ML103430561

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FC-2010-09-Draft OP Test Comments
ML103430561
Person / Time
Site: Fort Calhoun 
Issue date: 09/17/2010
From: Brian Larson
Operations Branch IV
To:
Omaha Public Power District
References
Download: ML103430561 (9)
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Text

Attachment 10 Page 1 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS ADMIN JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia RO (A1)

E The task standard needs to be corrected to (12 to 13 minutes) The range is based on reading the time required chart to between 12 and 13 minutes. 12 minutes X 120 gpm (charging pump capacity) = 1440 gals. 13 minutes X 120 gpm = 1560 gals. The hand calculation for step one results in 1525 gals.

1. JPM title doesnt match ES-301-2. fixed
2. KA and IR on JPM cover sheet doesnt match ES-301-2. fixed
3. Step 1 and 3 - What is range of answer based on? (1440-1560 gal)
4. Step 1 - 3: add calculations to Element. fixed RO (A2)

E

2. KA and IR on JPM cover sheet doesnt match ES-301-2. fixed
1. JPM title doesnt match ES-301-2. fixed
3. OI-DG-1/2 Attachment 1 should be included as reference materials.fixed RO (A3)

E

3. Will copies of drawings be available or will they use drawings on a rack?
1. JPM title doesnt match ES-301-2. fixed
2. KA and IR on JPM cover sheet doesnt match ES-301-2. fixed They will have bound drawing sets.

RO (A4)

E This JPM has high operational validity. I believe that the LOD is 2-3 because in step 5, the candidate must read and comprehend many RWP items. One of them is the stop work dose rate item. The candidate must then use the EAD dose rate setting to identify two areas on the survey map with dose rates above the EAD setting. Added a stay time calculation to increase the LOD.

1. KA on JPM cover sheet doesnt match ES-301-2. fixed
2. JPM does not identify Important Rating. fixed
3. LOD near 1.

SRO (A5)

E

1. Eliminate reference to Tech Specs in the Initiating Cue. SRO applicant should demonstrate they are aware of Tech Spec limitations on fuel location. fixed
2. Tech Spec 2.8.3 should be included as reference material (not just the figure). fixed SRO (A6)

X U

2. Step 3 is a Critical Step. Task Standard identifies the applicant finds the pump vibration results should have been designated as High Alert. fixed
1. JPM title doesnt match ES-301-2. fixed SRO (A7)

X U

2. KA and IR on JPM cover sheet doesnt match ES-301-2. fixed
1. JPM title doesnt match ES-301-2. fixed
3. Step 1 is a Critical Step. Task Standard identifies the applicant reviews TS and

0 Page 2 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS ADMIN JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia determines the procedure change would be allowed.

What if the candidate went to TDB-III-42 first? He could determine that the change was not allowed without even referring to Tech Specs. I changed the task standard to reflect.

4. Both procedure changes are for the same thing - why ask two questions? Not reasonable that you would approve one change and not the other.

Changed to one question.

SRO (A8)

X U

3. Steps 2 and 4 are Critical Steps as they are specifically identified in the Task Standard.
1. JPM title doesnt match ES-301-2. fixed
2. IR on JPM cover sheet doesnt match ES-301-2. fixed Agree. fixed.

JPM replaced due to disagreements between reference procedures - CR initiated.

SRO (A9)

E

2. Step 3 - Standard specifies that the applicant completes FC-1188 including Temperature Diff, and Stability Class - where is this information available to the applicant?
1. JPM title doesnt match ES-301-2. fixed See NOTE 1 on page 2 of the FC-1188 form 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 3 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia S1 E

3. JPM step 2 - how does applicant verify BASTs are available?
1. Schedule shows this done in parallel with S2 but does not show SROUs on sched per ES-301-2 (S1 and S8)

The schedule is correct. The USRO ES-301-2 form will be revised to have the USROs perform JPM's S-3 and S-8;

2. JPM title doesnt match ES-301-2. fixed Checks levels greater than 10%.
4. Move the initiation of the pipe break to just after the announcement is made (JPM step 8). If the break happens just before the applicant reads the IF - THEN procedure step is not a good measurement of the applicants ability to determine an alternate success path.

Break initiated at step 7 when operator closes LCV-218-2 S2 E

5. Attachment 1, steps 7f-h should be marked N/A. fixed
1. JPM title doesnt match ES-301-2. fixed
2. KA on JPM cover sheet doesnt match ES-301-2. fixed
3. Attachment 11 and 1 handouts - should step 3 be marked N/A instead of initialed?

