ML21193A316

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NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)
ML21193A316
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 06/16/2021
From:
NRC Region 1
To:
Exelon Generation Co
Shared Package
ML20261H327 List:
References
EPID L-2021-OLL-0028
Download: ML21193A316 (10)


Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Calvert Cliffs Exam Date: June 7, 2021 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.

RO Admin 1: Calculate BAST volume required to raise RWT to refueling boron concentration Conduct of Operations G2.1.20 2

E delete questions 1 and 2 RO Admin 2: Determine Power Ratio Recorder Potentiometer setting with the plant computer failed Conduct of Operations G2.1.7 2

E

-add an answer key of the attachments Step 2-add power reduction to 98% required 3.1 - spell out LTSS 4-add no action required RO Admin 3: Determine requirements and dose limits associated with performance of a task in the RCA Radiation Control G2.3.7 3

E

-Add to question 4 whole body dose RO Admin 4:

Respond to Condenser Vacuum reduction (Evaluate U-2 Load versus Vacuum)

Equipment Control G2.2.44 2

S SRO Admin 1:

Determine Operator Qualifications Conduct of Operations G2.1.8 3

S SRO Admin 2:

Review and approve a completed Surveillance Test Procedure Conduct of Operations G2.1.7 2

E 5.c - add for low D/P also STP 73 - circle all the steps, pg 16 - different initials for IV SRO Admin 3:

Establish Initial Conditions for STP O-8A-1 Equipment Control G2.2.12 2

S SRO Admin 4:

Review and Authorize KI Radiation Control G2.3.14 2

S SRO Admin 5:

Recommend Protective Action Guidelines to Public Officials Emergency Plan G2.4.44 2

E

-Change to 15 minutes (was 13) 1 Simulator/In-Plant Safety Function and K/A JPMs

ES-301 Operating Test Review Worksheet Form ES-301-7 A. SIM-1: Respond to a charging header rupture 1

004 CVCS A4.08 Charging (RO-3.8/SRO-3.4)

E

-fix cue on page 5

-procedure rev - add step 5 to adjust BIAS B. SIM-2: Align a LPSI Pump for Core Flush 2

006 ECCS A4.07 ECCS pumps and valves (RO-4.4/SRO-4.4) 2 E

Pg 7 - on 3rd MOV then insert event 3, in eval note -

must remain in PTO to shut the valves

-above cue - eval note - that charging header flow 1-FI-212 ion 1C07 is the indication Pg 8 - above 1.1.d - eval note about PTO Pg 9 - eval note above 1.1.h - read LPSI flow on FIC-306 or 1-FI-332 Init cond - DAS failure - no PPC indications C. SIM-3: Override Shut a PORV 3

010 PPCS A4.03 PORV and block valves (RO-4.0/SRO-3.8) 3 E

-bold event 1 on pg 5

-initial conditions change to 395

-added that zero output is -20

-1.b - added operator may take actions

-init conditions - add PORVs are in MPT enable D. SIM-4: Respond to a loss of Secondary Pumps 4S 056 CDS A2.04 Loss of condensate pumps (RO-2.6/SRO-2.8) 3 E

-add into cue to start 12 CBP E. SIM-5: Shift 13 IRU Power Supply 5

027 CIRS A4.01 CIRS controls (RO-3.3/SRO-3.3) 2 S

F. SIM-6: Perform Vital Auxiliaries 6

062 AC A4.01 All Breakers (RO-3.3/SRO-3.1) 2 E

-made starting the 0C EDG not critical

-deleted all steps after powering 11 4kv bus

-add cue for 14 bus faulted into the cue for perform vital auxiliaries G. SIM-7: Reactor Protection System Test 7

012 RPS A4.04 Bistables, trips, reset 2

E

-12 make not critical

-19 make not critical

ES-301 Operating Test Review Worksheet Form ES-301-7 and test switches (RO-3.3/SRO-3.3)

H. SIM-8: Shift Component Cooling Heat Exchangers 8

008 CCWS A4.01 CCW indications and controls (RO-3.3/SRO-3.1) 3 E

-typo-make not alternate path

-snap with 520 in bypass - add to initial conditions and into steps

-delete step B.6 I. PLT-1: Start 11 & 12 Containment Air Coolers 5

022 CCS A4.01 CCS Fans (RO-3.6/SRO-3.6) 2 S

J. PLT-2: Respond to a fire on site 8

086 FPS AA4.05 Deluge Valves (RO-3.0/SRO-3.5) 2 S

K. PLT-3: Control RCS and S/G Inventory from 2C43 4P 035 SGS A3.01 S/G Water Level Control (RO-4.0/SRO-3.9) 2 S

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: 2 Exam Date: June 7, 2021 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

X S

3 X

S 4

S 5

X S

6 S

7 XX S

Corrections and edits made:

-add comms for start up check for 12 CC pump

-add in may implement AOP-7E during AOP-7G

ES-301 6

Form ES-301-7 Facility: Calvert Cliffs Scenario: 3 Exam Date: June 7, 2021 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

X S

3 X

S 4

S 5

S 6

XX S

7 X

S Corrections and edits made:

-CT isolate SG bounded by time - within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

-add comm for MSIV fire alarm for event 7

-Add note into turnover sheet for shifting CHG pumps

ES-301 7

Form ES-301-7 Facility: Calvert Cliffs Scenario: 4 Exam Date: June 7, 2021 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

X S

3 X

S 4

S 5

X S

6 S

7 XX S

8 S

Corrections and Edits made:

-adjust timing for comms for condensate header rupture

-timing for 12 DC Bus loss to immediately on the trip

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, 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 9

Form ES-301-7 Facility: Calvert Cliffs Exam Date: June 7, 2021 Scenario 1

2 3

4 5

6 7

8 11 Event Totals Events Unsat.

TS Total TS Unsat.

CT Total CT Unsat.

% Unsat.

Scenario Elements U/E/S Explanation 2

7 0

2 0

3 0

0 S

3 7

0 2

0 3

0 0

S 4

8 0

2 0

3 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:

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%

ES-301 10 Form ES-301-7 Site name: Calvert Cliffs Exam Date: June 7, 2021 OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

0 5

4 Sim./In-Plant JPMs 11 0

7 4

Scenarios 3

0 0

3 Scenario 1 was the Spare and was not run.

Deleted from this record.

Op. Test Totals:

23 0

19 11 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.

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.

2.

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.

3.

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

4.

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

5.

Calculate the percentage of the operating test that is (U)nsatisfactory (Op. Test Total Unsat.)/(Op. Test 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%
6.

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).