ML100880161

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2009-09-Draft Operating Test Comments
ML100880161
Person / Time
Site: Cooper Entergy icon.png
Issue date: 09/21/2009
From: Garchow S
Operations Branch IV
To:
Nebraska Public Power District (NPPD)
References
50-298/09-301 50-298/09-301
Download: ML100880161 (6)
v • d • e


Text

CN - 2009 - 09 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) S RO (A2) S RO (A3) S RO (A4) S SRO (A5) U The Security Emergency is not an admin JPM.

S This JPM was replaced.

SRO (A6)

SRO (A7)

SRO (A8)

SRO (A9)

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 1 of 6 OBDI 202 - IOLE Process

CN - 2009 - 09 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 S S2 S S3 S S4 S S5 S S6 S S7 S S8 S P1 S P2 S P3 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 resolution on this form. 0 Page 2 of 6 OBDI 202 - IOLE Process

CN - 2009 - 09 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 U 1. The examiner will not act as a second checker for rod movement. A second operator (training staff member) can perform this function.

S 2. This scenario may take an excessive amount of time. CAF for validation time.

3. Is control rod 22-27 considered inoperable?
4. Since control rod 14-23 is stuck in the fully inserted position, there are no control room required TS actions.
5. Because there are no actions associated with event two other than the TS evaluation, no credit is given to the RO or BOP for this event.
6. In the scenario guide, include the specific TS the CRS will enter based in the fully inserted stuck control rod (LCO 3.1.3.C).
7. Include what actions, if any, are taken by the RO per 2.4CRD.
8. What is 4.4.1 referenced in event 2?
9. Because there are no actions associated with event three other than the TS evaluation, no credit is given to the RO or BOP for this event.
10. Event 4 (roll the main turbine) does not include a description of what actions are taken by the operators.
11. Event 4 will take an excessive amount of time particularly since no status with regard to prerequisites is given.
12. Event 5 has little safety significance.
13. Event 6 states all the MSIVs indicate open but MSL flow is abnormally high for MSLs A, C, and D. With power at ~12%, these would indicate 4% flow instead of 3%. Not sure it is reasonable for the operator to identify these as being abnormally high with a 1% change in indications.
14. No credit is given for event 6 for either operator since there is no action taken.
15. Event 6 does not include a write up of the entry into TS 3.6.1.3, Primary Containment Isolation Valves.
16. Not sure how much of a power/pressure spike there will be when an MSIV closes at 12% power. Does this annunciate?
17. Event 7 only includes one action for the board operators (depress the scram buttons).
18. Event 8 only has one action scripted (reset the scram).
19. One of the critical steps is to emergency depressurize. This activity is not in the scenario script.
20. Many important actions required for this scenario are not included in the scenario guide.

This scenario was replaced.

2 E 1. The correct answer for SRO question 15 is, in part, that the reactor will scram with HPCI initiating with power near rated. According to this scenario it does S not scram. Which is correct?

2. Event one, as proposed, will probably take an excessive amount of time.
3. Include supplemental operator actions on event 5 such as manually adjusting recirc loop flow(s).
4. Does event 5 result in being in the exclusion zone of the core instability map?
5. With an ATWS and high turbine vibrations, is the correct action to trip the main 0 Page 3 of 6 OBDI 202 - IOLE Process

CN - 2009 - 09 DRAFT OPERATING TEST COMMENTS SCENARIOS turbine? Depending on the power level, this action could result in significant fuel damage.

6. When the recirc pumps are tripped, where does reactor power stabilize?
7. Many significant crew actions for the ATWS (e.g. terminate injection, inhibit ADS, initiate power/level control, critical level related EOP steps, etc) are not scripted in the scenario. These actions need to be added.
8. If event 7 is triggered with event 6, then it is not an event for the scenario (i.e it is part of the major event).
9. It is not clear what value the RCIC trip is from an evaluation standpoint since there are no apparent operator actions in response to this event.
10. Critical tasks 2 and 3 are the same since boron cannot be injected.
11. The critical task for this scenario is to make the reactor subcritical by inserting control rods.

