Text

Columbia Generating Station - Initial Exam - 10/2002 - Draft Exam Comments
	ML030360488
Person / Time
Site:	Columbia
Issue date:	04/11/2002
From:	Gody A; NRC Region 4
To:	Parrish J; Energy Northwest
References
	50-397/02-301
	Download: ML030360488 (26)
	v • d • e

Columbia Generating Station October 2002 Initial Licensed Operator Operating Test Review Reviewer: Ryan Lantz Chief Examiner: Tom Stetka

1) Admin Section Senior Operator

SA.1-1JPMr0 The applicant may argue the load can be moved, since the LCS states that crane travel over fuel assemblies stored in the fuel storage pool shall be within the limits of Fig. 1.9.2-1. The given load is within those limits, if the load is moved over the pool less than about 3 inches above the water surface. The JPM key says the load cannot be moved, and I assume it is becasue the load must be lifted over the handrail, which is probably about 3 -4 feet tall. The applicant can argue that the handrail is not above any assemblys, and for some distance into the pool, there are no assemblys. This would seem to be a reasonable interpretation, otherwise Figure 1.9.2-1 should not allow any lifts that would only be allowed if carried less than the rail height.

Also, the JPM is very simple otherwise. Consider not giving the reference as part of the cue. This would increase the complexity by requiring the applicant to find the appropriate reference. I would also have the intial conditions be verifiable in the simulator (CR ventilation, rad monitors operable) so minimal cuing would be needed, and this is another evaluation area.

SA.1-2JPMr0 Change the initiating cue simply to You are the offgoing CRS/RO. Given the initial conditions and using the simulator in freeze, prepare for and conduct a turnover with the examiner as the oncoming CRS/RO. There are no malfunctions other than those given in the initial conditions. The examiner will cue you on areas that will be simulated. Complete any required documentation to support the turnover.

This allows the applicant to show his knowledge of how to conduct a turnover, and the examiner has flexibility to discuss the turnover and simulate areas, such as the board walkdowns.

Otherwise, the task is very simple, and only focuses on the ability to fill blanks on a form.

BA.2JPMr0 I see no reason to give the reference in the cue. Change the cue to read: Using plant drawings, explain the purpose of.....

SA.3JPMr0 This task is too simple as given. The task should not cue that an Increased Exposure request is needed. The situation (valve flushing) should be evaluated by the applicant as the individuals supervisor, for approval or authorization, to test if he recognizes the task will result in exceeding administrative control limits. Then, it can be asked what must be done to complete the valve flushing? Can this operator peform the flush, or must another operator be identified

who will not exceed dose limits?

SA.4JPMr0 The time critical nature should be clarified. In the initiating cue, the applicant should be requested to determine if an emergency classification change is required, and if so, complete a CNF form as needed. He should also be told that the task is time critical for both identifying the classification change and completing the form. (15 minutes to declare the SAE, and 15 minutes to complete the form)

Reactor Operator

RA.1-1JPMr0 The task is too simple if the applicant is told what references to use. In the initiating cue, remove reference to PPM 3.1.2 and the power to flow map. Simply state Given the initial conditions as stated, determine if it is allowable to enter the Area of Increased Awareness.

Justify your answer.

No comments for questions RA.3-1, .3-2, .4-1, .4-2.

Columbia Generating Station October 2002 Initial Licensed Operator Operating Test Review Reviewer: Ryan Lantz Chief Examiner: Tom Stetka

1) Admin Section Senior Operator

SA.1-1JPMr0 The applicant may argue the load can be moved, since the LCS states that crane travel over fuel assemblies stored in the fuel storage pool shall be within the limits of Fig. 1.9.2-1. The given load is within those limits, if the load is moved over the pool less than about 3 inches above the water surface. The JPM key says the load cannot be moved, and I assume it is becasue the load must be lifted over the handrail, which is probably about 3 -4 feet tall. The applicant can argue that the handrail is not above any assemblys, and for some distance into the pool, there are no assemblys. This would seem to be a reasonable interpretation, otherwise Figure 1.9.2-1 should not allow any lifts that would only be allowed if carried less than the rail height.

