ML22025A372

NRC Comments on Draft Licensee-Developed Operating Test (Folder 2)

ML22025A372
Person / Time
Site:	Limerick
Issue date:	01/25/2022
From:	Brian Fuller Operations Branch I
To:	Exelon Generation Co
Shared Package
ML19098B511	List: ML21043A207 ML21043A220 ML21050A084 ML21050A119 ML22025A372
References
Download: ML22025A372 (10)

Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: LIMERICK Exam Date: DECEMBER 2019 1 2 3 4 5 6 Attributes Job Content ADMIN Topic LOD Admin JPMs U/E/S Explanation and K/A (1-5) I/C Critical Scope Perf. Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link Administrative Actions on a G2.1.7 3 S Thermal Limit Violation Loss of MCR G2.1.25 3 S Annunciators Evaluate Jet Pump G2.2.37 2 S Operability Radioactive Substance G2.2.14 2 S Spill Administrative Actions on a G2.1.7 3 S Thermal Limit Violation Loss of MCR G2.1.25 3 S Annunciators Evaluate Jet Pump G2.2.37 3 S Operability Transportation Accident Involving G2.3.14 2 S Radioactive Material ERP Classification G4.4.41 3 S and Reporting (Time Critical)

ES-301 Operating Test Review Worksheet Form ES-301-7 1

Simulator/In-Plant Safety Function JPMs and K/A Resetting ASD 1 2 S Speed Hold 202002A1.01 Correct FWLCS Feed Flow 2 2 S Error 259002A2.02 Main Turbine 3

Bypass Valve 3 S 241000A4.06 Exercising HPCI Manual 4 3 S Slow Start 206000A4.12 Perform a Unit 1 Group 2A 5 2 S NSSSS 223002A4.03 Isolation Reset Shutdown the 6

D11 Diesel 3 S 264000A4.04 Generator Transfer RHRSW from 8 2 S Bypass to 400000A4.01 Spray Swap of in 9

service RERS 2 S 288000A4.01 Fans HPCI / RCIC High Area 2

Temperature 3 S 217000A2.10 Isolation Bypass T-363, Vent 6

Main Generator 2 S 295003AK2.06 During ELAP Start ESW 8 2 S Pump Per SE-1 400000A2.01

ES-301 3 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 4 Form ES-301-7 Facility: LIMERICK Scenario: 4056E Exam Date: DECEMBER 2019 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 X S 5 S 6 X S 7 S 8 S 9 X S 10 S

ES-301 5 Form ES-301-7 Facility: LIMERICK Scenario: 4056E Exam Date: DECEMBER 2019 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 X S 5 S 6 X S 7 S 8 S 9 X S 10 S

ES-301 6 Form ES-301-7 Facility: LIMERICK Scenario: 4159E Exam Date: DECEMBER 2019 6213E 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 S 4 X S 5 X S 6 X S 7 X S 8 X S

ES-301 7 Form ES-301-7 Facility: LIMERICK Scenario: 4159E Exam Date: DECEMBER 2019 7017E 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 X S 7 S 8 X S

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: LIMERICK Exam Date: DECEMBER 2019 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 SEG-4056E 10 0 2 0 2 0 0 S SEG-4159E 8 0 2 0 2 0 0 S SEG-6213E 8 0 2 0 3 0 0 S SEG-7017E 8 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.

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: LIMERICK Exam Date: DECEMBER 2019 OPERATING TEST TOTALS Total Total Total  %

Total Explanation Unsat. Edits Sat. Unsat.

Admin.

9 0 0 9 JPMs Sim./In-Plant 11 0 0 11 JPMs Scenarios 4 0 0 4 Op. Test 24 0 0 24 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).