ML091050244

CP-2009-03 - Draft Operating Exam Comments

ML091050244
Person / Time
Site:	Comanche Peak
Issue date:	04/03/2009
From:	Ryan Lantz Operations Branch IV
To:	Blevins M Luminant Generation Co
References
50-445/09-301, 50-446/09-301
Download: ML091050244 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process SITE Comanche Peak - YEAR 2009 - MONTH March DRAFT OPERATING TEST COMMENTS ADMIN JPMS

3. Attributes

4. Job Content Errors JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia

5.

U/E/S

6.

Explanation (See below for instructions)

NRC RO/SRO A.1.a S

4 E

5. Both comments are on ES-C-1, Page 7 of 9:

a)

Step 12 - It says that the standard is that the IBW entered should be 11451 +/- 50 pcm. The answer key form says 11415 +/- 50 pcm. Resolve what the correct answer is.

b) b) Step 13 - The Standard says to refer to NDR Table 6.1 to determine the most reactive stuck rod at EOL. The value provided is for the most reactive stuck rod at BOL. Resolve the issue.

NRC RO/SRO A.1.b S

3 E

5. On ES-C-1, Page 4 of 5, Step 3, it refers the applicant to Page 2 of Attachment 5, ABN-104. It is not included in the packet.

NRC RO A.2 D

3 S

NRC RO A.3 S

3 S

NRC SRO A.2 S

3 X

X U

3.

a)

IC - The initiating cue directs the applicant to review the surveillance paperwork. It doesnt direct him/her to mark any changes needed, and where to put such comments.

b)

Critical Steps - In addition to determining that the measured data is not within limits (Step 8.2.1.V of procedure, Step 17 in JPM), this involves not meeting a Surveillance Requirement. It should be part of the critical step that the applicant identifies that Technical Specification Action Required should say Yes on Step 8.2.1.V of the form as well.

5. On ES-C-1, Page 3 of 7, Step 5, it has the applicant identify that the temperature measurement time requirement is not met. It is not stated as an Acceptance Criteria on the form (says N/A), so is this requirement stated in the body of OPT-201A? This is not clear.

NRC SRO A.3 S

3 E

5. On ES-C-1, Page 4 of 5, Step 1, it should denote that the applicant identifies that a LCOAR NRC SRO A.4 S

3 S

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 a 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.

0 Page 2 of 6 OBDI 202 - IOLE Process 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 reviewer=s 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 any U or E rating in the explanation column.

7.

Save initial review comments as normal black text; indicate how comments were resolved using blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

0 Page 3 of 6 OBDI 202 - IOLE Process SITE Comanche Peak - YEAR 2009 - MONTH March DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

3. Attributes

4. Job Content Errors JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia

5.

U/E/S

6.

Explanation (See below for instructions)

RO NRC S-1 D

3 S

RO/SRO NRC S-2 D

3 E

5. Two items:

a)

To complete the JPM, the applicant needs copies of TDM-201A and TDM-203A.

They are not listed in the required materials.

a) b) On ES-C-1, Page 4 of 7, Step 9a (Cross Reference SOP-104A, Section 5.2.6, Step I.), it says set blender flow control to 127 gpm OR to a calculated value. How does the procedure user (applicant) know to use the calculated value or 127 gpm?

There is no criterion stated.

RO/SRO NRC S-3 D

3 S

RO/SRO NRC S-4 D

3 S

RO/SRO NRC S-5 D

3 S

RO/SRO NRC S-6 D

3 S

RO/SRO NRC S-7 D

3 E

5. On ES-C-1, Page 5 of 7, Step 8, there is a cue to direct the applicant to refer to a Job Aide for transferring the Steam Dump Mode to Steam Pressure Mode. There is a step for doing this in ABN-709 (Section 4.3, Step 3), but there is no note in the procedure referring to the Job Aide as an alternate. What is the reason for performing a Job Aide procedure outside the given procedure?

RO/SRO NRC S-8 D

3 S

RO/SRO NRC P-1 D

3 E

5. Two items:

a)

On ES-C-1, Page 5 of 8, Step 9, the applicant is expected to determine that a step is N/A. The procedure copy given to them has it marked that this is N/A already. If it is desired to grade the applicant on whether or not they recognize that this is N/A based on an Initial Condition, then it shouldnt be marked in the procedure copy given to them.

b)

Steps S and T of Section 5.8.1, SOP-607A, are not annotated in the ES-C-1 as steps for grading.

RO/SRO NRC P-2 D

3 X

U

3. Two items:

a)

The Initiating Cue is for the applicant to perform ABN-903, starting at Step 2.3.2.

