ML19217A292
| ML19217A292 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/20/2019 |
| From: | Greg Werner Operations Branch IV |
| To: | Vistra Energy |
| References | |
| 50-445/19-06, 50-446/19-06 50-445/OL-19, 50-446/OL-19 | |
| Download: ML19217A292 (14) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility:
CPNPP Exam Date:
Week of June 10, 2019 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.
RA1 1
3.5 25 m E
S
- 1. Why have applicant transcribe answers to Cue Sheet? Make a key using the procedure and eliminate answer requirements on Cue Sheet. Fixedused procedure and cue sheet
- 2. Should BOL be added to Initial Conditions?
Yes, added
Shouldnt both procedures be referenced?
Yes, added
- 4. Task Standard - change Critical Steps to Values of items above Fixed RA2 1
< 2 5 m U
S
- 1.
Replaced with different bank admin JPM, updated the ES-301-1 for RO
- 2.
With ODA-315 as a handout, this task becomes too non-discriminatory as its essentially a direct lookup using examples in Section 6.2.1.
- 3.
Initiating Cue should also ask the why the operator is/is not maintaining an Active license so as to avoid guessing the correct answer.
- 4.
What is the value of ODA-315-1, Active License Status Form to the applicant? Do they need this as a Handout?
- 5.
Task Standard - dont need to reference Answer Key since the standard of active/inactive for each Operator is identified. (doesnt make Task Standard unsat).
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 RA3 2
3 25 m E
S
- 1.
Task Standard - change Critical Steps to Values of items above Fixed
- 2.
Confirm that Ops doesnt want notification to SM that NI-44 is Unsat to be Critical Step (its not directly identified in Task Standard and its not identified in JPM step).
However, procedure says THEN immediately notify the Shift Manager AND reference Section 5.2. Seems step 5.2.4 should be critical as it identifies an LCO action. Confirmed Ops does NOT want a SM notification to be critical
- 3.
Answer Key - would be more helpful to examiners if only the Critical Step values are in RED. All info that is given can be BLACK. Fixed
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 RA4 3
2 15 m X
X U
S
- 1.
Task Standard - change Critical Steps to Values of items above Fixed
- 2.
Dont agree with Note that says Round all answers to the 1st decimal place for dose calculations. For example, if calculated max stay time is 42.858, why would 42.8-43 (42.9 +/- 0.1) be acceptable? If you stayed 43 mins, you would exceed the limit. What does procedure(s) say? Dose related calculations are normally rounded DOWN so not to exceed any limits. (This affects all answer range values.) Fixed
- 3.
Change initiating Cue to calculating the maximum stay time. Changed Initiating cue to: In accordance with provided RWP, DETERMINE most limiting allowable Stay Time for Containment entry team based on ALARA and Heat Stress:
- 4.
Why not provide applicants with RWP and survey maps vs giving them dose rates in Initial Conditions? Would make JPM more discriminatory and more operationally valid.
Created RWP
- 5.
Is asking most limiting allowable time for Containment entry team based on ALARA and Heat Stress discriminatory? What knowledge is the question seeking to test?
This was removed and then added back again based on comments during validation week.
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 SA1 1
3 15 m U
S
- 1.
Initiating Cue - for #1, ask if operator can assume license duties today (or equivalent).
I anticipate applicants asking question about when is the question referring to. Fixed
- 2.
What makes this JPM SRO-only? Its similar to RA2, which was identified as RO level knowledge. Agree that RA2 was SRO-Only knowledge as well as this JPM because these are specific to the SRO job function at CPNPP. RA2 replaced with Non SRO-Only JPM.
- 3.
Task Standard - change one operator to Operator A. (Similar comment to RA2)
Fixed
- 4.
For Operator B, must complete physical by July 31st or would be in violation of 10CFR55.21 every 2 years requirement.
Fixed
- 5.
Initiating Cue should also ask the why the operator can / can not assume license duties so as to avoid guessing the correct answer. Fixed
- 6.