Also, the JPM is very simple otherwise. Consider not giving the reference as part of the cue. This would increase the complexity by requiring the applicant to find the appropriate reference. I would also have the intial conditions be verifiable in the simulator (CR ventilation, rad monitors operable) so minimal cuing would be needed, and this is another evaluation area.

RESOLUTION JPM revised clarify intent and prevent confusion. References removed from cue.

SA.1-2JPMr0 Change the initiating cue simply to You are the offgoing CRS/RO. Given the initial conditions and using the simulator in freeze, prepare for and conduct a turnover with the examiner as the oncoming CRS/RO. There are no malfunctions other than those given in the initial conditions. The examiner will cue you on areas that will be simulated. Complete any required documentation to support the turnover.

This allows the applicant to show his knowledge of how to conduct a turnover, and the examiner has flexibility to discuss the turnover and simulate areas, such as the board walkdowns.

Otherwise, the task is very simple, and only focuses on the ability to fill blanks on a form.

RESOLUTION JPM revised to incorporate the suggested changes.

BA.2JPMr0 I see no reason to give the reference in the cue. Change the cue to read: Using plant

drawings, explain the purpose of.....

RESOLUTION JPM revised to incorporate the suggested changes.

SA.3JPMr0 This task is too simple as given. The task should not cue that an Increased Exposure request is needed. The situation (valve flushing) should be evaluated by the applicant as the individuals supervisor, for approval or authorization, to test if he recognizes the task will result in exceeding administrative control limits. Then, it can be asked what must be done to complete the valve flushing? Can this operator peform the flush, or must another operator be identified who will not exceed dose limits?

RESOLUTION Completely revised JPM to involve a dose release in lieu of a planned exposure. Revision acceptable.

SA.4JPMr0 The time critical nature should be clarified. In the initiating cue, the applicant should be requested to determine if an emergency classification change is required, and if so, complete a CNF form as needed. He should also be told that the task is time critical for both identifying the classification change and completing the form. (15 minutes to declare the SAE, and 15 minutes to complete the form)

RESOLUTION JPM revised to incorporate the suggested changes.

Reactor Operator

RA.1-1JPMr0 The task is too simple if the applicant is told what references to use. In the initiating cue, remove reference to PPM 3.1.2 and the power to flow map. Simply state Given the initial conditions as stated, determine if it is allowable to enter the Area of Increased Awareness.

Justify your answer.

RESOLUTION Following review of the JPM with the licensee, no changes were considered to be necessary.

No comments for questions RA.3-1, .3-2, .4-1, .4-2.

S:\DRS\OB\EXAMS\Cgs\October 2002 Exam\CGS-INIT EXAM-10-2002\CGS-10-2002-NRC DRAFT EXAM COMMENTS\AppEJPMQualityReview.wpd APPENDIX E - REGION IV OPERATING TEST JOB PERFORMANCE MEASURE QUALITY REVIEW MATRIX

1. 2. 3. Attributes 4. Job Content 5. 6.

JPM# Dyn LOD Errors U/E/S Explanation (D/S) (1-5) (See below for instructions)

IC Cues Critical Scope Over- Job- Minutia Focus Steps (N/B) lap Link B.1a D 2 S Is Step 4 critical? What happens if controller adjusted to 80% open? WILL CHECK For Step 7, what is the acceptable range of flows? Step 8 procedure step should be 5.1.14. This JPM is Safety Function 9 NOT 5.

B.1b D 2 S Step 4 has the incorrect procedure specified. It should be PPM 2.5.7 Main Turbine Generator.

Should there be a range (e.g., 70 psig)? WILL CHECK B.1c D 2 S If Step 2 is critical, why isnt Step 1 also critical? Per 1021 App C, Step 4 is not critical. Should Step 7, Substep 3 also be critical?

