ML093200596

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2009-10-Draft Operating Test Comments
ML093200596
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 11/16/2009
From: Apger G
NRC Region 4
To:
Southern California Edison Co
References
50-361/09-302, 50-362/09-302 50-361/09-302, 50-362/09-302
Download: ML093200596 (6)


Text

S0-2009-10 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 3 S Change title to RA1 All comments resolved below.

(RA1a)

RO 3 S Change title to RA2 (RA1b)

RO (RA2) 3 S Change title to RA3 RO (RA3) 2 Change title to RA4 SRO 3 E Perform Step 9: Change standard to (0.0148 + 0.0124 + 0.0173) / 3 = 0.0148 (SA1a) Change title to SA1 SRO 3 S Change title to SA2 (SA1b)

SRO 3 S Change title to SA3 (SA2)

SRO 3 S Change title to SA4 (SA3)

SRO 2 S Change title to SA5 (SA4)

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? 0 Page 1 of 5 OBDI 202 - IOLE Process
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.

NOTE AFTER TITLE CHANGE:

RA2 = SA2 RA3 = SA3 0 Page 2 of 5 OBDI 202 - IOLE Process

SO-2009-10 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 S1 D 3 E PLACE on front page of JPM a bold / large font note that states DO NOT HAND OUT PROCEDURE UNTIL APPLICANT HAS COMPLETED IMMEDIATE ACTIONS All comments resolved.

S2 D 3 S S3 D 3 S S4 D 3 S S5 D 3 S S6 D 3 S C7 S 3 S C8 S 3 S P1 S 2 S P2 S 3 E ENSURE the applicants are provided a marked-up copy of the procedure such that they will be at step 8, monitoring per the log sheet.

P3 S 2 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.

$ 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 0 Page 3 of 5 OBDI 202 - IOLE Process

resolution on this form. 0 Page 4 of 5 OBDI 202 - IOLE Process

SO-2009-10 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 E E EXPLAIN why Tripping RCPs is a critical task. This would protect the pump, but is it safety significant?

ENSURE time limit for tripping reactor is an Ops Manager expectation that can hold up under scrutiny.

ENSURE all other critical task time limits are Ops Manager expectations. These time limits need to have safety significance in UFSAR. They are not the time limits associated with operator performance in requal. All comments resolved.

2 E E EXPLAIN why restoring flow to the NCL is critical. Does it have safety significance?

3 S May be the backup scenario based on validation results.

4 S May use this in place of Scenario 3. Low power. Good sequence.

5 WILL NOT USE FOR ANY REASON.

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 5 of 5 OBDI 202 - IOLE Process

SONGS October 2009 Synopsis of Operating Exam Changes (These Comments are from changes incurred during NRC validation)

1. EOS-301 Modified Code for C-7 and C-8 to reflect the fact that these JPMs are being performed in the Control Room and incorporate additional Critical Steps not normally done in the Simulator. Modified Code for P-3 to reflect the removal of JPM Steps for entry and exit through the HP Checkpoint.
2. EOS-301 Modified Actual Attributes to reflect minor changes in Scenarios.
3. EOS-301 Modified Event locations to reflect minor changes in Scenarios.
4. Admin JPM SA1 - Made corrections to Answer Key to reflect NRC Validation comments.

Added a bullet item to the Initiating Cue to have Examinee record any procedural actions required in the Comments Section.

5. Admin JPM SA4 - Added information to Examinee Copy to reflect NRC Validation comments.
6. Simulator JPM S Removed information about providing a copy of the procedure to the Examinee. Added a Note regarding the Operator Aid present in the Control Room. Corrected handswitch number at JPM Step 11.
7. Simulator JPM S Removed a bulleted item from the Initial Conditions as it was not needed to perform the task. Corrected valve nomenclature in JPM Step 9.
8. Simulator JPM S Added FS-7, Verify SI Throttle/Stop Criteria as a reference that may be provided to the Examinee. Corrected recorded values at JPM Steps 10 and 23. Added Examiner Cue allowing Examinee to override valves at JPM Step 14.
9. Simulator JPM S Modified Simulator set up so that only the RCP P002 CCW LOW FLOW alarm actuates. Modified Examiner Cues as required to reflect conditions Examinee would be observing. Identified SO23-3-1.7, Attachments 1, 2 and 16 as additional provided references.
10. Simulator JPM S Added flow indications at JPM Steps 4b and 4c to reflect indications that the Examinee should observe.
11. Simulator JPM S No changes required.
12. Simulator JPM C Changed Initial Conditions to reflect the fact that Control Room Emergency Chiller would remain running to avoid confusion while performing the JPM. Added Examiner Cues as required to evaluate performance of FHIS Restoration.
13. Simulator JPM C Added a Step and associated Examiner Cue when Examinee goes to reference the DAS Trends Page following the CONTAINMENT HI RADIATION alarm.
14. Simulator JPM P No changes required.
15. Simulator JPM P No changes required.
16. Simulator JPM P Removed entry and exit Steps through the HP Checkpoint. Made minor corrections to JPM Steps 1 and 2 to reflect labeling on the Reactor Trip Circuit Breaker Switchgear. Modified Examiner Cues to minimize word usage for this Time Critical JPM.

Changed the initiating location for the JPM to just inside the HP Checkpoint.

17. Simulator Scenario #1 - Removed RO bean from Event #3. Added Annunciator 56A11 to Indications Available for Event #3. Added descriptive Steps for boration alignment in Event #3.

Added descriptive Steps for Bus 2A07 Transfer post-trip.

18. Simulator Scenario #2 - Changed Initial Conditions from 74% to 99% power to facilitate observation of actions following Main Feed Pump trip. Removed BOP bean from Event #3.

Added descriptive Steps for Alternate Boration alignment in Event #3. Added descriptive Steps for transfer of the Non-Critical Loop and Letdown Heat Exchanger in Event #4. Modified Critical Task wording for restoration of feedwater flow to Steam Generator E088.

19. Simulator Scenario #3 - Modified Event #3 to restore VCT Level Transmitter once actions were performed to support alignment of Emergency Boration via the Gravity Feed Valves post-trip.
20. Simulator Scenario #4 - Reworded conditions for Event #2 and instituted Simulator modifications as required to support performance of this malfunction. Added descriptive Steps for transfer of the Non-Critical Loop and Letdown Heat Exchanger in Event #3.