ML20245E569

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ES-401-9
ML20245E569
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 08/27/2020
From:
Nuclear Management Co
To:
NRC/RGN-III/DRS/OLB
Callaway G
Shared Package
ML19127A300 List:
References
Download: ML20245E569 (20)


Text

ES-401 1 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

Imbedded reference NRC Comments:

Make each answer match plant labeling of the control switch.

Dont ask what the crew will do. No one knows that. Ask what is required by ...

Licensee explained that the terminology is that normally used by E

1 H 3 N operators.

S Licensee explained that all of their exam bank uses the what will the operator do format. At Prairie Island, WILL specifies a requirement. This comment was resolved on all questions that use this terminology.

SAT GWC 7/22/2020 2 H 3 B S Imbedded reference Imbedded reference NRC Comments:

E 3 H 3 N Dont ask what the crew will do. Ask what is required by . . .

S SAT GWC 6/30/2020 Imbedded reference NRC Comments:

E Dont ask what the crew will do. No one knows that. Ask what is 4 H 3 B S required by .

SAT GWC 6/30/2020..

NRC Comments:

Dont ask what the crew will do. No one knows that. Ask what is E

5 F 3 N required by ...

S SAT GWC 6/30/2020 Imbedded reference NRC Comments:

K/A mismatch This question tests 022 AA2.03, Failures of flow control valve or controller instead of AA2.02, Charging pump U

6 H 3 X N problems.

S Perhaps this could test inadvertent start of a 2nd pump, trip of the running pump, or a leak on the pump casing.

Question revised, SAT GWC 7/22/2020 Reference U NRC Comments:

7 H 3 X M S K/A mismatch. This question tests Generic 2.1.25, Ability to interpret reference materials, such as graphs, curves . . .

ES-401 2 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

This does not test if the applicant has any knowledge of the operational implications of loss of RHRS. No RHRS knowledge is required to determine the correct answer.

Do not list the specific reference in the question (Fig C1-33 is provided). The applicant has a package of references and it is the applicants responsibility to determine of any of them are appropriate to a given condition (just like the job).

An operational implication of loss of RHRS may be failure to meet one or more LCOs or inability to achieve MODE 5 (or 6).

Question revised, SAT GWC 7/22/2020 Imbedded reference NRC Comments:

Dont diagnose in the stem (LOCA has occurred). Either give plant indications or tell what procedure is in use (like you did in E question 4).

8 H 3 B S Dont ask what will be done. Ask what is required by Licensee rationale for stating that LOCA has occurred is accepted. It does not detract from the quality of the question.

After discussion, SAT GWC 7/22/2020 Imbedded reference NRC Comments:

E 9 H 3 N No one knows what the crew will observe. Ask what will happen.

S SAT GWC 6/30/2020 10 F 3 N S 11 F 3 N S Imbedded reference NRC Comments:

LOD 1. A picture is given of 6 valve indications, only two of which are open. The meaning of the red and green lights is given away in the question 4 imbedded reference. The question then asks which two valves must be closed. It is apparent that the only two U

valves that can possibly be closed are the open ones. No plant or 12 H 1 E procedure knowledge is required to answer this question.

S Perhaps this could test a combination of what needs to be done with how to do it (controller manipulation) or why 31127 is closed even though it has a full open demand.

After discussion change original evaluation to E.

Revised question SAT GWC 7/22/2020

ES-401 3 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

Imbedded reference NRC Comments:

K/A mismatch. This question does not test the caution prior to step 4. The caution is only exercised when there are no intact SGs (e.g. one faulted, one ruptured) and no other feed source exists. Otherwise, the step is always adequate. In this case, the applicant would do the same thing even if he had no knowledge of U the caution.

13 F 3 X N S Also, the current form of this question is double jeopardy with Event 6 of scenario 1 (isolate a faulted SG).

