ML091490499

2009-03 - Draft OP Test Comments

ML091490499
Person / Time
Site:	Fort Calhoun
Issue date:	03/27/2009
From:	Brian Larson NRC Region 4
To:	Omaha Public Power District
References
50-285/09-301, FC-2009-03 50-285/09-301
Download: ML091490499 (6)

Text

FC - 2009 - 03 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

JPM# Dyn LOD Explanation U/E/S (D/S) (1-5) IC Cues Critical Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link RO (A1) 1. Title should be Calculate Shutdown Margin with Inoperable CEAs (match 301-1) Done

2. NUREG 1021 Appendix C requires all JPMs must have a clearly identified Task Standard (B.3) Done

3. Appendix C requires JPMs to have Initial Conditions AND Initiating Cues (B.1) Done

4. JPMs need Answer Keys when possible Done

5. JPM coversheet should identify whether Time Critical or Alternate Path (Yes/No) Done

6. Performance Standards and Task Standards are written in past tense. Done E

7. Initiating Cues should/shall include references to appropriate steps in appropriate procedures/attachments (just like in real life). If given direction to complete an action already started, the handout shall include appropriate initials/signatures/etc. Done

8. Provide a copy of all reference/handout material in order to validate the JPM. Done

9. On JPM coversheet - differentiate between references and handouts. Done

10. Step 3 - not Critical? No

11. Step 4 - what is basis of range? changed RO (A2) 1. See 2-9 above Done E

2. Steps 1 & 2 - what is basis of range? changed RO (A3) 1. See 2-9 above Done E

RO (A4) 1. See 2-9 above Done

2. No Critical Steps? Fixed U 3. Initiating Cue is not written as a directive. How is applicant supposed to know where he is supposed to go inside the RCA - what maps to review - what to discuss with RP? Fixed

4. What are the initial conditions? LOCA in progress? RHR in service? Fixed SRO (A5) 1. See 2-9 above Done E

2. Change title to Review Shutdown Margin Calculation with Inoperable CEAs Done SRO (A6) 1. See 2-9 above Done E

2. Use bullets for listing information in Initial Conditions. Done SRO (A7) 1. See 2-9 above Done E

SRO (A8) 1. See 2-9 above Done E 2. What is Ops Department expectations of the CRS/SM if errors are found on Attachment 4? Not authorize release SRO (A9) 1. See 2-9 above Done E 2. Identify regulatory requirement and/or commitment for 15 minutes to classify the event.

Revised 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 1 of 6 OBDI 202 - IOLE Process

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 2 of 6 OBDI 202 - IOLE Process

FC - 2009 - 03 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

JPM# Dyn LOD Explanation U/E/S (D/S) (1-5) IC Cues Critical Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. Renumber as S1 - see Draft Outline Comments Done

2. Need page 4 of OP-ST-CEA-0003 with initials/date for pre-reqs Done

3. Step 13 - does procedure steps 5.1 and 5.13 apply? Yes What procedure directs the Mode Selector Switch to be placed in OFF? OI-RR-1 Add ref to list on JPM coversheet.

J1 D 2 E Done

4. Add steps to JPM for all NOTES and CAUTIONS - Applicant reviewed NOTE/CAUTION This is applicable to all JPMs. Done where practical

1. Renumber as S2 Done J2 E 2. Verify if all valve manipulations are Critical Steps. Done

1. Renumber as S3

2. Step 1 of Attachment 9 missing from JPM. Fixed

3. Verify if all valve manipulations are Critical Steps. Done J3 E

4. Step 6 of Attachment 9 missing from JPM. Will applicant be able to recognize loss of IA at this step and not have to go to Step 7? Fixed

1. Renumber as S4 Done

2. JPM doesnt qualify as Alternate Path - see Appendix C, Section C.2 Fixed

3. Add to Initial Conditions that RCP-3A motor is COLD. Any other info needed in the Precautions section? Done

4. Will need a completed Pre-reqs section with initials/date Done

5. Step 1 completed? (Controlled Bleedoff) Yes - needs signed off - Done J4 U 6. JPM Step 4 - procedure step 5 - says TDB-III.7.a and TDB-III.7.d, RCS Pressure and Temperature Limits, not III.25. Fixed

7. JPM Step 6 - Annunciators are A6 and A5, not D5 Fixed

8. Caution before Procedure Step 10 - add to Initial Conditions that no one is in containment. Done

9. JPM step 12 should be step 10 Fixed

1. Renumber as S5 Done

2. What procedure step is JPM step 2? Should this step be in the procedure? Revised JPM

3. Verify if all valve manipulations are Critical Steps. Done J5 E

4. What procedure guidance is provided to direct the applicant to transition to 12.a?

Revised JPM

5. JPM step 9 - not Critical? Critical - revised JPM

1. Renumber as S6 Done J6 E 0 Page 3 of 6 OBDI 202 - IOLE Process

FC - 2009 - 03 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

JPM# Dyn LOD Explanation U/E/S (D/S) (1-5) IC Cues Critical Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. Renumber as S7 Done

2. Between JPM step 2 and 3 - add step for reading Caution with an Examiner Cue that System Operations has been notified. Done J7 E 3. JPM step 4 - no need to wait to provide OI-EE-1 attachment. Add to Initiating Cue since pre-reqs should be signed off. Done

4. JPM steps 7 and 13 - what is basis for 25 volts? Ops Rep verified

1. Renumber as S8 Done

2. Change Initiating Cue to all Title Case for procedure, lower case for the rest. Done

3. Add to Initial Conditions that pre-reqs are met - and complete the initial/date on copy provided to applicant. Done

4. Will procedure steps 7.9, 7.10 and 7.11 be signed off in the copy provided to the J8 E applicant? Yes

5. JPM is missing procedure step 7.12 Fixed

6. JPM is missing procedure step 7.14. Fixed

7. Add last step to JPM - applicant signs the surveillance test and notifies shift manager the test is complete. Revised JPM to 2 channels only

1. Renumber as P1 - see Draft Outline Comments Done

2. Change JPM such that the Control Room is performing AOP-11. Using cues, direct the applicant to perform various local operations in 2 areas of the plant. Done P9 E 3. May need to add river level greater than 983.5 ft and Containment temperatures less than 150°F to Initial Conditions. (see Cautions prior to procedure step 12.c) and whether or not an SIAS/CIAS has occurred. Done

1. Renumber as P2 Done P10 E

1. Renumber as P3 Done P11 E Other 1. Are any JPMs designed to run simultaneously? Yes

2. Index for Plant Procedure files are corrupt. Resent 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. 0 Page 4 of 6 OBDI 202 - IOLE Process

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

FC - 2009 - 03 DRAFT OPERATING TEST COMMENTS SCENARIOS Scenario 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 1 1. For Tech Spec calls - Identify the applicable Condition(s). Done

2. Need all data (partially complete surveillance, turnover sheets, etc) given to crew at watch turnover. Done

3. Add procedures and titles to all D-2s. Done

4. Identify key annuciators that alarm. Done

5. Provide more detail for E-00 steps. Done

6. Event 7 is not a Major Transient. Fixed 2 1-5. see above Done

6. What procedure directs actions for Event 1? Replaced event

7. Event 4 - more detail on D-2s. Done

8. Event 8 - move SPTAs to Event 7. Done 3 1-5. see above. Done 4 1-5. see above. Done 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 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. 0 Page 6 of 6 OBDI 202 - IOLE Process