Yes. fixed

4. JPM step 2 - second cue is not required since SM has initialed on Attachment 1 as identified in JPM step 4. fixed
6. JPM step 10 - applicant reenters Attachment 11 at step 1.a and can now initial it.

fixed

7. JPM is not an Alternate Path because the cue provides the applicant the success path.

Replace JPM or remove the AP designation.

We can remove AP designation.However, It should be noted that this JPM was approved as an AP JPM during a previous NRC Operating Test (2005)

S3 E

4. JPM step 2 - For the note on page 11 - are there indications in the simulator that the applicant can determine differential temp between Pressurizer and spray line? If not -

provide a cue in JPM step. Can determine from cold leg and pressurizer temperature indications.

1. Different JPM than at Outline submittal - discussed with CE during outline feedback.

Improved logistics of JPM sets

2. Add to Initiating Cue that all prerequisites have been met for Attachment 2 since they are initialed on the handout. fixed
3. Will the applicant mark procedure step 1 as N/A? If so, we will need two copies of Attach 2 so the applicant has a clean copy when he raises pressure at JPM step 9. agree
5. JPM steps 4 and 10 - procedure uses nomenclature PCV-103-1 and Standard uses HC-103-1. Should the procedure be changed to identify the actual switch that is manipulated? fixed
6. JPM step 14 Standard states applicant may also close HCV-150 what is this valve?

Block valve for the other PORV

0 Page 4 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia S4 X

U

3. JPM step 2 - does Operations agree that this step means to start FW-54? The procedure ensures a steam path then starts steaming on a separate step.
1. JPM title doesnt match ES-301-2. fixed
2. Initial Conditions - Delete first bullet and change bullets 2 and 3.
  • Efforts to reestablish Shutdown Cooling have not been successful (or something similar) fixed May not start FW-54 with adequate S/G level. Changed step to not critical and revised wording.
4. JPM is a weak Alternate Path - cueing the applicant just before he reads the IF - THEN procedure step is not a good measurement of his ability to identify an alternate success path. Happens after Steam dump and bypass flow is established.

S5 E

2. Add ARP-AI-44/A39 to References and include as reference material to JPM. fixed
1. Different JPM than at outline submittal.

Original JPM was not discriminating and was very time consuming.

3. After JPM step 13, add step for applicant to determine that step 1, Attch 3A, is N/A and initials procedure. fixed S6 E
3. After JPM step 11, add step for applicant to determine that step 1.k, Attch 1, is N/A and initials procedure. fixed
1. JPM title doesnt match ES-301-2. fixed
2. KA listed on ES-301-2 doesnt match KA on the JPM cover sheet. fixed S7 E
5. Attachment 3, step 1 - remove x and initials since we have a cue for this step. fixed
1. Different KA than outline submittal - discussed with CE during outline feedback.
2. Still Engineered safety feature (EN)?

I will revise ES-301-2 forms to remove as EN since we are using it for safety function 4P.

Note: S-8 (which is performed by the USROs) is an EN.

3. The Importance Ratings listed on the ES-301-2 form are not correct for the KA. fixed
4. Task Standard and Initiating Cue identify Attachment 2 - should be 3. fixed
6. Attachment 3, step 2 - what is [AR 01900]?

Action Report for mispositioning error that occurred many years ago and resulted in a modification.

7. JPM step 2 - Standard. Why at least one of the following switches?

Switches are redundant, either one will have the same affect S8 E

Engineering Calculation associated with modification to remove autostarts of HPSI Pump SI-2C and Containment Spray Pump SI-3C.

1. Different JPM than outline submittal - discussed with CE during outline feedback.
2. Attachment 26, Caution on page 140 - what is EC 27581?

0 Page 5 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia P1 E

Changed JPM KA, 000055 EA1.04 is more appropriate

1. JPM title doesnt match ES-301-2. fixed
2. ES-301-2 lists KA 000055, EA1.04 but JPM lists 063000 A1.01. Revise ES-301-2.
3. JPM step 3 - Standard. Should be DC Bus 1, not 2. fixed P2 X

X U

1. JPM title doesnt match ES-301-2. fixed
2. JPM step 2 - is an Examiner cue necessary or can applicant observe strainer operation without a cue? Changed cue to "If the strainer is not operating then give cue.
3. JPM step 4 - is this step Critical (in order to accomplish Task Standard)?