One way to test this caution would be with one ruptured SG and one faulted SG, then require the applicant to supply the TD AFW pump from the ruptured one (the faulted one will soon have no steam).

Revised question SAT GWC 7/22/2020 Imbedded reference NRC Comments:

E Dont ask what the crew will do. No one knows that. Ask what is 14 F 3 X N S required.

SAT GWC 6/30/2020 Imbedded reference NRC Comments:

E Bus designation needs correcting. 111 is Instrument bus 2, 112 is 15 H 3 N S instrument bus 1.

Correction made SAT GWC 7/22/2020 NRC Comments:

The following comment was first made in a free look submittal.

K/A mismatch. The value of post-trip startup rate is the knowledge that is supposed to be tested here (decay power as a function of time). Giving the value in the stem defeats this purpose. Giving a value that is the expected plant response should never be done. The assumption is that the plant responds as expected unless stated otherwise.

U The distractors are too far apart to be credible. All that is required 16 F 3 X N S for the applicant to know is that SUR has unit of decades per minute. Only one answer has units of minutes.

This could be valid if the SUR info is removed and the answers are all in minutes.

Due to confusion regarding COVID19 (unplanned, emergent work-at-home requirements), the communication for free look submittal was dropped. The affected questions were actually revised, but not submitted. This comment also applies to other free look submittals.

ES-401 4 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

SAT Question replaced. SAT GWC 7/22/2020 17 F 3 N S NRC Comments:

Dont ask what the crew will do. No one knows that. Ask what is E

18 F 3 N required.

S SAT GWC 6/30/2020 19 F 3 N S NRC Comments:

KA mismatch. We previously discussed that a metroscope was an old system to determine rod position in relation to rod insertion limits. This has been replaced by other equipment. I said you should write a question about how you determine if RIL requirements are met during stuck rod response. This question U does not test that.

20 F 3 X N S This question tests AK3.06 Actions contained in EOP for inoperable/stuck control rod instead of the assigned K/A.

Perhaps the question could test if the RIL is based on individual or group position, and the note in step 2.5.3 (new rod insertion limits are required.

Question replaced. SAT GWC 7/22/2020 21 F 3 N S Imbedded reference NRC Comments:

K/A mismatch.

This does not test the reason for the interlock. Instead, it asks about the required operator response.

Perhaps you have a lesson plan or other document that gives U

reasons for some interlocks. For example, is the overload 22 F 3 X N E interlock designed to prevent damage to the crane or the fuel S

assembly? And then test what to do about it.

After discussion, change original designation to E based on minor changes required to correct question.

Question revised, SAT GWC 7/22/2020 NRC Comments:

E 1. This question does not seem to be a modified form of the 23 H 3 M S bank question listed. It tests something completely different.

2. The tie to tube leak is superfluous. The line 11 Steam

ES-401 5 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

Generator has a TUBE LEAK changes nothing (it is window dressing) and is apparently only added to make it appear as a K/A match.

3. Perhaps the premise could be changed to a condition where subcooling is lost during a post-SGTL cooldown and some information page item applies.

Question revised, SAT GWC 7/22/2020 Imbedded reference NRC Comments:

E Dont ask what the RO will do. No one knows that. Ask what is 24 H 3 M S required per SAT GWC 6/30/2020 NRC Comments:

Delayed Neutron is a reactor physics term, not an HP term.

E 25 F 3 M There is no such thing as a delayed neutron detector.

S Deleted delayed. SAT GWC 7/22/2020 Imbedded reference NRC Comments:

Non-credible distractors. Whatever rationale is used to select A could also be applied to C and D (the readings are identical).

U Only B is different No nuclear plant knowledge is required to get 26 H 3 X N S this one correct.

Perhaps ask how this affects the RCS leak detection LCO (in this condition the sump monitor is useless to measure RCS leakage).

Revised question SAT GWC 7/22/2020 27 H 3 B S Reference NRC Comments:

LOD 1.

