examiner to record BWST level.

All changes made, JPM SAT.

S3 3

2 E

S Step 1 performance checklist column, there is an unnecessary parenthesis.

Task standard is to secure P-34B, but step 1A (critical step) is to override and stop P-34B AND P-36C, so is securing P-36C critical? Please put an examiner note in step 4 noting what RCP and RB pressure are, so the examiner knows which channels should be tripped. What would be the impact if the applicant chose to trip any other ESAS channels, incorrectly assuming RB pressure was too high? Step 5 performance, add "then use K11 ACA to clear uexpected alarms." Step 5 standard add how the applicant will verify each component is in its proper position, and a comment about P-35B being included. All changes made, JPM SAT.

3 Attributes 4

Job Content ADMIN Topic and K/A LOD (1-5)

U/E/S Explanation Facility: ANO Unit 1 Exam Date: February 26, 2018

ES-301 2

Form ES-301-7 S4 4A 2

E S

Safety function on 301-2 form should be 4P (for primary) not 4A. The initiating cue is to stop the RCP per 1103.006, section 11. The copy of 1103.006 that was sent with the exam reference materials has Section 11 as "Operating RCP Oil Pumps for RCP Hand Rotation or Other Activities." Is there a more recent revision of 1103.006 than what was included (Rev. 44)?

Change validation time to 10 minutes. Add to the examiner note before step 11.9 that, "If asked, the pump is not accessible." All changes made, JPM SAT.

S5 5

2 E

S Step 8.2.3, the standard column shoud state using attachment B2, not simply attachment B. I disagree with the acceptable range of 67.0 to 69.0. kW. The applicant will be reading the graph on the intersection of two lines. According to the graph, that is just a hair under 68.0 kW. It is non conservative with recombiners to "round down," and if they interpret the graph to 69.0 kW they misread the graph. I think the acceptable range is 67.5 to 68.0 kW. Add an examiner cue prior to step 8.2.3 B that five minutes has elapsed. All changes made, JPM SAT.

S6 6

2 S

S7 7

2 E

S The copy of 1105.001 that was sent with the exam reference materials has Section 7 as "Channel Checks of NI and RPS." Is there a more recent revision of 1105.001 than what was included (Rev. 28), or should the applicant be using Section 8? Step 7.2 standard, add that shutdown bypass bistables are bright, and list the bistables that are dim. All changes made JPM S8 8

2 E

S The copy of 1203.052 that was sent with the exam reference materials does not have the same numbering sequence as the JPM shows. The JPM states that step 1.C.1 is not applicable, but step C in my reference material matches what is identified as step D in the JPM. Is there a more recent revision of 11203.052 than what was included (Rev. 00)? Change validation time to 15 minutes. Step I positive cue add that either CV-2216 and CV-1213 OR CV-2217 and CV-121 are red light on green light off. Remove stem M standard, and note that the step is not applicable. All changes made JPM SAT.

P1 4B 2

E S

Safety function on 301-2 form should be 4S (for secondary) not 4B. Step 1.3, can these valves be manually opened, and it is possible they will try and manually open them? How close is the discharge pressure gauge to the trip/throttle valve? i.e., can you see it while you are throttling? Step 1.3, take away opetion of control room opening valves. Applicants must find the valves and demonstrate opening. All changes made, JPM SAT.

P2 6

2 X

E S

Step 14.14 must be a critical step. Pages 9 and 11 of the JPM should be swapped. Pages 9 and 11 should be labeled as to which cabinet it is coming from so the examiner can show the correct close-up photo. How can you tell (from pages 10 and 12) that breakers D2116A and D211A are closed? The examiner note prior to step 14.4 states to show a picture of panels RS1 and RS2, instead just direct the applicant to call the control room and manipulate the breakers. The positive cues for step 14.6 should be for each individual substep. The positive cue for step 14.7 should be that the handwheel no longer moves in the CCW direction. The positive cue for step 14.8 should be something along the lines of continuous noise. Need to identify in step 14.5 standard that only breakers A-409 and A-403 are critical. Ensure that the pictures are printed on white paper. All changes made, JPM SAT.

P3 9

2 S

ES-301 3

Form ES-301-7 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)

Instructions for Completing This Table:

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.

 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. (ES301, D.2.c)

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. (ES301, D.1.a, and ES301, D.2.a)

ES-301 4

Form ES-301-7 1

3 4

5 6

7 8

9 1

S 2

S 3

E 4

S 5

E 6

S 7

E 8

S 9

E 10

S 1

3 4

5 6

7 8

9 1

S 2

S 3

S 4

S 5

S 6

E 7

S 8

E 9

S 10

S 1

3 4

5 6

7 8

9 1

E 2

E 3

E 4

U 5

S 6

E 7

S 8

S 9

S 10

S 11

S 2014 exam, scenario 4. Add Tech Spec 3.8.1 Condition B. (Unsat due to missing tech spec)

Move Power reduction steps to event 5, after step 9.

