ML20365A087
| ML20365A087 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/13/2018 |
| From: | Chuck Zoia Indiana Michigan Power Co |
| To: | NRC/RGN-III/DRS/OLB |
| Zoia C | |
| Shared Package | |
| ML17164A381 | List: |
| References | |
| Download: ML20365A087 (14) | |
Text
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: DC Cook Exam Date: July 2018 1 2 3 4 5 6 Admin. Simulator Safety Attributes Job Content LOD and In-plant Function U/E/S Explanation (1-5) I/C Critical Scope Perf.
JPMs and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC:
- 1) K/A associated with this administrative topic not listed as coming from Section 2 (Generic Knowledge and Abilities) of the K/A Catalog in the JPM Guide.
This is contrary to NUREG 1021 Rev. 11 as indicated on ES-301, Page 10 of 33. K/As associated with Conduct of each administrative topic shall be selected from Section 2 of the applicable NRC K/A Catalog A1-RO Ops - 2 E
- 2) Task Briefing incorrectly lists 2-SG-9, Point 16 for 015.A1.01 Feedwater Heater 6A & 6B Outlet Temperature.
Procedure calls out 2-SG-9, Point 26.
- 3) Verify critical steps are documented on the form and not just verified to be correctly filled out.
Licensee: K/A matter fixed. 2-SG-9, Point 26 is correct.
Equipment A2-RO Control - 3 S 2.2.13 Radiation NRC: Step 3.2 - the switch must be repositioned for the step to be critical, not just verified.
A3-RO Control - 2 E
2.3.5 Licensee
No longer a critical step.
NRC: The JPM Guide is based on out of date revisions of the applicable references. PMP-2080-EPP-108 is now revision 15 (which is not provided to Emergency the examinee) and EMD-32a was revised as of 12/2014 (and is provided to the examinee - changed A4-RO Plan - 3 E formatting). These revisions do not appear to result 2.4.39 in the examinee being unable to successfully complete the JPM, but must be confirmed.
Licensee: Updated references.
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: DC Cook Exam Date: July 2018 1 2 3 4 5 6 Admin. Simulator Safety Attributes Job Content LOD and In-plant Function U/E/S Explanation (1-5) I/C Critical Scope Perf.
JPMs and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link Simulator/In-Plant Safety Function JPMs and K/A 1 - APE 024 NRC 2018-AA1.15 2 S SIM01 and SYS 004 A2.14 NRC: Step 19.a - if the operator opens 2 sets of 2 - EPE valves, is that a failure?
NRC 2018-009 2 X E SIM02 Licensee: No, the step (CS) says at least one set of EA2.38 valves.
NRC: Directing an Aux Operator to perform an action would not be considered a CS in itself. The NRC 2018- 3 - 006 2 X E subsequent actions would be. (Step 24.c)
SIM03 A4.02 Licensee: JPM starts at Step 26 after OV.
4 - EPE NRC 2018-009 2 S SIM04 EA1.09 NRC 2018- 5 - 103 2 S SIM05 A3.01 NRC 2018- 6 - 064 2 S SIM06 A4.06 NRC: What is the cause of the high radiation conditions being experienced on the refuel floor?
NRC 2018- 7 - 072 The JPM is unclear in this regard.
2 X E SIM07 K4.02 Licensee: This cue is provided at steps 3.5 - 3.7, if requested.
NRC: Step 10.b.2 - if the operator starts 2 NRC 2018 8 - 034 Pressurization Fans, is that a failure?
2 X E SIM08 A2.01 Licensee: One Fan is required and expected.
ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: DC Cook Exam Date: July 2018 1 2 3 4 5 6 Admin. Simulator Safety Attributes Job Content LOD and In-plant Function U/E/S Explanation (1-5) I/C Critical Scope Perf.
JPMs and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC: The safety function of this JPM appears to be more in alignment with Safety Function 8 Plant Service Systems as the primary purpose of the JPM 7 - APE is to initiate cooling water for the Control Room Air NRC 2018 068 2 E Conditioning system.
INP01 Licensee: This point was discussed with the licensee, AA1.24 who defended their original position. Noted that choosing SF 8 or leaving it as SF 7 has no impact on any exam requirements.
3 - APE NRC 2018 068 2 S INP02 AK3.18 NRC: Step 4.9 can ONLY be a CS IF the valve is NRC 2018 9 - 071 repositioned (Verification is not a verifiable action).