K/A mismatch With C3 provided and pointed to in the stem, simple math skills are all that is necessary to get the correct answer (SKIN Temp -

U Tcold > 15°F). This test should discriminate between someone 28 H 1 X N E who only has basic high school knowledge and someone who S went to license class.

Do not say C3, is provided Also the K/A is to apply AND explain. The question should include the reason for this restriction.

There is probably an LTOP question here.

Licensee argued that some operator knowledge was required to answer this question. I agreed to change initial designation to E.

ES-401 6 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

Revised question SAT GWC 7/22/2020 Imbedded reference NRC Comments:

LOD 1 because of the imbedded reference.

This question only tests

1. Reading comprehension
2. Ability to read an analog meter
3. Basic math skills This test should discriminate between someone who only has basic high school knowledge and someone who went to license U class.

29 H 1 N E The imbedded reference tells the applicant what we are supposed S to finding out if the applicant knows.

I could accept this question if you do not imbed the reference, include the reference in the package but do not point to the reference in the stem. It is the applicants responsibility to determine if any of the given references are appropriate to a given condition After discussion change original designation to E due to minor corrections needed.

Revised question SAT GWC 7/22/2020 NRC Comments:

The as they relate to MTC part of the K/A is not here.

This question would have the same answer at any time in core life (all credible values of MTC).

E 30 H 3 N The question should compare conditions with different values of S

MTC.

Perhaps ask about the change in Tavg for a given change in rod position at EOL and BOL.

Replaced question SAT GWC 8/5/2020 NRC Comments:

K/A mismatch. This has the same answer if a steam bubble is in U

31 H 3 X N the pressurizer. This K/A requires a question that tests how being S

solid is different than not being solid.

Replaced question SAT GWC 7/30/2020 Imbedded reference NRC Comments:

Small break LOCA is in progress is a conclusion, not an E observation. Instead say, after containment pressure, What does 32 F 3 N S ATTACHMENT L, SI Alignment Verification, require regarding the below valves? (or something along those lines).

Also, justification for C is incoherent.

Question revised SAT

ES-401 7 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

GWC 7/22/2020 Imbedded reference NRC Comments:

K/A mismatch. This question appears to test procedure selection, but it does not. The first part has four unique answers, so the second part adds nothing. i.e. If the applicant recognizes that U

pressure is too high, C is the only possible correct answer. This 33 H 3 X B E may be a question that lends itself to a 2x2 format.

S Also, the justification for a. is backwards.

Change original evaluation to E due to use on previous NRC exam.

Question revised SAT GWC 7/22/2020 Imbedded reference NRC Comments:

Double Jeopardy with #2. Both require the applicant to interpret U tail-pipe temperature to determine status of PORV/Safety valves.

34 H 3 N E The licensee convinced me that there are significant differences S that make it not double jeopardy. Change original designation to E..

Question revised to more precisely match the K/A SAT GWC 7/30/2020 NRC Comments:

K/A mismatch.

The K/A is the effect of loss of component cooling to an RCP.

The question provides that info (bearings heat up and RCP must U be tripped) and asks for a setpoint instead.

35 F 3 X N S Perhaps test the idea that not all bearings should heat up (one is cooled by seal injection or water coming up the shaft).

Revised question to test the effect of SI (Containment isolation) on RCP cooling SAT GWC 7/302020 Imbedded reference NRC Comments:

36 F 3 N S Attached figure 22 (charging pump speed) is an inappropriate reference for this question.

Reference corrected. 7/22/2020 NRC Comments:

Specify in stem that the subsequent failure being considered is 37 H 3 N E another Pressurizer LEVEL channel.

Question revised SAT GWC 7/22/2020 U Imbedded reference 38 H 3 X B E NRC Comments:

S Two non-credible distractors.

ES-401 8 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

While it is true in this case that a pump is not running even though its breaker is closed, it is not credible that a pump is running with an open breaker.

