ML22252A010

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

ML22252A010
Person / Time
Site:	FitzPatrick
Issue date:	09/09/2022
From:	Brian Fuller NRC/RGN-I/DORS/OB
To:	Entergy Nuclear Operations
Shared Package
ML 18163A275	List: ML22252A005 ML22252A010
References
Download: ML22252A010 (1)

Text

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: Exam Date:

1 2 3 4 5 6 ADMIN Attributes Job Content LOD Admin JPMs Topic U/E/S Explanation (1-5) I/C Critical Scope Perf.

and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link COO No JPM Task Standard provided. Added task 17-2 RO COO1 K/A X U standard; added procedure number to cue 2.1.4 sheet; deleted N/R -- SAT COO 17-2 RO K/A S COO2 2.1.7 Motor space heater RBACE5, Breaker #1 (from OP-40)

EC 17-2 RO EC K/A X E needs to be isolated. Revised maintenance to be 2.2.13 intrusive to impeller, but not motor RC Fixed log readings, adjusted range on one 17-2 RO RC K/A E 2.3.5 reading No JPM Task Standard provided. Added task 17-2 SRO COO standard; added procedure number to cue K/A X U COO1 2.1.4 sheet; deleted N/R -- SAT COO Editorial Added note to have SPDES permit 17-2 SRO K/A E available; added note regarding SAT/UNSAT COO2 2.1.7 boxes

- No JPM Task Standard provided.

- JPM step #1 needs to remove ST 21Q as a required reference that must be obtained.

- JPM Standards for steps 2 and 3 do not meet Tech Specs. Reference B.3.7.6-2 top of page is interpreted to be OK to stay at 100% power. Also with TBVs OOS =

EC 17-2 SRO EC K/A X U 3.7.6 not met, therefore all penalties are the same for 2.2.22 MCPR and LHGR (see table 5-4).

Revised wording of part of step 3; added task standard; deleted need for ST-1Q; lowering initial condition to 28% power and gave evaluator note regarding COLR -- SAT

ES-301 Operating Test Review Worksheet Form ES-301-7 Task Standard identified an SAE as the EAL and did not consider a note in the EAL regarding loss of containment. Actual correct answer is an ALERT as EP K/A written. Revised initial conditions and EAL 17-2 SRO EP X U 2.4.40 declaration, added status of NMP units, editorial change to task standard RC K/A No JPM Task Standard provided. Added task 17-2 SRO RC X U 2.3.11 standard, added detail to two steps 1

Simulator/In-Plant Safety Function JPMs and K/A 7 Added two additional procedure steps to end K/A 17-2 A 212000 E of JPM; added detail to initiating cue; added A4.14 to task standard 6

K/A Added evaluator note regarding 17-2B X E 262001 synchroscope A4.04 2 Specified use of Hard Card; deleted extra K/A part of step 5; changed role play in step 7; 17-2C E 217000 A4.01 deleted steps 10 and 11 9

K/A 17-2D S 261000 A4.06 3

K/A Added note about EPIC displays 17-2E E 239001 A4.04 4

K/A Revised JPM to not break vacuum 17-2F X E 245000 A4.06 8

K/A 17-2G S 400000 A4.01 1

K/A Added new procedure step; revised changed 17-2H E 202001 procedure step; edited one examiner cue A4.01

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

K/A Added one cue; modified setup not regarding 17-2I E 202002 need to open panel door 2.1.30 6 Added one examiner cue; changed from K/A 17-2J E safety function 6 to 8 295003 AA1.02 2

K/A 17-2K S 295031 EA1.08

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: Scenario: Exam Date:

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

ES-301 6 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 7 Form ES-301-7 Facility: Exam Date:

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 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 8 Form ES-301-7 Site name: Exam Date:

OPERATING TEST TOTALS Total Total Total  %

Total Explanation Unsat. Edits Sat. Unsat.

Admin.

8 7 JPMs Sim./In-Plant 11 5 JPMs Scenarios 5 0 Op. Test 24 12 50%

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).