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 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 RO Admin 1: Calculate delete questions 1 and 2 Conduct of BAST volume required to Operations 2 E raise RWT to refueling G2.1.20 boron concentration RO Admin 2: Determine -add an answer key of the attachments Conduct of Power Ratio Recorder Step 2- add power reduction to 98% required Operations 2 E Potentiometer setting with 3.1 - spell out LTSS G2.1.7 the plant computer failed 4- add no action required RO Admin 3: Determine -Add to question 4 whole body dose requirements and dose Radiation limits associated with Control 3 E performance of a task in the G2.3.7 RCA RO Admin 4:

Equipment Respond to Condenser Control 2 S Vacuum reduction (Evaluate G2.2.44 U-2 Load versus Vacuum)

SRO Admin 1: Conduct of Determine Operator Operations 3 S Qualifications G2.1.8 SRO Admin 2:

Conduct of 5.c - add for low D/P also Review and approve a Operations 2 E STP 73 - circle all the steps, pg 16 - different initials completed Surveillance Test G2.1.7 for IV Procedure SRO Admin 3: Equipment Establish Initial Conditions Control 2 S for STP O-8A-1 G2.2.12 Radiation SRO Admin 4:

Control 2 S Review and Authorize KI G2.3.14 SRO Admin 5: -Change to 15 minutes (was 13)

Emergency Recommend Protective Plan 2 E Action Guidelines to Public G2.4.44 Officials 1

Simulator/In-Plant Safety Function JPMs and K/A

ES-301 Operating Test Review Worksheet Form ES-301-7 1 -fix cue on page 5 004 CVCS -procedure rev - add step 5 to adjust BIAS A4.08 A. SIM-1: Respond to a Charging E charging header rupture (RO-3.8/SRO-3.4) 2 Pg 7 - on 3rd MOV then insert event 3, in eval note -

006 ECCS must remain in PTO to shut the valves A4.07 -above cue - eval note - that charging header flow 1-B. SIM-2: Align a LPSI ECCS FI-212 ion 1C07 is the indication 2 E Pump for Core Flush pumps and Pg 8 - above 1.1.d - eval note about PTO valves (RO- Pg 9 - eval note above 1.1.h - read LPSI flow on 4.4/SRO- FIC-306 or 1-FI-332 4.4) Init cond - DAS failure - no PPC indications 3 -bold event 1 on pg 5 010 PPCS -initial conditions change to 395 A4.03 -added that zero output is -20 C. SIM-3: Override Shut PORV and -1.b - added operator may take actions 3 E a PORV block valves -init conditions - add PORVs are in MPT enable (RO-4.0/SRO-3.8) 4S -add into cue to start 12 CBP 056 CDS A2.04 Loss D. SIM-4: Respond to a of 3 E loss of Secondary Pumps condensate pumps (RO-2.6/SRO-2.8) 5 027 CIRS A4.01 CIRS E. SIM-5: Shift 13 IRU controls 2 S Power Supply (RO-3.3/SRO-3.3) 6 -made starting the 0C EDG not critical 062 AC -deleted all steps after powering 11 4kv bus A4.01 All -add cue for 14 bus faulted into the cue for perform F. SIM-6: Perform Vital Breakers 2 E vital auxiliaries Auxiliaries (RO-3.3/SRO-3.1) 7 -12 make not critical 012 RPS -19 make not critical G. SIM-7: Reactor A4.04 2 E Protection System Test Bistables, trips, reset

ES-301 Operating Test Review Worksheet Form ES-301-7 and test switches (RO-3.3/SRO-3.3) 8 -typo-make not alternate path 008 CCWS -snap with 520 in bypass - add to initial conditions A4.01 CCW and into steps H. SIM-8: Shift indications -delete step B.6 Component Cooling Heat 3 E and controls Exchangers (RO-3.3/SRO-3.1) 5 022 CCS I. PLT-1: Start 11 & 12 A4.01 CCS 2 S Containment Air Coolers Fans (RO-3.6/SRO-3.6) 8 086 FPS AA4.05 J. PLT-2: Respond to a Deluge 2 S fire on site Valves (RO-3.0/SRO-3.5) 4P 035 SGS A3.01 S/G K. PLT-3: Control RCS Water Level and S/G Inventory from 2 S Control 2C43 (RO-4.0/SRO-3.9)

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 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 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 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 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 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 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 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 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.

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

Total Explanation Unsat. Edits Sat. Unsat.

Admin.

9 0 5 4 JPMs Sim./In-Plant 11 0 7 4 JPMs Scenario 1 was the Spare and was not run.

Scenarios 3 0 0 3 Deleted from this record.

Op. Test 23 0 19 11 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).