The meaning of the pump status lights was tested in Q. 8.and may not be tested again Perhaps this can be tested showing both SI pump breakers and ask the status of these two pumps.

This would then test the two concepts:

1. Power supply to the pump
2. An SI pump breaker stays closed if its bus deenergizes.

Change original evaluation to E due to use on previous NRC exam.

Question replaced SAT GWC 7/22/2020 39 H 3 B S Imbedded reference Imbedded reference NRC Comments:

E Dont ask what the RO will do. No one knows that. Ask what is 40 H 3 B S required by . .

SAT GWC 6/30/2020..

41 H 3 B S 42 F 3 N S 43 F 3 B S Imbedded reference NRC Comments:

Dont diagnose in the stem. Tell what procedure is in use.

Containment pressure shows that the break is outside E

44 H 3 N containment.

S Dont ask what the RO will do. No one knows that. Ask what is required by . . ..

Question revised SAT GWC 7/22/2020 NRC Comments:

E c and d have essentially the same meaning.

45 H 3 X N S If the first two answers are RISE and LOWER, the only other possible answer is neither rise nor lower (remain the same).

ES-401 9 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

There are other possible misconceptions to test:

  • That each feed pump is dedicated to its own SG (affected SG level drops, unaffected one remains constant)
  • That standby feed pump auto starts when a running one trips (both initially drop, then recover)

There may be some sort of 2x2 arrangement that would make a valid question.

Revised question with better distractors GWC 7/220/2020 Imbedded reference NRC Comments:

E Dont ask what the RO will do. No one knows that. Ask what is 46 H 3 N S required by . .

SAT GWC 6/30/2020..

NRC Comments:

Dont ask what the RO will do. No one knows that. Ask what is E

47 H 3 N required by . . ..

S SAT GWC 6/30/2020 Imbedded reference NRC Comments:

Distractors are not credible. The marked band at the top suggests a desired value and the other three arrows point at U

48 F 3 X N nothing. I Suggest two part: clockwise/counter clockwise and just S

to left of TOP center/just to the right of top center.

Dont ask what the RO will do. No one knows that. Ask what is required by . . .

Revised question as suggested SAT 7/30/2020 Imbedded reference NRC Comments:

The two dashed items are window dressing (The crew is performing and 12 Steam Generator) especially when the E readings do not reflect this condition.

49 F 3 N S Instead of designated as post-accident instrumentation, say intended for use under accident conditions (quote from RG 1.97).

Question revised SAT GWC 7/22/2020 50 H 3 N S NRC Comments:

E Distractor B is not credible. (Loss of the D1 starting air system 51 H 3 X N S disables D2 but not D1). The justification section does not address this.

ES-401 10 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

At some plants, starting air is the motive force to stop a running EDG. Perhaps there is a question involving depletion of the start air while the diesel is running. (cant stop it remotely). Even if it is not true, it would be a good distractor.

Revised question to test if remote and local starts are available SAT GWC 7/30/2020 52 H 3 N S NRC Comments:

K/A mismatch When this was submitted for the free look the NRC comment said that Prairie Island apparently does not have a reactor U

building closed cooling water system. Look at the replacement 53 F 3 X N E K/A suggested.

S The licensee revision after free look revision was E (see above)

Revised question tested chilled water to containment which serves the function of reactor building closed cooling water at PI.

SAT GWC 7/30/2020 Imbedded reference NRC Comments:

Distractors C and D are not credible. (A Unit 2 leak makes Unit 1 pressure lower than Unit 2 pressure). If the systems are cross-connected they will read the same. If the instrument and station U

54 H 3 X B air are cross-connected, there is no way to distinguish between A S

and B from these indications.

Perhaps ask the meaning of the red lines on the U-1 meters (I dont know what they mean, but the applicants should).

Revised question SAT GWC 7/22/2020 Imbedded reference NRC Comments:

Dont diagnose in stem. Small break LOCA is a conclusion, not an observation.