Yes fixed

4. JPM step 7 - Standard states applicant placed breaker in OFF, but also contains a cue that another operator placed the breaker in OFF? Cant be both. Critical Step?

During validation, it was recommended that we replace this step with a cue since this step is performed at a distance from the Intake Structure and this step significantly increases the time required to perform this JPM. I will revise the standard. This would be critical if the candidate actually performed the step.

5. JPM step 8 - change cue to read that When applicant reports completion of procedure step 1.d to the Control Room, inform the applicant that the Control Room reports that the High Differential Annunciator is still in alarm. fixed P3 X

U Noted, procedure could be improved by placing before starting release.

1. Initiating Cue, third bullet. Attachment is 5A, not 5. fixed
2. JPM step 1 - Critical Step (operator manipulates equip)? JPM step 14 says it is just ensure. If no manipulation is required, change Standard. fixed
3. Cue before JPM step 7 - Change to inform applicant that steps 9 and 11 are complete and step 10 is N/A. fixed
4. After cue but before JPM step 7 - add a step that applicant marks procedure step 12.a as N/A. fixed
5. Procedure steps that identify securing the purge criteria (steps 13, 15, 17) and data recording requirements (step 16) should be read before the release is started.
6. JPM step 12 - change cue to power has been lost to RM-062 and RM-052. Not much of an Alternate Path challenge if you tell the applicant right after he reads the step
7. JPM is not a good Alternate Path. Cueing the applicant just after he reads the IF -

THEN procedure step is not a good measurement of the applicants ability to determine an alternate success path. Either move the cue to earlier in the JPM, remove the AP designation or replace JPM.

Changed initial conditions to reflect another radiation monitor lineup. Moved RM-051 cue earlier.

JPM replaced due to exam security concerns with cameras in the RCA during validation.

Miscellaneous

1. JPM cues should not provide applicants the end state (ex. EDG 1 is running, valve xx is

0 Page 6 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM#

1.

Dyn (D/S)

2.

LOD (1-5)

3. Attributes
4. Job Content Errors
5.

U/E/S

6.

Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B)

Over-lap Job-Link Minutia open). Cues should provide information that enables the applicant to determine end state (ex. Loud noise, using pen indicate 900 RPM on EDG 1 speed indicator, using pen, indicate that the VPI is at the open position). OK

2. All JPM Initiating Cues should be present tense - You are directed to perform or The CRS directs you to perform Not You have been directed to perform Will fix on next revisions.

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 7 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 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
1. Normal evolutions dont count towards malfunctions listed on ES-301-4. (6 vs 7)

Events: 2+4+5+6+7+8+9=7 malfunctions

2. LOOP removed - replaced with HPSI pump failure to start. Impact on complexity of scenario?

The loss of offsite power did not add to the required operator action because the diesels start and automatically power their loads. The failure of HPSI pump SI-2A to start requires operator action to restore adequate SI flow by starting SI-2C.

3. Turnover - Shift Manager directs that rotating charging pumps be continued at the beginning of the shift..(since procedure is in progress) fixed
4. Event 3 - add to D-2 that CRS has entered AOP-1,Section II, and include Section 4, steps 1-3. fixed
5. Event 9 - D-1 says SI-2A fails to auto start. D-2 says CRS directs starting SI-2C.

Does that mean SI-2A and 2C fail to auto start? Does CRS direct both pumps started?

Normally, the sequencer switches for SI-2C are not aligned for automatic start.

6. During EOP-4 implementation - are Steps 5 and 6 missing in D-2s?

During validation, it was determined that these steps would be performed while still in EOP-00. (EOP-00, Step 11.3) However, I will add steps to verify in EOP-04.

2 X

E

1. see #1 above - what are 7 malfunctions?

Events: 1,2,3,4,5,7,8 = 7 malfunctions I should have listed Event 1 as N and C

2. Surveillance for AFW pump, Step 7.5 - has start time recorded but no stop time when flow indicator > 100 gpm?

Acknowledged. CR after exam..

3. Event 2 - D-2 missing step 1 of ARP. fixed
4. Event 3 - actions in D-2 dont match ARP. fixed
5. Event 4 - In the ARP step to verify VIAS has actuated, it says refer to two other annunciators (Ventilation Isolation Command). Both referenced ARPs have a step 2.4 that says if none of the 86A-B/CRHS, 86A-B/SIAS, or 86A-B/CSAS relays are tripped, then go to AOP-23. Why?