Facility: ANO Unit 1 Scenario: 2 Exam Date: February 26, 2018 2

10 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap U/E/S Explanation 2016 exam, scenario 4.

U/E/S Explanation Step 15.1.3 add that both pumps are secure. Step 15.1.5 is N/A Booth cue pg 10, no signs of electrolyte on the floor (eliminate leakage from the battery cell).

Header says TT-1043 fails high, should be TT-1048. Step 4 TT-1044 should be selected. Add in step 18 steps.

Examiner note on page 23 should reference valve CV-2827, not CV-2627.

Eliminate this event Verifiable actions 2

Event Required Actions Realism/Cred.

Exam Date: February 26, 2018 Facility: ANO Unit 1 Scenario: 1 TS LOD 10 Explanation CTs Scen.

Overlap U/E/S 2014 exam, scenario 4.

Move Attachment 3 from the back of the D-2 to the next page (after page 2). Change event termination criteria to move on after Attachment 3 is complete.

ATC took no action. Add (P-64B) to step 5.A (pg 14). Add (P-36B) to step 5.E and (P-64B) to step 5.F (pg 15)

Can't get credit for a reactivity change, since the unit load demand failure prevents that. Events 5 & 6 should really be one event.

2016 exam, scenario 4. Change examiner note on page 29 that examiner shall tell boothe AAC available after RCP seals are isolated.

2016 exam, scenario 2.

Facility: ANO Unit 1 Scenario: 3 Exam Date: February 26, 2018 2

10 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap

ES-301 5

Form ES-301-7 Instructions for Completing This Table:

1. Use this table for each scenario for evaluation.

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.

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.

8. Check this box if the event overlaps with another event on any of the last two NRC examinations. (Appendix D, C.1.f)

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 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. (ES301, D.5.d)

In column 7, preidentified CTs should be 2 for each scenario. (Appendix D; ES301, D.5.d; ES3014)

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) 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.

ES-301 6

Form ES-301-7 1

2 3

4 5

6 7

8 1

10 9

0 2

0 2

0 0

E S

2 10 9

0 2

0 2

0 0

E S

3 11 1

2 1

2 0

13 E

S 8 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.

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.

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.

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).

9 In column 9, explain each unsatisfactory event, TS, and CT. Editorial comments can also be added here.

Exam Date:

Facility:

Event Totals Scenario 10 Explanation 7 In column 7, calculate the percentage of unsatisfactory scenario elements:

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.

All changes made. Scenario SAT.

All changes made. Scenario SAT.

CT Total CT Unsat.

% Unsat.

Scenario Elements U/E/S All changes made. Scenario SAT.

Events Unsat.

TS Total TS Unsat.

2 4 6 1 3 5 100%

Admin. JPMs 9

4 1

4 Sim./InPlant JPMs 11 0

8 2

Scenarios 3

0 3

0 Op. Test Totals:

23 4

12 6

17%

Site name: ANO Unit 1 Exam Date: February 26, 2018 OPERATING TEST TOTALS Total Total Unsat.

% Unsat.

Explanation Total Edits Total Sat.

Refer to ES501, E.3.a, to rate the overall operating test as follows:

satisfactory, if the Op. Test Total % Unsat. is 20%

unsatisfactory, if Op. Test Total % Unsat. is > 20%

Instructions for Completing This Table:

Update data for this table from quality reviews and totals in the previous tables and then calculate the percentage of total items that are unsatisfactory and give an explanation in the space provided.

1. Enter the total number of items submitted for the operating test in the Total column. For example, if nine administrative JPMs were submitted, enter 9 in the Total items column for administrative JPMs. For scenarios, enter the total number of simulator scenarios.

2. Enter the total number of (U)nsatisfactory JPMs and scenarios from the two JPMs column 5 and simulator scenarios column 8 in the previous tables. Provide an explanation in the space provided.

TS entries/actions were determined to be incorrect in a scenario(s).

3. Enter totals for (E)nhancements needed and (S)atisfactory JPMs and scenarios from the previous tables.

This task is for tracking only.

4. Total each column and enter the amounts in the Op. Test Totals row.

CTs were incorrect in the scenarios (not including postscenario critical tasks defined in Appendix D)

The EOP strategy was incorrect in a scenario(s).

5. Calculate the percentage of the operating test that is (U)nsatisfactory (Op. Test Total Unsat.)/(Op. Test Total) and place this value in the bolded % Unsat. cell.

6. Update this table and the tables above with postexam changes if the asadministered operating test required content changes, including the following:

The JPM performance standards were incorrect.

The administrative JPM tasks/keys were incorrect.