E 55 H 3 M Dont ask what the RO will do. No one knows that. Ask what is S

required.

See above. Diagnosis in stem does not change quality of question.

SAT GWC 7/22/2020 NRC Comments:

Remove causing a pressurizer vapor space accident. It adds E nothing.

56 H 3 B S Revised question to specify that the safety valve fails full open.

SAT GWC 7/22/2020

ES-401 11 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

57 F 3 N S NRC Comments:

K/A mismatch. This question does not test effects on axial flux U density This should have been an AFD question, like how a 58 H 3 X N S rod insertion would affect AFD and what do to about it.

Revised question as suggested.

SAT GWC 7/30/2020 59 H 3 N S Imbedded reference NRC Comments:

A lot of window dressing. Nothing changed the basic question of what is the power supply to? If it is not necessary to answer E

60 F 3 N the question or make a distractor credible, it does not belong in S

the stem.

Revised question SAT GWC 7/22/2020 Imbedded reference NRC Comments:

1. K/A mismatch. Ability to predict and monitor changes to prevent exceeding design limits is the requirement. There is no prediction or reference to design limits in this question.
2. This is a cookbook question that requires no plant U

knowledge.

61 H 3 X X N E

3. Level in relation to sea level is not operationally relevant.

S I suggest a question that requires the applicant to correlate the two graphed levels (why are they different? For a given plant condition should they trend together?)

After discussion change original evaluation to E. Licensee defended that some operator knowledge was required.

Revised question to test affect of levels on refueling ops.

SAT GWC 7/30/2020 NRC Comments:

Dont ask what the crew will do. No one knows that. Ask what is E

62 H 3 N required.

S SAT GWC 6/30/2020 NRC Comments:

K/A mismatch. The applicant is not asked how the loss of purge U

affects the containment entry. The question and answers are not 63 H 1 X M E changed by the availability of purge.

S This question only tests literacy. Someone who knows nothing about CPS or containment gets it correct by carefully reading.

ES-401 12 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

Does the containment entry procedure impose any additional requirements if CPS is not available? If so, there may be a question there. If the loss of purge does not affect the containment entry in any way, we may need a new K/A.

After discussion, change original evaluation to E due to small changes required.

Revised question to test affect of loss of purge GWC 7/30/2020 64 H 3 N S 65 F 3 N S 66 F 3 B S 67 F 3 N S Reference NRC Comments:

The distractors are too far apart to be credible. The only way to miss this question is to be about 1000 pcm wrong. Simply being U within 1000 pcm is not an acceptable standard for reactivity 68 H 1 X N S planning. Make the errors more subtle.

Do not say FIG C1.7A is provided After discussion, original question is SAT. They are all possible operator errors using the process.

GWC 7/22/2020 NRC Comments:

It is not credible that normal 100% power operations is an infrequently performed evolution.

There may be some abnormal condition or difficult evolution that U is not specified as an IPTE that could serve as a credible 69 F 3 X N S distractor.

After discussion change original evaluation to E due to small changes required.

Revised question SAT GWC 7/22/2020 70 F 3 N S Imbedded reference U

NRC Comments:

71 H 1 B E All this tests is if the applicant can read an analog meter with a log S

scale and apply simple math skills.

ES-401 13 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

I suggest you keep the picture and ask how to do a source check (check source reading - background). Perhaps a distractor could involve pressing Channel test. Provide no reference.

Change original evaluation to E due to use on previous NRC exam.

Question revised SAT GWC 7/22/2020 Reference 72 H 3 B S NRC Comments:

Do not say RWP is provided.

Reference NRC Comments:

You submitted this as a free look question. NRC made the following comment.

This question can be answered by system knowledge. If Tavg is above the no-load value and rising, only one of these actions is U credible. Perhaps, to test the generic concept, ask what the 73 H 3 X N E symbol means, or perhaps FR rules of usage in a generic S way.

