ML113480086

2011-09-Draft Operating Test Comments

ML113480086
Person / Time
Site:	South Texas
Issue date:	09/26/2011
From:	Office of Nuclear Reactor Regulation, NRC Region 4
To:	South Texas
References
50-498/11-301, 50-499/11-301, ST-2011-09
Download: ML113480086 (4)

Text

ST-2011-09 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content

3. Attributes

1. 2. Errors 6.

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 2 S No Comments RO (A2) S 3 S No Comments RO (A3) S 3 S No Comments RO (A4) S 3 S No Comments SRO (A5) S 3 S No Comments SRO (A6) S 3 S No Comments SRO (A7) S 3 S No Comments SRO (A8) S 3 S No Comments SRO (A9) S 3 E E Add This is a time critical JPM to the initiating cues on the JPM handout sheet.

S This added to the cue sheet as requested.

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 4 OBDI 202 - IOLE Process

ST-2011-09 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

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

Focus Steps (N/B) lap Link S1 D 3 E E Step 9 indicates it is a critical step, however none of the substeps in the standard indicate S they are critical.

This was corrected as requested.

S2 D 3 E E The third bullet of the standard for step 2(C) is not critical.

S Steps 3 and 4 are not critical as there is no action required.

Step 8 is a critical step.

These were corrected.

S3 D 3 E E Steps 2 and 3 indicate they are critical steps, however none of the substeps in the S associated standard indicate they are critical.

These were corrected.

S4 D 3 E E Step 6 through 9 indicate they are critical steps, however none of the associated substeps S in the standard indicate they are critical.

These were corrected.

S5 D 3 E E Step 5 indicates it is a critical step, however none of the substeps in the standard indicate S they are critical.

This was corrected.

S6 D S No Comments C1 S 3 S Not sure this is a JPM that is conducive to being performed in the CR. Many of the actions appear to be in the controlled area (i.e. main panels) of the control room. This is not desirable. CAF This is ok as written per Ops management.

C2 S 3 S Discuss the use of a computer in the control room.

This is ok per Ops management.

P1 S 2 E E Change the cue for step 2 so that it has indications rather than state a conclusion (i.e.,

S tripped).

Step 3 is not a critical task. This was revised.

This JPM has low discriminatory value, however it is being retained due to its high importance rating.

P2 S 3 E E Change the cue for step 2(C) so that it has indications rather than state a conclusion (i.e.,

S closed/open).

The local indications are actually as stated in the cues.

P3 S 3 S No comments 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. 0 Page 2 of 4 OBDI 202 - IOLE Process

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 4 OBDI 202 - IOLE Process

ST-2011-09 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 S S E S S S S S E Typically, isolating the SG is the critical task for this event and not determining the target S temperature. Discuss with scenario author.

Change terminating the scenario to when the cooldown has been started.

These changes were made as requested.

2 E S S E S S S S E Change event one to a component failure (C).

S There dont appear to be any actions for the RO on event 4 - delete the RO from the scenario out line (D-1) form for event 4.

Event one was changed as requested. During validation it was determined that there are actions performed by the RO so no change was required.

3 S S E S S S S S E Need to explain why the critical task associated with event 3 is critical. If it is determined S event 3 is not critical, then need to add one more critical task per ES-301-4 criteria.

This was revised.

4 S S E S S S S S E Need to explain why the critical task associated with event 3 is critical.

S This was left as written because if not performed correctly, it would directly lead to a reactor trip and entry into an EOP. This spare scenario was not validated during validation week.

General comment: Have a spare scenario ready at least for a table top review during validation week.

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 4 of 4 OBDI 202 - IOLE Process