Task standard for RO C, 2nd part: should also include another operator in the control room is required since the operator has a no-solo license condition. Fixed SA2 1
3.5 20 m E
S
- 1.
Task Standard - change Critical Steps to Values of items above Fixed
- 2.
Why have applicant transcribe answers to Cue Sheet? Make a key using the procedure and eliminate answer requirements on Cue Sheet (Same as RA1)
This JPM is much easier to have examinees transcribe to Cue Sheet because only one calculation comes from SOP-104A. The other calculations are from the TDMs.
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 SA3 2
3 25 m U
S
- 1.
Task Standard doesnt include all answers highlighted in Answer Key (in Impaired Fire Protection System/Equipment section) Fixed
- 2.
JPM Step 7 doesnt match Answer Key -
step says Other and key says Instructions/Additional Info. Fixedupdated to state the applicant can fill in either block SA4 3
2 15 m E
S
- 1.
Answer Key for Volunteer 7 doesnt state Why or Why Not selected, only that he was most preferred. Task Standard says the why is required. Fixed
- 2.
Applicant simply reads through procedure and deselects Volunteers 1-6. Low LOD I agree it is low LOD, however I think it is at least LOD 2this JPM would be a function of the Shift Manager or the Emergency Coordinator in actual plant emergency and important for the applicants to know.
SA5 4
3 20 m S
1 Simulator/In-Plant Safety Function and K/A JPMs
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 S-1 1
15 m 3
S
- 1.
Should we have available a copy of the ALM if applicant asks for one? Yes, added ALM as procedure 3 and updated JPM (now on Rev. 2 of JPM)
- 2.
When does Rods Below RIL alarm come in?
Will/should applicant respond to that alarm prior to Step 7 of ABN-302? The Rod Insertion Limit recorder tracks Control Rod Bank position and continuously updates Rod Positions and RILs. We would normally mark the time this alarm occurred during performance of ABN and then handle the problem when the ABN addresses the step.
S-2 2
15 m 3.5 S
S-3 3
7 m 3
S Should applicant perform Initial Operator Actions of ABN-705 from memory (prior to performing ALM)? If yes, re-order JPM steps. No, ABN-705 is for an instrument failure only (instrument failure has not occurred in this case). Updated examiner note in JPM to reflect this. ABN-705 provided to operator only if requested (referenced in ALM) should not need or request ABN-705.
S-4 4S 10 m 3.5 E
S
- 1.
Initial Operator Action of ABN-502 (EDG 1-
- 01) to PTL from memory? [JPM Step 7] Yes
- 2.
JPM Step 11 - applicant performing E-0 immediate actions prior to stopping all RCPs is Critical Step (confirm with Ops Rep) Yes, confirmed with Ops Rep S-5 6
6 m 2
S Minimum LOD Approved during Val Week S-6 7
5 m 2.5 S
S-7 8
5 m
< 2 E
S Need Alt Path or additional Critical Steps to raise LOD to > 2. Approved during Val Week
ES-301 Operating Test Review Worksheet Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 S-8 9
5 m 3
E S
Task Standard - last sentence isolated containment ventilation by closing 1-HS-5548/5549 in accordance Fixed to state: After containment high radiation alarm annunciated, isolated containment ventilation by closing 1-HS-5548/5549 in accordance with ALM-0032A, Alarm Procedure or SOP-801A.
P-1 4P 12 m
< 2 E
S
- 1.
Need Alt Path or additional Critical Steps to raise LOD to > 2. Approved during Val Week
- 2.
Procedure files (EOP-2.0A/B, Faulted Steam Generator Isolation) not included in submittal. Added marked up EOP-2.0A/B to both the Unit 1 and 2 JPMs for examinee reference, however, the examinee must know how to perform this task from memory as the procedure does not provide guidance on how to perform the taskjust to do it (also the reason why I believe LOD 2).