There is apparently no response to the NRC comment.

Do not say 1ES-01 is provided.

After discussion, change original evaluation to E due to free look submittal confusion.

Question revised SAT GWC 7/22/2020 NRC Comments:

Two distractors are not credible. Controlling decay heat removal from the control room is not credible if the control room is being evacuated. (Controlling is a continuous action, not a one-time U

action). If this intends to ask the location where AFW pumps are 74 F 3 X N E started, the question needs to say that.

S After discussion, change original evaluation to E due to small changes required.

Question revised SAT GWC 7/22/2020 Imbedded reference NRC Comments:

The first item, A Large Break LOCA is window dressing.

E 75 F 3 X N Alarm Spent Fuel Pit Hi Temp is not lit. That makes it not a S

credible distractor.

Changed picture SAT GWC 7/22/2020 Imbedded reference U

76(1) H 3 X N NRC Comments:

S RO knowledge.

ES-401 14 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

SRO-only knowledge should not be claimed for questions that can be answered solely using fundamental knowledge of ... plant parameters that require direct entry into Red/Orange Function Restoration. ES-401, P 23.

The CSF status in the upper left corner of the screen shot shows that only Integrity is Red, so the applicant does not need to know FR entry conditions.

Also, SRO-only knowledge should not be claimed for questions that can be answered solely using fundamental knowledge of theoverall mitigative strategy of a procedure.

One of the high level actions of FR-P.1 is to terminate SI if criteria satisfied.

Perhaps a two-part: Conditions required to terminate SI, and TS application when EOPs are exited (Auto SI is disabled until trip breakers cycled).

Replaced question SAT 7/30/2020 Imbedded reference Reference NRC Comments:

RO knowledge. Applying RO system knowledge to the stem-provided info reveals that Unit 2 is the only available source of power to Unit 1. This question then requires the applicant to select the step that provides Unit 1 with power from Unit 2 The picture adds nothing.

Do not say 1ECA-0.0 is provided.

U 77(2) H 3 X M Also, testing how an applicant will implement a given procedure is S

not procedure selection. Selection of a section of a procedure is acceptable, but a particular step is not a section of a procedure.

An example of a procedure section is an attachment. Some procedures have sections. ECA-0.0 has no sections.

There may be a question here that combines a power restoration and a procedure transition after power is restored (the SRO part).

Change SRO justification for learning objective unique to the SRO position at PI.

Original question is SAT Imbedded reference Reference E Do not say T.S. provided 78(3) H 3 N S Corrected as requested SAT GWC 8/5/2020 Imbedded reference Reference E

79(4) H 3 N NRC Comments:

S Do not say PINGP 1576, EAL Matrix, is provided.

Corrected as requested

ES-401 15 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

SAT GWC 8/5/2020 Reference NRC Comments:

Do not say T.S. LCO 3.8.1 is provided.

80 E H 3 N Explain why it is credible that the loss of one transformer causes (5) S two paths to be inoperable.

Updated justification SAT. Reference to LCO in stem removed.

7/22/2020 Reference NRC Comments:

You submitted this is as a free look question, but this submittal does not incorporate NRC feedback..

This question just tests literacy. It says that a pressure boundary leak exists and requires the applicant to enter an action for pressure boundary leakage.

There is UNISOLABLE RCS PRESSURE BOUNDARY leakage outside containment is a conclusion not an observation.

81 U H 1 X N A job-relevant way to test pressure boundary leakage is to give (6) S the location for a leak due to a pipe crack that cannot be isolated and require the applicant to classify the type of leakage The following items are window dressing RCS temp RHR Train B 1C1.6 AOP2.

Do not say T.S. , is provided Revised question SAT due to free look confusion.

GWC 7/22/20290.

82 Imbedded reference H 3 N S (7) 83 NRC Comments:

H 3 N S (8) Do not say T.S. is provided NRC Comments:

Add to justification that NRC Resident Inspector must be notified 84 E H 3 N because of OCC activation.