B.1d D 3 E Should the cue contain the procedure number and section to be used to startup RCIC or is this an expected action to be done from memory? WILL REVIEW Step 8, Substep a, has the wrong valve number - should be RCIC-V-45. Why is Step 6 crit? WILL MAKE NOT CRIT B.1e D 3 S Step 1 is not a critical task (appears to be a simple verification step). Step 5 needs clarification AGREE B.1f D 2 S I dont believe Step 5 is critical? Why couldnt you leave the controller is manual? Not concerned with a constant rod drive speed. NOT CRITICAL - WILL CHANGE B.1g D 3 E Step 1 - the procedure step should be 5.3.8. For Step 8, need to know what expected drywell pressure should be and what is the expected system response - how long would it take to see a change in drywell pressure and how rapidly would pressure fall? For Step 10, how long to get to 0.5 psig and what is the target ROA purge supply and SGT flow rates? WILL REVIEW AND CHANGE Step 10 TO CLARIFY CUE AND MAKE SHORTER B.2a S 3 S Step 8 - should this step contain a cue, since this was given as part of the initial conditions? WILL MAKE AN EXAM NOTE B.2b S 2 S Step 3, BOLD critical steps and add cue RE: UV, UF,lights and POWER OUT light.

B.2c D 3 S For Step 2, should the examiner cue read, HPSC-P-2 is running? For Steps 4 & 5, include annunciator noun name for drop 1.1, 3.1, 6.8. For Step 8, how do the operators verify the air start motors are disengaged - include this as a note in the cue (since this is a critical task). Step 7, BOLD CT. Step 6s OK FOR ALL Spare S 3 E The JPM Setup Information and the Student Information Sheet/Cue needs to be corrected. The cue LR258 talks about venting Control Rod 30-03, but the cue tells the candidate to inform the CRS when Rod 26-11 venting is complete. Need to change Rod 26-11 to Rod 30-03 in both locations. WILL CORRECT Spare S 2 S I dont believe Step 2 is critical, because it is already open and is simply a verification step. AGREE LR208

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Instructions for Completing Matrix This form is not contained in or required by NUREG-1021. Utilities are not required or encouraged to use it. The purpose of this form is to enhance regional consistency in reviewing operating tests. Additional information on these areas may be found in Examination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided.

1. Determine whether the task is dynamic (D) or static (S). A dynamic task is one that involves continuous monitoring and response to varying parameters. A static task is basically an system reconfiguration or realignment.

2. Determine level of difficulty (LOD) using established 1-5 rating scale. Levels 1 and 5 represent inappropriate (low or high) discriminatory level for the license being tested.

3. Check the appropriate box when an attribute weakness is identified:

The initiating cue is not sufficiently clear to ensure the operator understands the task and how to begin.

The JPM does not contain sufficient cues that are objective (not leading).

All critical steps (elements) have not been properly identified.

Scope of the task is either too narrow (N) or too broad (B).

Excessive overlap with other part of operating test or written examination.

4. Check the appropriate box when a job content error is identified:

Topics not linked to job content (e.g., disguised task, not required in real job).

Task is trivial and without safety significance.

5. Based on the reviewers judgment, is the JPM as written (U)nacceptable (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

6. Provide a brief description of problem in the explanation column. Provide conclusion on whether JPM SET criteria satisfied (i.e., number/distribution of safety functions, A.3 and A.4 integrated with parts B/C, Admin topics per section meet ES).

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S:\DRS\OB\EXAMS\Cgs\October 2002 Exam\CGS-INIT EXAM-10-2002\CGS-10-2002-NRC DRAFT EXAM COMMENTS\AppEJPMQualityReviewComment .wpd APPENDIX E - REGION IV OPERATING TEST JOB PERFORMANCE MEASURE QUALITY REVIEW MATRIX (COMMENT RESOLUTION)

1. 2. 3. Attributes 4. Job Content 5. 6.