2 X E INP03 A4.14 Licensee: Agreed
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: DC COOK Scenario: 1 Exam Date: July 2018 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 X X S 5 X S 6 X S 7 X S 8 S 9 S 9 3 2 8 S
ES-301 6 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 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 7 Form ES-301-7 Facility: DC Cook Scenario: 2 Exam Date: July 2018 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 NRC: This event requires a TS call per TS 3.7.8. This was not included on the D-1 or the X E 2 301-5.
3 X S 4 X S 5 X S 6 X S 7 X S 8 X S 8 3 3 7 E See above.
ES-301 8 Form ES-301-7 Facility: DC Cook Scenario: 3 Exam Date: July 2018 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 S 3 X S 4 S 5 X S 6 S 7 X S 8 X S 9 X X S 10 S 10 2 3 9 S
ES-301 9 Form ES-301-7 Facility: DC Cook Scenario: 4 Exam Date: July 2018 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 X S 4 X S 5 S 6 S 7 X S 8 S 9 X S NRC: D-1 and 301-4 list 3 CTs for this scenario, but D-2 does not identify CT associated X E 10 with RWST makeup.
10 2 2 8 E See above.
ES-301 10 Form ES-301-7 Facility: DC Cook Scenario: 5 Exam Date: July 2018 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 X S 2 S 3 X S 4 X X S 5 X X S 6 X S 7 X S 8 X X S 8 3 2 2 S
ES-301 11 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 9 0 3 0 2 0 0 S NRC: This event requires a TS call per TS 3.7.8. This was not included on the D-1 or the 2 8 0 3 0 3 0 0 E 301-5. Called for in the D-2.
3 10 0 2 0 3 0 0 S NRC: D-1 and 301-4 list 3 CTs for this scenario, but D-2 does not identify CT associated with 4 10 0 2 0 2 0 0 E RWST makeup.
5 8 0 3 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.
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 12 Form ES-301-7 Site name: Exam Date:
OPERATING TEST TOTALS Total Total Total %
Total Explanation Unsat. Edits Sat. Unsat.
Admin.
4 0 2 JPMs Sim./In-Plant 11 0 2 JPMs Scenarios 5 0 2 Op. Test 20 0 6 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).
Facility: Exam Date:
1 2 3 4 5 6 ADMIN Attributes Job Content SRO Admin LOD Topic and U/E/S Explanation JPMs (1-5) I/C Critical Scope Perf.
K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link Conduct of NRC: On page 13, JPM Guide incorrectly states that NI-41 indicates above 100.5%, it should say NI-44 A1-SRO Ops - 3 E reads above 100.5%.
2.1.45 Licensee: Corrected Conduct of NRC: How does SRO validate RCS and Transfer Canal boron concentration and source range counts A1.B-SRO Ops - 3 E information reported in paperwork?
2.1.40 Licensee: Added a verification/cue.
NRC: SRO IR for K/A 2.2.13 should be reported as 4.3. 301-1 and JPM Guide incorrectly list it as 3.8.
Also, the steps originally marked as critical to remove Equipment power from the motor operated valves should not be A2-SRO Control - 2 E critical. The cue was to isolate the leak and protect 2.2.13 the system. The only critical steps should be closing the boundary valves and disabling the pump start.
Licensee: Updated K/A IR. Those steps are no longer considered to be critical.
Radiation NRC: Examinee may also notice that the recirc time for two volumes incorrectly selects 80-89% level A3-SRO Control - 3 E when tank level is reported as 90%.
2.3.11 Licensee: Changed to 85%
A4-SRO 3 S 2.4.41 and 2.4.44 Simulator/In-Plant Safety Function JPMs and K/A 1 - APE 024 NRC 2018-AA1.15 2 S SIM01 and SYS 004 A2.14 2 - EPE NRC 2018-009 2 S SIM02 EA2.38 NRC 2018- 3 - 006 2 S SIM03 A4.02 4 - EPE NRC 2018-009 2 S SIM04 EA1.09 NRC 2018- 5 - 103 2 S SIM05 A3.01
NRC 2018 064 2 S SIM06 A4.06 NRC 2018 8 - 034 2 S SIM08 A2.01 NRC: The safety function of this JPM appears to be 7 - APE more in alignment with Safety Function 8 Plant NRC 2018 068 2 E Service Systems as the primary purpose of the JPM INP01 is to initiate cooling water for the Control Room Air AA1.24 Conditioning system.
3 - APE NRC 2018 068 2 S INP02 AK3.18 NRC 2018 9 - 071 2 S INP03 A4.14