First, it is Section 2.3, Step 2. Second, it appears that the goal is to have the applicant perform that step only, but the Initiating Cue is written to say take actions starting at that step. The applicant could judge that they need to keep going after this step is complete. There is no examiner cue to stop them from doing so. The

0 Page 4 of 6 OBDI 202 - IOLE Process SITE Comanche Peak - YEAR 2009 - MONTH March DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

3. Attributes

4. Job Content Errors JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia

5.

U/E/S

6.

Explanation (See below for instructions)

Initiating Cue and the content of the JPM need to reviewed and revised to make the actions line up with it, and revise examiners cues as needed.

b)

This JPM is set up to have the content of the JPM completed, stopped, start/complete RO/SRO NRC P-3, and then restart this one for completion. This is stated in the front matter of the JPM, but the examiner cues in the body of the JPM do not clearly state how to handle this logistically. It should be discussed and revised as needed.

Editorial Enhancement - On Form ES-C-1, Page 5 of 7, Step 11, the Examiner Cue should be that the hand wheel is rotated and resistance is felt, vice the valve is closed.

RO/SRO NRC P-3 S

3 E

5. Procedure ABN-305, Attachment 1 doesnt say or show how to reset the overspeed linkage. How is this addressed?

General The format of all of the JPM Task Standards is a statement saying that all critical steps are completed. Shouldnt the Task Standard say what is accomplished when the critical steps are completed (i.e., a system/pump is in service, and inverter is in service, a surveillance is completed, etc.)?

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 a 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 reviewer=s 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 any U or E rating in the explanation column.

7. Save initial review comments as normal black text; indicate how comments were resolved using blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

0 Page 5 of 6 OBDI 202 - IOLE Process SITE Comanche Peak - YEAR 2009 - MONTH March DRAFT OPERATING TEST COMMENTS SCENARIOS Scenario Set

1.

ES

2.

TS

3.

Crit

4.

IC

5.

Pred

6.

TL

7.

L/C

8.

Eff

9.

U/E/S

10. Explanation (See below for instructions) 1 E

9. There are several items:

a)

Add the Heater Drain Pump Seal repairs to the Initial Conditions on the D-1.

b)

D-2, Page 15/19 - One of the ROs actions is that he/she verifies the Turbine Drive Auxiliary Feedwater Pump is RUNNING (Event 5-7). In Event 4 (p.

11/19), the BOP places the steam supply valve to the turbine in PULL-OUT.

These two items should be resolved.

c)

Critical Task for cooldown and depressurization - On the D-1, the Critical Task in question says to Perform actions to cooldown and depressurize the Reactor Coolant System. On the D-2, Page 19/19, it is stated as Cooldown and depressurize the Reactor Coolant System. The actual graded actions go through completing the cooldown only. This would cause a conflict in evaluating to the Critical Task.

2 E

9. There are three items:

a)

Based on the definition of Critical Task discussion in NUREG-1021, the emergency boration cannot be called one. Even if the RO did not see the rods on the bottom via DRPI and didnt take this action, the rods would be on the bottom in a safe configuration.

b)

Recommend replacing Events 5-8 with two Major events (Loss of Offsite Power and Loss of All AC Power), followed by EDG failures as a Component Failure.

Recommend loss of EDG 1-01, and EDG 1-02 operational with output breaker failing to close due to voltage regulator issue.

c)

For Event 2, there needs to be consideration for whether the following transient would result in a change from Mode 2 to Mode 1 without having the preparations in place to account for this. The direction to the crew is to take power to 2% and hold (Mode 2). If the subsequent feed recovery results in a power increase above 5%, this needs to be accounted for in the scenario.

3(B/U)

E

9. In the D-1 and D-2, Events 1 and 2 are related to TI-421A and LT-554, respectively.

On the Scenario Summary NRC #3, it says that Events 1 and 2 are associated with TI-421B and a feed flow instrument. The inconsistencies need to be fixed in the documents.

General Comment s

X

1)

On the ES-301-5, minimum required event types are not accounted for with each applicant. SROI-1, 2, 3 and RO-4 have no Reactivity manipulations, and RO-1,2,3 and RO-5 have no Normal operations. Resolve this with the scenario outlines.

2)

Form ES-301-6 is meant to show where each applicant/applicant group will be taking actions related to each competency. The change in format to showing where competencies are addressed by crew position versus application type makes it unclear on how the intent of this form is being addressed. The reason for this change needs to be discussed, and issues resolved accordingly.

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

0 Page 6 of 6 OBDI 202 - IOLE Process SITE Comanche Peak - YEAR 2009 - MONTH March DRAFT OPERATING TEST COMMENTS SCENARIOS 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 reviewer=s judgment, rate the scenario set as (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.

11. Save initial review comments as normal black text; indicate how comments were resolved using blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.