ML21230A351

CN-2021-06-DRAFT Op Test Comments kdc-rev1-final

ML21230A351
Person / Time
Site:	Cooper
Issue date:	06/25/2021
From:	Heather Gepford Operations Branch IV
To:	Nebraska Public Power District (NPPD)
References
Download: ML21230A351 (5)

Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Rev. 11 Facility:

Cooper Nuclear Station Exam Date:

(Retake) June 28, 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.

A1 N/A SRO only admin and JPM Retake Exam A2 N/A A3 N/A A4 N/A A5 2.1.5 CO 2

S Topic is determining shift staffing requirements.

A6 2.1.7 CO 3

S Topic is cause and actions for reactor power anomalies.

A7 2.2.22 EC 3

S Topic is Mode change with EDG2 Inoperable.

A8 2.3.6 RC 3

X E

S Topic is complete radwaste discharge permit for release.

I dont see how you get error bars for the calc in step 4 of JPM (the range would be 16368 - 16369 with rounding).

Licensee did not submit correct JPM. BC commented that this doesnt appear to be SRO only. Licensee stated that it is a post release form that the SM does but agreed to change the JPM to have more operational validity.

Licensee wrote new JPM (rev1) and it is now Sat.

A9 2.4.41 EPP 3

X E

S Topic is EAL classification.

I need a key for this JPM to show the path to the answer.

EAL key uploaded to BOX and put in SP 4/20/2021. With rev1 of this JPM it is now Sat.

1 Simulator/In-Plant Safety Function and K/A JPMs P1 295031 EA1.08 2

S RCA P2 295025 EK1.07 2

S RCA P3 263000 K4.01 2

S RCA S1 201003 A2.03 3

X E

Alt Path.

The numbers for handouts used for the file names are confusing. Should have handouts 1, 2, and 3. Check file

ES-301 Operating Test Review Worksheet Form ES-301-7 Rev. 11 S

names to see what I am saying. Ensure different paper color for handout #3. Also step 2 of the JPM standard states for rod 22-07 to check LPRMs for rod 26-07. I think this is a typo since it is rod 22-07 that is being moved in this step. For JPM standard step 5, it needs to state that rod 22-07 goes from step 46 to step 48. I would like to have a copy of the Alarm response procedure to ensure actions are the same between it and the AOP (especially since applicant may choose to use it instead of AOP).

Copy of ARP sent on 4/20. Waiting on updated JPM now. With rev1 of JPM it is now Sat.

S2 217000 A4.03 3

S Alt path.

S3 241000 A4.06 2

S S4 202001 A4.01 3

X E

S Alt path.

On JPM standard step 15 it states in the procedure that two or more values for vibration must exceed the danger setpoint in order to meet the criteria to trip the pump. The standard for this step in the JPM should be that two or more values for vibration (or all values for vibration) exceed the xxx value for danger alarm setpoint (turns red on screen or danger flags next to point) and requires a pump trip.

With rev1 of JPM it is now Sat.

S5 219000 A4.02 3

E S

Alt path.

First handout should be 2.2.69.3 (and specifically the hard card Att 1). The subsequent procedure needed is procedure 2.2.70.

Procedure references sorted out with licensee and updated to SP file on 4/20/2021. JPM is now Sat.

S6 400000 A2.01 2

S S7 261000 A4.03 3

S Alt path.

ES-301 3

Form ES-301-7 Rev. 11 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 4

Form ES-301-7 Rev. 11 Facility:

CNS Scenario:

N/A Exam Date:

(Retake) June 28, 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

N/A No scenarios for retake exam

ES-301 5

Form ES-301-7 Rev. 11 Site name:

Cooper Nuclear Station Exam Date:

(Retake) June 28, 2021 OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 5

0 2

3 Sim./In-Plant JPMs 10 0

3 7

Scenarios N/A N0/A N/A N/A Op. Test Totals:

15 0

5 10 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).