ML21334A012

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GG 2021-10 Draft Op Test Comments
ML21334A012
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/25/2021
From: Heather Gepford
Operations Branch IV
To:
Entergy Operations
References
Download: ML21334A012 (16)


Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Rev. 11 Facility: Grand Gulf Exam Date: October 18, 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.

General comments:

1. Per NUREG must always submit a key for math and graphs. Show your work.
2. Please provide KAs on ES-301-1 forms for each admin JPM.
3. Remove SRO only aspect on RO ES-301-1 form for JPM AR4.
4. B careful with cueing on the JPMs.

A1 G2.1.25 3

X X

X U

S Unsat for incorrect task standard and critical step(s).

1.

Task standard says to use

2.

JPM step 1 states to use,

3.

JPM step 2 states to use at top of page and Attachment 8 in body of step,

4.

The actual attachment in the Key states it is Attachment 1.

Need to correct all that are incorrect.

I believe Attachment 8 is correct.

Licensee made corrections and JPM is now Sat.

A2 2.2.13 2

S Validation week changes included changing Val time to 20 minutes, added Evaluator note to Task Standard about one fuse for both dampers. Changed KEY Place Seq. for breaker to 2/3.

A3 2.1.25 3

X U

S No Key with Attachment 29 provided.

Licensee submitted a key and JPM is now Sat.

A4 2.3.4 2

S AS1 (SRO) 2.1.34 3

S

ES-301 Operating Test Review Worksheet Form ES-301-7 Rev. 11 AS2 (SRO) 2.1.25 3

X U

S Task standard is incorrect with yellow risk. Risk level is orange as listed on page 4 of table 2 on page 44 of the provided reference.

Licensee made corrections and JPM is now Sat.

AS3 (SRO) 2.2.12 3

S Val week changed discrepancy #1 to not critical.

AS4 (SRO) 2.3.13 2

X E

S Remove the cue for what procedure you use and just ask them what actions need to be taken?

Licensee made corrections and JPM is now Sat.

AS5 (SRO) 2.4.41 3

E S

Requested EAL tables in larger format during initial exam call. These are needed to review this JPM. These were not provided in the reference file folder for this JPM either.

Val week change - removed the completion of Notification form as a task.

Licensee made corrections and JPM is now Sat.

1 2

LOD (1-5) 3a I/C 3b Cues 3c Critical 3d Scope 3e Overlap 3f Perf.

3h Key 4a Minutia 4b Job Link 5

U/E/S 6

Explanation Simulator/In-Plant Safety Function and K/A JPMs General comments for all JPMS S1 1 (201001 A4.01) 3 X

E Nice job on this new JPM.

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

JPM step 9 should not cue to step A1. It should state CRS directs you to restore CRD IAW the hard card correct? Yes.

Val week comment - Added words for indications of pump seizure in step 6.

Licensee made corrections and JPM is now Sat.

S2 2 (217000 A2.01) 3 X

X E

S Step 4 of JPM is not critical - no actions taken there. Step 6 of JPM-the cue should be start RCIC IAW the hard card, right? Step 9 start GS compressor not listed as critical step but you have it in the task standard-if it is not critical then should not have it in task standard.

Licensee removed GS from critical step/task standard because it is not critical.

Licensee made corrections and JPM is now Sat.

S3 3 (241000 A1.13) 3 X

S S4 4 (205000 A2.10) 3 X

X E

S Step 3 is critical step but not in task standard and should be.

Val week comments - added When High Temp is received to task standard.

Licensee made corrections and JPM is now Sat.

S5 5 (223001 A2.11) 2 X

E S

Task standard has typo - needs to say Division 1 and Division 2 (not Div 1 and Div 1).

Val week comment - Changed Initiating Cue to state BOTH systems.

Licensee made corrections and JPM is now Sat.

S6 8 (400000 K1.02) 2 S

Val week comment - Changed validation time from 10 minutes to 5 minutes.

S7 9 (233000 A1.06) 2 S

Val week comment - Changed validation time from 10 minutes to 5 minutes.

S8 7 (201005 A4.01) 3 S

Val week comment - Changed handout material to complete upfront steps and Initiating CUE to begin with step 5.3.2.

P1 6 (264000 A4.03) 3 X

E For this JPM it is more valid to give them the alarm panel picture with the alarms lit instead of reading the alarms to them that are in. This is cueing per NUREG (so change cue for JPM step 3). Also,

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

can they use the ARI book at the machine to look up actions instead of the examiner handing them a lot of handouts? On JPM step 7, it is critical that they perform this step even though it doesnt help in this situation, they dont know that and it could work in other situations. Add to task standard and asterisk this step in the JPM.

Licensee made these changes.

Val week comments - Changed CUE in step 2 to Green light ON. Re-worded CUE in step 5 to Diesel engine is still running.

Licensee made corrections and JPM is now Sat.

P2 8 (286000 A1.05) 3 S

P3 7 (295016 AA1.07) 2 S

ES-301 5

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 6

Form ES-301-7 Rev. 11 Facility: Grand Gulf General comments on scenarios Exam Date: Oct 18, 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 General Comments for all scenarios

1.

