ML19346E371

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NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML19346E371
Person / Time
Site: Hope Creek 
Issue date: 08/12/2019
From:
NRC Region 1
To:
Public Service Enterprise Group
Shared Package
ML19007A361 List:
References
EPID L-2019-OLL-0016
Download: ML19346E371 (10)


Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility:

Hope Creek Exam Date: August 12, 2019 1

2 3

4 5

6 Attributes Job Content JPMs ADMIN Topic and KIA LOD U/E/S Explanation Admin (1-5)

Critical Scope Perf.

1/C Job Cues Overlap Key Minutia

  • .Focus.

Steps (N/B)

Std.

Link

1.

Added that J. Smith is not SRO ADMIN A1 - Ensure The qualified for another position to Operating Shift Is Adequately Conduct of Operations 2

E Initial Conditions.

2.1.5

2.

Added location for Manned comoleted time to Initial Conditions. *

1.

Corrected typographical errors in the Initial Conditions.

SRO ADMIN A2 - Review All

2.

Added Note any Operations Logs In Use During Conduct of Operations E

.discrepancies (if any) to Initiating A Shift lnclµding Computer 2.1.25 3

Cue.

Logs

3.

Modified Standard for Step 4.1 per NRC's recommendation.

SRO ADMIN A3 - Complete an Equipment Control E

1.

Added Loop A to describ~

Action Statement Loa Sheet 2.2.23 2

unsatisfactorv test.

1.

Added procedure and Form to provided procedures.

SRO ADMIN A4 - Verify Radiation Control E

2.

Added to note any Compliance with Gaseous 2.3.6 3

changes if any to Initiating Cue.

Release Permit

3.

Changed one step to not

  • critical.
1.

Corrected difference SRO ADMIN A5 - Utilize The between Examiner and Operator's ECG To Determine The Emergency Plan E

Initial Conditions.

Emergency Classification 2.4.38 3

2.

Added reference And/Or Reportability Of An procedures provided to Operator at Event And/Or Plant Condition the beoinnirio of the JPM.

RO ADMIN A1 - Complete The Conduct of Operations 2

E Added Noun Name to CRIDS point.

Dailv Surveillance Loas 2.1.19 RO ADMIN A2 - Perform A Conduct of Operations s

Shift Turnover As On-2.1.18 3

Comina/Off-Goino NCO

1.

Revised/added the following to the Initial Conditions:

RO ADMIN A3 - Perform Another operator is Actions to Achieve Criticality Equipment Control 3

E responsible for making entries into and Raise Power to the Point 2.2.2

~

the Control Room Narrative Log.

of Adding Heat Stated that step 4.2.1 has iust been completed.

ES-301 RO ADMIN A4 - Purge The Containment Simulator/In-Plant JPMs SIM JPM A - Synchronize and Load the Main Generator/Respond To A Turbine Generator Malfunction SIM JPM B - Reduce Torus Level Using RCIC System SIM JPM C-TransferTACS To The Standby SACs Loop SIM JPM D - Manually Start the Core Spray System SIM JPM E - Exercise A Control Rod Radiation Control 2.3.11 Safety Function and KIA 6 - Electrical 262001 A4.04 4 - Heat Removal from the Core 295029 EA1.04 8 - Plant Service Systems 400000 A4.01 2 - Reactor Water Inventory Control 209001 A4.01 1 - Reactivity Control 201003 A2.06 Operating Test Review Worksheet 3

E 3

s 3

E 4

s 3

s 3

E Form ES-301-7 All conditions are satisfactory for completing step 4.2.2.

Inserted Reactor Engineering Guidance for rod selection and movement.

2.

Modified Standards to reflect removal of 4.2.1 and insertion of RE Guidance.

. 3.

Corrected_typographical error 4.2.6.2.

1.

Removed not-applicable dates and times.

2.

Recalculated time.

1.

Modified Standard for 5.1.7.

1.

Change 5. 12. 1 to not critical.

2.

Modified Standard for 5.6.

ES-301 Operating Test Review Worksheet Form ES-301-7 SIM JPM F - Operate The 5 - Containment PCIG System During Post Integrity 3

s LOCA/lsolation Conditions 223001 A4.11 SIM JPM G - Respond To A 7 - Instrumentation Recirculation Pump 3

s Malfunction 295001 AA 1.06

1.