(9) S Revised justification SAT GWC 7/22/2020 85 H X N S Imbedded Reference (10)

U NRC Comments:

86 H 3 X N E The first part and second part each have four unique answers, so (11)

S knowledge of procedure selection is not tested. i.e. if the

ES-401 16 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

applicant knows that the running RHR pump must be stopped, there is only one answer that says that.

This is a valid question without the first part. i.e. the shift supervisor must transition to A large Break LOCA is a conclusion not an observation. The question stands without it (1ES-1.2 has directed Transfer to Recirculation).

After discussion, changed initial evaluation to E due to small changes required.

Revised question SAT GWC 7/22/2020 Reference NRC Comments:

Do not say PINGP is provided.

87 E H 3 N Do not ask what the shift sup will do. No one knows that. Ask (12) S what is required.

Changed as suggested SAT GWC 7/30/2020 Imbedded reference NRC Comments:

With C35 AOP4 provided, this is a direct look up and requires no SRO knowledge. Step 2.4.3.C says LCO 3.6.5 is not met.

The third paragraph in PURPOSE says Therefore, T.S.3.6.1 CONDITION A is exited after isolating the CFCU cooling water supply and return and entering CFCU T.S.3.6.5CONDITION C or D.

This question would be sat if there were no references and the stem said the plant MODE and 14 fan cooler unit was isolated U

88 IAW C35 AOP4 and then asked about LCO 3.6.5 and 3.6.1.

H 1 X B E (13) If a CFCU has a leak, it is unnecessary to say that the water is S

from the river. This is system knowledge given the above information.

Do not provide C35 AOP4.

The picture is superfluous.

The licensee successfully defended that the question was not a direct look up. There is some ambiguity that must be resolved by operator knowledge. The picture is necessary. Change initial evaluation to E Removed reference SAT GWC 7/30/2020 NRC Comments:

SRO-only knowledge should not be claimed for questions that 89 U can be answered solely using the overall mitigative strategy of a H 3 X N (14) S procedure The high level action summary says The operator attempts to restore or establish auxiliary feedwater flow, main feedwater flow

ES-401 17 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

RO systems knowledge can eliminate A and D, making two distractors not credible.

This question does not select a procedure or a section of a procedure. FR-H.1 has no sections, only steps.

It is not credible that WR levels are stable. If there is no decay heat, how did they get this low?

B should say Bleed and Feed (not feed and bleed).

Perhaps the procedure transition FROM FR-H1 can be tested.

Do not ask what the SS will do. No one knows that. Ask about what is required.

Change SRO justification to learning objective unique to the SRO position.

Change original evaluation to SAT GWC 7/22/2020 90 H 3 N S Imbedded reference (15) 91 H 3 N S (16)

Reference NRC Comments:

Do not say T.S. LCO is provided.

Do not ask what the SS will do. No one knows that. Ask what is 92 E required.

H 3 B (17) S No time frame is specified in the question. In 7 days, D will be correct. Perhaps ask which actions must be entered at the time of discovery.

Revised as suggested. SAT GWC 7/22/2020 NRC Comments:

Change will align equipment to is assigned the responsibility to implement____. with the possible answers Attachment A (name) and Attachment B (name) 93 E F 3 X N This will make it easier for subsequent review and audit to clearly (18) S see that this question requires the applicant to select a procedure.

After discussion, original question is SAT. The names of the attachments give away the answer.

GWC 7/22/2020 NRC Comments:

This can be answered with RO knowledge.

U 94 LCO 3.9.4, in above the line information, requires a decay time F 3 X B E (19) of at least 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. Only one of the answers complies with this S

requirement. No plant procedure has the legal authority to reduce this time.

ES-401 18 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

It is possible that a procedure imposes a more restrictive admin requirement that the TS limit (a longer decay time). Even though this is not the case, it is credible. Perhaps there is a question there.