P-2 5
15 m 2
S JPM replaced after Validation Week based on comments from Chief Examiner P-3 6
25 m 4.5 S
NOTE: All Modified JPMs require Bank JPM to be included with submittal.
ES-301 8
Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 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 9
Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility: CPNPP Scenario: 1 Exam Date: Week of June 10, 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
X S
3.3.1 Condition E 2
X S
3.8.9 Condition A 3
X S
3.3.1 Condition E, 3.3.2 Condition D, 3.3.2 Condition I 4
S 5
S 6 (M) 2 S
7 1
S 8
3 S
Other Comments - same for all scenarios
- 1. Where possible, CTs should be bounded by plant parameters or conditions that are specific to the scenario instead of being linked to procedure steps or transitions. Discussed where applicable during Val Week
- 2. Safety Significance descriptions are too vague. Updated based on CE comments after Val Week
- 3. For all TS - identify Function(s) in summary to aid in balancing TS opportunities between scenario sets. Fixed
- 4. All scenarios are heavy on events before major transient. Will review during validation to determine if events should be removed. Reviewed and updated after Val Week
- 5. Number CTs (CT-1, CT-2, CT-3) on Critical Task Determination pages.
Fixed
ES-301 10 Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility: CPNPP Scenario: 2 Exam Date: Week of June 10, 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
S 2
S 3
X S
3.6.6 Condition A 4
X S
3.7.8 Condition B 3.8.1 Condition B 5
X S
3.3.1 Condition E 3.3.2 Condition D and Condition L 6
S 7 (M) 1, 3 E
Split out spurious SI signal (M) and Auto SI failure (C - post trip) into separate events. Events are integrated, left alone based on Val Week 8
2 S
Other Comments:
- 1. Abnormal Events is 4, not 5 (in Attributes table) Changed Abnormal Events to 4 in the Attributes Table
ES-301 11 Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility: CPNPP Scenario: 3 Exam Date: Week of June 10, 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
S Normal evolution 2
S 3
X E
3.3.1 Condition T 4
X S
3.1.6 Condition A 5
X E
3.3.1 Condition M 6 (M) 1, 2 S
7 S
8 (M)
S Other Comments:
What are the 2 malfunctions after EOP entry? If one is Event 8, then only count one Major Transient or add malfunction after LBLOCA. (EDG starts but output breaker fails to Auto close due to low frequency). Changed Malfunctions after EOP Entry to 1 in the Attributes Table
ES-301 12 Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility: CPNPP Scenario: 4 Exam Date: Week of June 10, 2019 1
2 3
4 5
6 7
8 9
10 Event Realism/
Cred.
Required Actions Verifiable actions LOD TS CTs Scen.
Overlap U/E/S Explanation 1
S Normal evolution 2
S 3
X S
3.3.1 Condition M (TS only event) 4 S
3.5.2 Condition A 3.8.1 Condition C 5
S 6 (M)
U FWIV 3 failing closed meets definition of Major Transient (see below).
Changed Event 6 to Major 7 (M) 1, 2 S
Loss of All AFW Flow (FRH 0.1A, Response to Loss of Secondary Heat Sink) 8 S
Comments:
- 1. Split out 3 malfunctions after EOP entry into separate events. Moved MDAFWP Trip to Event 6. Split out Events 7 and 8.
- 2. What are 2 EOPs entered/requiring substantive actions? (Note that E-0 doesnt count.) Changed EOP entered/requiring substantive actions to 1
- 3. Event 6 is a Major Transient per Appendix D (C.2.e) Changed Event 6 to Major 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.
ES-301 13 Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Instructions for Completing This Table:
1 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 14 Form ES-301-7 Rev 1 NUREG 1021, Rev. 11 Facility: CPNPP Exam Date: Week of June 10, 2019 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
8 0
5 0
3 0
0 S
2 7
0 5
0 3
0 0
S 3
7 0
3 0
2 0
0 S
4 7
1 3
0 2
0 0
E 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:
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.
9 In column 9, 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.
2 + 4 + 6 1 + 3 + 5100%