These are the inputs to VIAS. If VIAS occurs without one of the inputs, the procedure assumes that the VIAS is inadvertent. I will add a step to determine VIAS due to CRHS.

(It's called Containment Radiation High Signal even though it also is actuated by aux building stack monitors.)

6. Event 5 - will entry into AOP-35 be without reference to ARP?

Very likely, AOP-35 entry conditions are met. But, should also refer to ARP. Added steps.

7. Event 6 - does SRO direct ATC and BOP to commence emergency shutdown and they perform steps without direction or does SRO read/direct each procedure step?

CRS will read and direct steps 1-5, step by step. steps 3 and 5 will be performed continuously during the shutdown.

8. Event 6 - AOP-05 does not contain a directive step to reduce turbine load.

In step 3, the BOPO reduces turbine load to maintain T-cold.

9. Event 7 - is the SRO expected to direct a reactor trip? If so, then remove May from the D-2 and change ATC action to Trip the reactor when directed.

0 Page 8 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS SCENARIOS In the validation, the automatic trip occurred just as the ATCO was about to manually trip the reactor. Following the validation, we decided to make the break smaller.

So I expect that a manual trip is more likely. fixed.

10. Events 7/8, page 3 of 4, after CT - D-2 says the CRS determines that a Steam Generator Tube Rupture Event is in progress? (Cut and paste error, fixed)

Also, steps listed on the D-2s are not easily traced to AOP-05 steps.

Added references to AOP steps.

3 X

E

1. see #1 above - what are 8 malfunctions?

Events:1,2,3,4,6,7,8,9 = 8 malfunctions

2. What are 2 malfunctions after EOP entry?

I counted event 7 as occurring with EOP entry and PPLS failure and blackout as malfunctions after EOP entry. D-2 failure was considered part of blackout.

3. What are 2 EOPs entered requiring substantive actions?

EOP-03 and EOP-20

4. Event 1 - D-2 is missing ARP step 2 Added
5. Event 1 - what is procedure reference once the leak is reported as isolable? Also, D-2 says to shutdown AC-3A and close suction and discharge valves for AC-3A? Isnt the leak on AC-3C? Also, Tech Spec Required Actions list AC-3A, not 3C.

Fixed to say AC-3C. AOP-11 step 7 directs operators to attempt to isolate CCW leak but does not specifically list these valves.

6. Event 2 - steps listed on D-2 doesnt match ARP for B3L.fixed
7. Event 3 - what procedure directs selecting Channel X for pressurizer level control?

This is an expected operator action for a controlling channel failure, Will write a CR after exam

8. Event 4 - is the applicable ARP CB-4/A20?Multiple alarms What specific Windows?

B-7 Does the ARP direct resetting Rod Drop Bistables? ? ARP sends operators to AOP-15 which directs reset of rod drop bistables. Also, should the Nuclear Instrumentation Inoperable be Nuclear Instrumentation Channel Inoperable? Fixed 9 Event 4 - if rod drop bistables are reset per AOP-15, then move the step on the D-2 to after ATC actions to place Channel C RPS Trip Units in trip. Fixed

10. Event 5 - what initiates OP-4 Power Reduction? ? Required by Tech Spec 2.15(2)

Also, steps in D-2 dont match OP-4.

OP-4 step 1 is N/A, step 2 is on the D-2, step 3 is N/A, step 4 is N/A. The actions in step 5 of OP-4 are performed concurrent ly during a plant shutdown. 5.g is the first step,,

Steps 5.c,d,e are automatically controlled. I added a step for ASI control to the D-2.

11. Event 7 - What is basis for 10 minutes in the CT for manually initiating PPLS?

Based on consensus

12. Event 8 - need to add to D-2 that BOP should report failure of DG-2 to start after manual actuation of PPLS, not at beginning of Event 9. Also, add Step 10 of EOP-3 to D-2. Fixed 4

(B/U)

E

1. Event 7 - steam dumps fail open ESD major transient?

Only if not isolated.

During our discussions, Tom and I had some concerns about emergency boration as a critical task. We decided to to change event 6 to "Manual Reactor Trip - 2 CEAs fail to insert" that way there can be no argument about emergency boration being a critical step.

0 Page 9 of 9 OBDI 202 - IOLE Process FC - 2010 - 09__R1 DRAFT OPERATING TEST COMMENTS SCENARIOS Miscellaneous

1. Op Test, not Op Exam OK 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.
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