Added that plant has been 3 - Reactor *Pressure stable for the last two hours to the SIM JPM H - Perform a Control Initial Conditions.

Cooldown Using Bypass 2

E

2.

Revised Initiating Cue to Valves 241000 A4.02 specific temperature. Revised Standard for the associated

-orocedure Stec.

8 - Plant Service IN-PLANT JPM I - Respond To Systems 3

s A SACS Malfunction 400000 A2.01 IN-PLANT JPM J - Remove A 6 - Electrical 120 VAC Electrical Distribution 3

s Svstem From Service 2.1.30 IN-PLANT JPM K - Vent To 5 - Containment Control Containment Pressure Integrity With Suppression Pool Level 3

s Less Than 180 Inches 295024 EA1.19

\\

ES-301 4

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 KIA. Mark in column 1.

(ES-301, D.3 and D.4)

2.

Determine the level of difficulty (LOO) 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:

D The initial conditions and/or initiating cue is clear to ensure the operator understands the task and how to begin. (Appendix C, 8.4)

D. 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)

D All critical steps (elements) are properly identified.

D The scope of the task is not too narrow (N) or too broad (B).

D 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)

D 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.

D 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 m~et the following elements:

D Topics are linked to the job content (e.g., not a disguised task, task required in real job).

D 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 reviewer's 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)nharicement 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.

r

ES-301 5

Form ES-301-7 Facility:

Hope Creek Scenario:

1 Exam Date: 8/12/2019 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOO TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

s 2

s 3

X s

4 s

5 X

s 6

s 7

X s

8 X

s 8

2 2

5 E

ES-301 6

Form ES-301-7 Facilitv: Hope Creek Scenario:

2 Exam Date: 8/12/2019 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable' LOD TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

s 2

s 3

X s

4 X

X s

Loss of 1 OD420 2018 Scenario 1 5

s 6

X X

s Loss of off site oower with EOG fail b autostart 2018 scenario 3 7

X X

s HPCI steam leak 2018 scenario 2 8

s

(

.--cc

ES-301 7

Form ES-301-7 Facility: Hope Creek Scenario:

3 Exam Date: 8/12/2019 1

2 3

4 5

6 7

8 9

10 Event Realism/Cred.

Required Verifiable LOO TS CTs Seen.

U/E/S Explanation Actions actions Overlap 1

s 2

X s

3 X

s 4

X s

5 s

6 s

7 s

8 s

9 X

X s

Drywell spray valve failure, 2018 scenario 1

ES-301 8

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, 8.3).)

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 reviewer's 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.

1 O Record any explanations of the events here.

In the shaded boxes, sum the number of check marks jn each column.

In colu~n 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 LOO 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 9

Form ES-301-7 Facility:

Hope Creek Exam Date: August 12, 2019 1

e 2

3 4

5 6

7 8

11 Scenario Event Events TS TS CT CT

%Unsat.

Explanation

(_

Totals Unsat.

Total Unsat.

Total Unsat.

Scenario U/E/S Elements 1

8 0

2 0

2 0

0 s

D-1 s do not list any TS events, and do not list which operator is credited for the action.

2 8

0 2

0 2

0 0

s 3

8 0

2 0

2 0

0 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 + 5 100%

8 If the value in column 7 is > 20%, mark the scenario as (U)nsatisfactory in column 8. If column 7 is :5 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.

ES-301 Site name:

Admin.

JPMs Sim./In-Plant JPMs Scenarios Op. Test Totals:

Total Total Unsat.

9 0

11 0

4 0

24 0

10 Form ES-301-7 Exam Date:

OPERATING TEST TOTALS Total Total Explanation Edits Sat.

Unsat.

8 9

Edits were editorial in nature 3

11 Edits were editorial in nature 4

4 Edits were editorial in nature 14 24 0

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.
2.
3.
4.
5.
6.

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.

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.

Enter totals for (E)nhancements needed and (S)atisfactory JPMs and scenarios from the previous tables. This task is for tracking only.

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

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

Refer to ES-501, 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%

Update this table and the tables above with post-exam changes if the "as-administered" operating test required content changes, including the following:

The JPM performance standards were incorrect.

The administrative JPM tasks/keys were incorrect.

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

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

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