After discussion, original submittal is E due to small corrections required.

Revised question SAT GWC 7/22/2020 NRC Comments:

Include the SRO only objective in the documentation (not just a 95 E reference to it).

F 3 N (20) S D has a typo (egineering)

Changes made.

SAT GWC 7/22/2020 Imbedded reference NRC Comments:

Distractors are not credible. If Action B is entered at the time of discovery, Action A has no meaning. If the Action A time resets when it expires, the completion time is infinite. If the action A time resets with a 2nd valve, then failing additional valves would be in the best interest of capacity factor.

U 96 If you wish to test the completion time rules from TS section 1.3, H 3 X N E (21) use an actual plant condition and an actual LCO. For example, S

the meaning of the note separate condition entry is allowed can be tested by making LCO 3.4.15 a reference and giving series of overlapping PIV inoperable components.

After discussion, original submittal is E due to small changes required.

Revised question SAT GWC 7/22/2020 NRC Comments:

Distractors not credible.

This question was submitted in its present form as a free look, and the NRC commented that it was unsat.

It is not credible that temporary use of counterfeit parts caused a permanent inoperability/unavailability.

It is not credible that a PAST operability review determines 97 U PRESENT operability.

H 3 X N (22) S The stem says that a Past Operability Review is in progress, but the attached reference does not include the word past. If, as implied using capital letters, this is an identified process, include the reference that defines that process.

It is not credible that a component is OPERABLE, but NOT AVAILABLE There may be a valid question in requiring the applicant to evaluate operability and availability with the counterfeit part still

ES-401 19 Prairie Island 2020 Form ES-401-9 1.

L 3. Psychometric Flaws 4. Job Content Flaws 5. Other O 2. 6. 7.

Q K LOD Source Status 8. Explanation (F (1-5) Stem Cred. Job- Q- SRO (B/M/N) (U/E/S)

Cues T/F Partial Minutia #/Units Backward

/H Focus Dist Link K/A Only

)

installed, but the question must specify the details of the expected effect of the part (e.g. would operate in a normal environment but may fail in an adverse environment or may shorten mission time).

Replaced question SAT GWC 7/30/2020 Reference NRC Comments:

B is not credible. There is no ODCM action that estimates flow rate every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The justification is identical to A but seems to not apply.

It not credible that an SRO applicant would think that R-21 is a flow monitor. Question 71 lists two indications with an R-U 98 designation and they are both obviously radiation monitors.

H 3 X B E (23) Do not say Table 2.2 is provided S

Perhaps if SG blowdown is NOT aligned to the river, there is a question that applies the applicability of its monitor (during releases).

After discussion, change original evaluation to E. R is used a a designation for flow monitors associated with rad monitors.

Revised question SAT GWC 7/22/2020 NRC Comments 2 non-credible distractors.

If the TSC is not manned, distractors A and B are not credible. It is not possible for the site vice president and Ops Mgr to be on site at all times. Thus, they cannot be have initial ED duties.

If there are other SRO positions that are 24/7, they can be used as distractors.

U Most of the stem is window dressing. The exact event or 99 F 3 X N E classification is irrelevant.

(14)

S Just ask who is responsible for initial ED duties when the shift manager is not available.

If there are only two SRO that are 24/7, this may need to be tested with the TSC manned.

After discussion, change original evaluation to E due to small changes required.

Revised question SAT GWC 7/22/2020 Reference NRC

Reference:

100 H 3 N E Do not say PINGP 1576 is provided.

(15)

Removed statement of reference provided SAT GWC 7/30/2020 RO SRO Total Unsat - 11 Unsat - 3 Unsat - 14 Imbedded reference 32 Imbedded reference 8 Imbedded reference 40 Other reference 5 Other reference 6 Other reference 11

ES-401 20 Prairie Island 2020 Form ES-401-9