JPM# Dyn LOD Errors U/E/S Explanation (D/S) (1-5) (See below for instructions)

IC Cues Critical Scope Over- Job- Minutia Focus Steps (N/B) lap Link B.1a D 2 S The JPM was replaced because original JPM was used on audit examination.

B.1b D 2 S Step 4 revised to reference correct procedure. A hydrogen range is not needed, however, a load reduction range was added.

B.1c D 2 S Steps 1, 2 and 4 changed to not critical. Step 7, Substep 3 changed to critical.

B.1d D 3 S Procedure number and section for RCIC startup added to cue. Step 8, Substep a, valve number corrected. Step 6 changed to not critical.

B.1e D 3 S New JPM due to audit exam overlap.

B.1f D 2 S Changed Step 5 to a non-critical step.

B.1g D 3 S Step 1procedure step corrected. For Step 8, as a result of discussions with the licensee, the length of time is dependent on control settings and, therefore, cannot be stated as a specific value. Step 10 was changed to clarify the cue.

B.2a S 3 S Step 8 changed to an exam note.

B.2b S 2 S Revised Step 3.

B.2c D 3 S Examiner cue HPSC-P-2 is running added to Step 2. Annunciator titles added to Steps 4 and 5.

For Step 8, air start motors failure to disengage narrative added. Renumbered steps such that old Step 7 is now Step 8 and CT made bold.

Spare S 3 S JPM corrected to indicate that the affected control rod is 30-03.

LR258 Spare S 2 S Changed Step 2 to not critical.

LR208

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Instructions for Completing Matrix This form is not contained in or required by NUREG-1021. Utilities are not required or encouraged to use it. The purpose of this form is to enhance regional consistency in reviewing operating tests. Additional information on these areas may be found in Examination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided.

1. Determine whether the task is dynamic (D) or static (S). A dynamic task is one that involves continuous monitoring and response to varying parameters. A static task is basically an system reconfiguration or realignment.

2. Determine level of difficulty (LOD) using established 1-5 rating scale. Levels 1 and 5 represent inappropriate (low or high) discriminatory level for the license being tested.

3. Check the appropriate box when an attribute weakness is identified:

The initiating cue is not sufficiently clear to ensure the operator understands the task and how to begin.

The JPM does not contain sufficient cues that are objective (not leading).

All critical steps (elements) have not been properly identified.

Scope of the task is either too narrow (N) or too broad (B).

Excessive overlap with other part of operating test or written examination.

4. Check the appropriate box when a job content error is identified:

Topics not linked to job content (e.g., disguised task, not required in real job).

Task is trivial and without safety significance.

5. Based on the reviewers judgment, is the JPM as written (U)nacceptable (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

6. Provide a brief description of problem in the explanation column. Provide conclusion on whether JPM SET criteria satisfied (i.e., number/distribution of safety functions, A.3 and A.4 integrated with parts B/C, Admin topics per section meet ES).

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S:\DRS\OB\EXAMS\Cgs\October 2002 Exam\CGS-INIT EXAM-10-2002\CGS-10-2002-NRC DRAFT EXAM COMMENTS\AppNScenarioMatrixComment .wpd APPENDIX N - REGION IV OPERATING TEST SCENARIO REVIEW MATRIX (COMMENT RESOLUTIONS)

Scen 1 2 3 4 5 6 7 8 9 10 Explanation (See below for instructions)

Set ES TS Crit IC Pred TL L/C Eff U/E/S S Changed to reflect the 5 CTs. Added time line. Scenario details revised 1 to specify which EOP the crew is in.

2 S Changed to reflect 3 CTs. Added time line. Power reduction position identified. Scenario details revised to specify which EOP the crew is in.

3 S Changed to reflect 4 critical tasks. Added time line. End of scenario is not marked. Scenario details revised to specify which EOP the crew is in. Added high vibs on recirc pump as the credible preceding event for the large break LOCA.