This scenario was replaced.

3 E U 1. Event 2 is the same as event 2 in scenario 2. Cannot use the same event in multiple scenarios.

S 2. Reformat the scenario guide so it is the same as the first 2 scenarios.

3. Event 4 does not contain any operator actions and will not count as an event except for the SRO TS call.
4. Event 5 and 6 are considered one event since the operator response is to the same initial condition (lowering vacuum).
5. This scenario requires the crew to implement steam cooling. Operating experience indicates that even with a loss of all injection, with all control rods fully inserted it will take an excessive amount of time to run this scenario.
6. This scenario contains the minimum two tech spec events. One of these TS calls (failure of the RRMG flow controller) is conditional on the operator response being slow enough for recirc flows to differ by more than 15%. If the operator response is quick enough, there will be no TS entry. This will necessitate running an additional scenario for the SRO to satisfy the minimum two TS calls.
7. Event 7 and 8 should be combined as the main event since they are triggered together.
8. Delete the E-Plan declaration from the scenario.
9. Several different font sizes/types and formats are used in the scenario. These should be corrected so they are consistent.
10. Event 7 (trip of reactor feedpumps) is irrelevant since they are lost anyway on the loss of off-site power when the MSIVs go closed.
11. This is the second scenario with a loss of HPCI and RCIC.

This scenario was replaced.

4 U 1. This is the third scenario with one of the events being to raise reactor power with reactor recirc.

S 2. This is the third scenario with a loss of RCIC event.

3. Because the emergency power reduction is performed in direct response to the trip of the recirc pump, it is part of event 5 and not a stand alone event.
4. With power available, the probability of all four RHR pumps failing to start and both core spray valves failing to open is extremely remote.
5. Event 4, Condensate Booster Pump trip, does not contain any operator actions 0 Page 4 of 6 OBDI 202 - IOLE Process

CN - 2009 - 09 DRAFT OPERATING TEST COMMENTS SCENARIOS or TS calls. This is a non-event for the entire crew and has no evaluation value.

6. Event 3 does not identify what instrument is causing the feed flow oscillation (e.g. feed flow, steam flow, RPV level, master level controller, slave controller, etc.).
7. Event 3 does not detail what actions are required in response to the oscillating feed flow. One step of the scenario states the operator should take one of three actions - which one would be expected given the instrument failure simulated.
8. Event 5 does not detail what actual actions are taken in response to the tripped recirc pump (e.g. reduce flow in the operating loop, drive rods, attachment 1/3 of 2.4RR, etc.)
9. If the tripped recirc pump is isolated to prevent reverse flow, then event 7 is a non-event.
10. Event 7, Recirc pump seal failure, is to be initiated before the crew takes any actions to exit the instability region. It is not clear what actions, if any, will be taken in response to the recirc pump trip. If there are no actions, this is a non-event for the board operators.
11. The scenario states the crew is to scram the reactor when containment reaches 1.5 psig. What is drywell pressure when containment pressure is 1.5 psig (i.e.

would an automatic scram have occurred)?

12. Event 8 is to be initiated when the recirc loop is isolated however, according the script, the loop cannot be isolated.
13. All the safety related injection systems fail during the scenario, however all the alternate injection systems (condensate pumps, CRD, feed booster pumps, etc.) remain available. Also, I would expect the board operators would recognize the RHR pumps failed to start and start them. Given this and a large break LOCA, RPV level should not reach the top of the fuel.
14. With a large break LOCA, an emergency depressurization should not be required as the break will depressurized the RPV.
15. It would seem that given the sequence of events, the operators could do nothing and the plant would take care of itself.
16. Based on the previous comments, I would argue there are no critical tasks in this scenario.

This scenario was replaced.

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 0 Page 5 of 6 OBDI 202 - IOLE Process

CN - 2009 - 09 DRAFT OPERATING TEST COMMENTS SCENARIOS 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
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