For parameters to record for grading purposes, we will need to work thru the required parameters to capture for scenarios for grading during validation week.

ES-301 7

Form ES-301-7 Rev. 11 Facility: Grand Gulf Scenario: 1 Exam Date: Oct 18, 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 Scenarios looked good-all comments found during validation were resolved during validation week.

1 3

S 2

3 S

3 3

S 4

3 S

5 3

S 6

3 S

7

ES-301 8

Form ES-301-7 Rev. 11 Facility: Grand Gulf Scenario: 2 Exam Date: Oct 18, 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 Scenarios looked good-all comments found during validation were resolved during validation week.

1 3

S 2

3 S

3 3

S 4

3 S

5 3

S 6

3 S

7 3

S 8

3 S

9 3

S 10 3

S

ES-301 9

Form ES-301-7 Rev. 11 Facility: Grand Gulf Scenario: 3 Exam Date: Oct 18, 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 Scenarios looked good-all comments found during validation were resolved during validation week.

1 2

S 2

2 S

3 3

S 4

3 S

5 3

S 6

3 S

7 3

S 8

3 S

ES-301 10 Form ES-301-7 Rev. 11 Facility: Grand Gulf Scenario: 4 (spare) Exam Date: Oct 18, 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 Scenarios looked good-all comments found during validation were resolved during validation week.

1 3

S 2

3 S

3 3

S 4

3 S

5 3

S 6

3 S

7 3

S 8

3 S

9 3

S

ES-301 11 Form ES-301-7 Rev. 11 Facility: Grand Gulf Exam Date: Oct 18, 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 1

7 0

2 0

3 0

0 S

2 10 0

2 0

2 0

0 S

3 8

0 3

0 2

0 0

S 4

9 0

2 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.

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.

2 + 4 + 6 1 + 3 + 5100%

ES-301 12 Form ES-301-7 Rev. 11 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 13 Form ES-301-7 Rev. 11 Site name: Grand Gulf Exam Date: OctT 18, 2021 OPERATING TEST TOTALS Total Total Unsat.

Total Total Unsat.

Explanation Edits Sat.

Admin.

JPMs 9

3 3

3 Send keys to show work for conclusions to the answers. Also, must match task standard to critical steps and ensure task standards are correct.

Licensee corrected all of these items including validation comments.

Sim./In-Plant JPMs 11 0

6 5

Scenarios 4

0 0

4 Op. Test Totals:

24 3

9 12 12.5%

Satisfactory submittal.

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).

Changes from NRC Validation Week GJPM-OPS-10-2021AR1:

NO CHANGE GJPM-OPS-10-2021AR2:

Rev 02, NRC Validation Comments, Changed Val time to 20 minutes, added Evaluator note to Task Standard about one fuse for both dampers. Changed KEY Place Seq. for breaker to 2/3.

GJPM-OPS-10-2021AR3:

NO CHANGE GJPM-OPS-10-2021AR4:

NO CHANGE GJPM-OPS-10-2021AS1:

NO CHANGE GJPM-OPS-10-2021AS2:

NO CHANGE GJPM-OPS-10-2021AS3:

Rev 02, NRC Validation Comments, Changed discrepancy #1 to not critical.

GJPM-OPS-10-2021AS4:

Rev 02, NRC Validation Comments, Added steps A1 and A2 of the ONEP to task standard.

Corrected Student Handout Cue. Changed wording on last bullet of Task Standard, use.

GJPM-OPS-10-2021AS5:

Rev 02, Removed the completion of Notification form as a task.

GJPM-OPS-10-2021P1 Rev 03, NRC Validation Comments, Changed CUE in step 2 to Green light ON. Re-worded CUE in step 5 to Diesel engine is still running.

GJPM-OPS-10-2021P2 NO CHANGE GJPM-OPS-10-2021P3 NO CHANGE GJPM-OPS-10-2021S1 Rev 03, NRC Validation Comments, Added words for indications of pump seizure in step 6.

GJPM-OPS-10-2021S2 NO CHANGE GJPM-OPS-10-2021S3 NO CHANGE GJPM-OPS-10-2021S4 Rev 03, NRC Validation Feedback, added When High Temp is received to task standard.

GJPM-OPS-10-2021S5 Rev 03, NRC Validation Feedback, Changed Initiating Cue to state BOTH systems.

GJPM-OPS-10-2021S6 Rev 02, NRC Validation Feedback, Changed validation time from 10 minutes to 5 minutes.

GJPM-OPS-10-2021S7 Rev 02, NRC Validation Feedback, Changed validation time from 10 minutes to 5 minutes.

GJPM-OPS-10-2021S8 Rev 02, NRC Validation Feedback, Changed handout material to complete upfront steps and Initiating CUE to begin with step 5.3.2.

All Simulator Scenarios were changed as requested.

ES-301-2, SRO-U was changed and JPM replaced.

ES-401-4, Rejected KAs, changed on update of written exam.

NRC Exam Schedule changed to allow 3 crews and one less day.

Added document Changed from NRC Validation Week