Spare 1 S Changed to reflect 2 critical asks. Added time line. Added TS details in Event 2. This scenario could conflict with scenario 1 because of the earthquake.

Spare 2 S Made a new scenario because scenario was used on audit exam.

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APPENDIX N - REGION IV OPERATING TEST SCENARIO REVIEW MATRIX (COMMENT RESOLUTIONS)

Instructions for Completing Matrix This form is not contained in or required by NUREG-1021. Utilities are not required or encouraged to use it. The purpose of this form is to enhance regional consistency in reviewing operating test scenario sets. Additional information on these areas may be found in Examination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided.

1. ES: ES-301 checklists 4, 5, & 6 satisfied.

2. TS: Set includes SRO TS actions for each SRO, with required actions explicitly detailed.

3. Crit: Each manipulation or evolution has explicit success criteria documented in Form ES-D-2.

4. IC: Out of service equipment and other initial conditions reasonably consistent between scenarios and not predictive of scenario events and actions.

5. Pred: Scenario sequence and other factors avoid predictability issues.

6. TL: Time line constructed, including event and process triggered conditions, such that scenario can run without routine examiner cuing.

7. L/C: Length and complexity for each scenario in the set is reasonable for the crew mix being examined, such that all applicants have reasonably similar exposure and events are needed for evaluation purposes.

8. Eff: Sequence of events is reasonably efficient for examination purposes, especially with respect to long delays or interactions.

9. Based on the reviewers judgment, is the scenario set as written (U)nacceptable (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

10. Provide a brief description of problem in the explanation column

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S:\DRS\OB\EXAMS\Cgs\October 2002 Exam\CGS-INIT EXAM-10-2002\CGS-10-2002-NRC DRAFT EXAM COMMENTS\AppNScenarioReviewMatrix-R1.wpd APPENDIX N - REGION IV OPERATING TEST SCENARIO REVIEW MATRIX Scen 1 2 3 4 5 6 7 8 9 10 Explanation (See below for instructions)

Set ES TS Crit IC Pred TL L/C Eff U/E/S X S On Form ES-D-1, for events 6, 7 and 8, need to specify which operator 1 will get credit for the failure after M for bean count. Appears to be at least 8 critical tasks verses 5 listed on Form ES-301 may be too many. There is no time line. Scenario details need to specify which EOP the crew is in - not clear when they transition. Need necessary procedure pages only.

2 X S Appears to be at least 10 critical tasks verses the 3 listed on Form ES-301 too many. There is no time line. Who does the power reduction? Power reduction shows up in Events 2 and 3. For Event 8, two steps are marked as critical, but there is a note that says the actions may not be necessary - need to clarify. Scenario details need to specify which EOP the crew is in - not clear when they transition.

3 X S For Event 3, the listed critical tasks does not appear to be a critical task.

Appears to be at least 9 critical tasks verses the 3 listed on Form ES-301-4. There is no time line. Scenario details need to specify which EOP the crew is in - not clear when they transition. End of scenario is not marked. What is the credible preceding event for the large break LOCA? Will add high vibs on recirc pump will be preceding event.

Spare 1 X S There is no time line. There are 4 critical tasks verses the 2 listed on form ES-301-4. Need TS details in Event 2. This scenario could conflict with scenario 1 because of the earthquake.

Spare 2 X S There is no time line. There are 5 critical tasks verses the 3 listed on form ES-301-4. For Event 8, is failure to manually open PCB 4885 really a critical task? This scenario could conflict with scenario 2 because of the ATWAS repeat.

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APPENDIX N - REGION IV OPERATING TEST SCENARIO REVIEW MATRIX Instructions for Completing Matrix This form is not contained in or required by NUREG-1021. Utilities are not required or encouraged to use it. The purpose of this form is to enhance regional consistency in reviewing operating test scenario sets. Additional information on these areas may be found in Examination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided.