ML20274A094

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NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML20274A094
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/07/2020
From:
Exelon Generation Co
To:
Division of Nuclear Materials Safety I
Shared Package
ML19105A101 List:
References
Download: ML20274A094 (11)


Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Calvert Cliffs Exam Date: January 27, 2020 1 2 3 4 5 6 ADMIN Attributes Job Content LOD Admin JPMs Topic and U/E/S Explanation (1-5) I/C Critical Scope Perf.

K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link Conduct of -change ranges for both calculations - fixed RO Admin 1: Estimate Operations 2 E -clean up task standard - fixed Time to Boil G2.1.25 -make 2a and 3a critical - fixed

-move cue on page 5-fixed Conduct of RO Admin 2: Determine -page 6 unbold CEA position - fixed Operations 2 E Shutdown Margin -page 6 clean up words for when SDM is valid until -

G2.1.37 fixed

-remove TS 3.6.3 from initial conditions - fixed Equipment

-add 3 other valves they may add to the isolation step RO Admin 3: Print Reading Control 3 E

- fixed G2.2.41

-step 3 add the letter A to the TS - fixed Emergency -page 4 and 5 clean up words for required people -

RO Admin 4:

Plan 2 E fixed Respond to a Plant Fire G2.4.27 SRO Admin 1: Conduct of Evaluate Overtime Work Operations 3 S No comments Request G2.1.5 SRO Admin 2: Conduct of Supervisory Review of Operations 2 S No comments Shutdown Margin G2.1.37 SRO Admin 3: Print Equipment -remove TS 3.6.3 from initial conditions - fixed Reading and Application of Control 2 E -add 3 other valves they may add to the isolation step Tech Specs G2.2.41 - fixed SRO Admin 4: -clean up set up instructions - fixed Radiation Administrative -add cue for giving RP-CA-300-1004 to students if Control 2 E Requirements for RMS asked - fixed G2.3.15 Inoperability SRO Admin 5: Emergency -change initial conditions to per gm not per cc - fixed Perform Shift Emergency Plan 2 E Director Functions G2.4.41 1

Simulator/In-Plant Safety Function JPMs and K/A 1 -Add in range for CEA motion in step I - fixed A. SIM-1: Respond to a A4.03 E -Typo on page 5 note - fixed CEDS failure CRDS

ES-301 Operating Test Review Worksheet Form ES-301-7 mode -add evaluator note for multiple boration success control (4.0, paths - fixed 3.7) -add evaluator note for alarms being silenced - fixed 2 -change cue to respond to all alarms - fixed A3.01 Input -add cue to additional operator monitoring RCP temps B. SIM-2: Verify Validity of channels 2 E - fixed CIS Actuation and logic (3.7, 3.9)

-page 4 and 10 add in nomenclature for 1-SI-656 -

3 fixed A4.07 -page 7 change words for 13 HPSI pump to tripped -

C. SIM-3: Verify ECCS fixed 3 E HPSI/LPSI Flow pumps and -page 2 adjust RCS leakrate to 1000 gpm - fixed valves (4.4, -page 2 adjust 1st RCS leakrate to 300 gpm - fixed 4.4) -page 6 - add cue to not pursue 12 HPSI pump at this time - fixed 4P -page 6 add cue for not a common mode failure -

A4.01 fixed Controls -page 7 change wording of cue and swap order of cue D. SIM-4: Attempt to and and step - fixed Correct the Abnormal SDC 3 E indications -page 8 add cue for ECCS air coolers - fixed Condition for RHR -task standard add words for flow value - fixed pumps (3.6, 4.4) 4S -page 8 - make 3 valves critical steps - fixed A4.04 -page 6 add a cue for local verification of 1-SW-5149 E. SIM-5: Align Saltwater Emergency 2 E - fixed Emergency Overboard heat loads (3.5, 3.5)

-page 2 fix task standard - fixed, more detail added 5

-page 2 add parameters to step 6 - fixed F. SIM-6: Pressurizer Vent A4.04 PZR 2 E -page 4 make 6.4.3 critical - fixed Valve Testing Vent Valve

-page 6 make 6.4.6.5, 6.4.6.6, and 6.4.6.7 critical -

(2.6, 3.1) fixed 6 -page 2 add OI to the task standard - fixed A4.01 All -page 4 and 11 clean up initial conditions - fixed Breakers -page 6 unbold the value for MW and KVARS - fixed G. SIM-7: Perform Vital (including 2 E Auxiliaries available switchyard)

(3.3, 3.1) 8 -clean up task standard to spell out alternate actions H. SIM-8: Respond to A4.01 CCW taken - fixed RCS leakage into indications 3 E -make step to start the pen room fans not critical -

Component Cooling System and controls fixed (3.3, 3.1) -clean up standard for step 10 - fixed 4S -add details for locking device - fixed 2.1.30 -add details for valve manipulation in the locked box -

I. PLT-1: Align AFW flow Ability to 2 E fixed control to 1C43 locate and operate

ES-301 Operating Test Review Worksheet Form ES-301-7 components (4.4, 4.4) 6 -page 4/5 - breakers from OPEN to OFF - fixed AA1.10 -page 5 - typo AH to AG - fixed J. PLT-2: Operate MCC Power -page 4 - add a cue for electrical safety - fixed 2 E Load Breakers Distribution:

ac and dc (3.7, 3.9) 8 -add page numbers - fixed AA1.04 -step 4 add gauge number - fixed K. PLT-3: Respond to a Emergency -step 5 add HS number - fixed 2 E Loss of Instrument Air air -step 5d add gauge number - fixed compressor (3.5, 3.4)

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 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 5 Form ES-301-7 Facility: Calvert Cliffs Scenario: 1 Exam Date: January 27, 2020 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 X S 2 S 3 S 4 X S 5 X S 6 S 7 X S 8 X S Corrections and Edits made:

-make LOOP on a timer for 2 minutes (page 2) - fixed

-make event 5 (ATWS) on a trigger at 84% power - fixed

-make RCS leak 300 gpm - fixed

-cascading TS question for trip of 12 SRW pump - fixed

-rearrange the order of actions for Event 6, 7, and 8 - fixed

ES-301 6 Form ES-301-7 Facility: Calvert Cliffs Scenario: 2 Exam Date: January 27, 2020 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 X S 2 X S 3 S 4 X S 5 S 6 X S 7 XX S 8 X S Corrections and edits made:

-add detail for TRM for charging - fixed

ES-301 7 Form ES-301-7 Facility: Calvert Cliffs Scenario: 3 Exam Date: January 27, 2020 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 X S 3 S 4 S 5 X X S 6 X S 7 X S Corrections and edits made:

-added may to securing letdown on page 10 - fixed

ES-301 8 Form ES-301-7 Facility: Calvert Cliffs Scenario: 4 Exam Date: January 27, 2020 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 X S 2 X S 3 S 4 S 5 S 6 XX S 7 S 8 S Corrections and Edits made:

-remove incorrect tech spec from page 12 - fixed

-added cue to adjust turbine vibrations to reach trip criteria as directed by lead examiner - fixed

-clarify temperature of Tcold for critical task 2 - fixed

-changed timing of event 8 to be 5 minutes after event 7 - fixed

-page 16 0C EDG remove - fixed

-remove #3 critical task - fixed

ES-301 9 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, 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 10 Form ES-301-7 Facility: Exam Date:

1 2 3 4 5 6 7 8 11 Scenario  % Unsat. Explanation Event Events TS TS CT CT Scenario U/E/S Totals Unsat. Total Unsat. Total Unsat.

Elements 1 8 0 2 0 3 0 0 S 2 8 0 3 0 4 0 0 S 3 7 0 2 0 3 0 0 S 4 8 0 2 0 2 0 0 S 5 Removed details about Scenario 5 (SPARE) as this was never ran 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.

2+4+6 7 In column 7, calculate the percentage of unsatisfactory scenario elements: 100%

1+3+5 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.

ES-301 11 Form ES-301-7 Site name: Calvert Cliffs Exam Date: January 27, 2020 OPERATING TEST TOTALS Total Total Total  %

Total Explanation Unsat. Edits Sat. Unsat.

Admin.

9 0 7 9 JPMs Sim./In-Plant 11 0 11 11 JPMs Scenarios 5 0 5 5 Op. Test 25 0 23 25 0 Totals:

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.

Enter the total number of (U)nsatisfactory JPMs and scenarios from the two JPMs column 5 and 2.

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 3.

tables. This task is for tracking only.

4. 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 5.

Total) and place this value in the bolded % 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 6.

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).