ML12240A318

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CP-2012-06 Draft Ops Test Comments
ML12240A318
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/11/2012
From:
NRC Region 4
To:
Luminant Generation Co
References
Download: ML12240A318 (7)
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Text

CP-2012-06 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 (RA1) S 3 X E If it is critical that the applicant identifies which curve applies for containment closure time (thermal S environment or radiological environment-limiting), then the incorrect curve could be used and still arrive at the stated correct numerical answer. If the applicant selected the thermal environment limiting curve, he could select 78 minutes, which fits the stated pass/fail criteria of 75 +/- 3 minutes.

JPM Revised to address concerns.

RO (RA2) S 3 S RO (RA3) S 3 X E The temperature and pressure values changed compared to the modified version, but the tasks and the S outcome are the same. Recommend modifying this one to include results that are below the curve in Figure 1. This would result in an evaluation that the surveillance is unsatisfactory.

JPM revised to address concerns.

RO (RA4) S 3 X E Is the fact that the workers need ice vests for the job figured into the Action Time stated in the initial S conditions? Not sure what goes into the calculation of Action Time, and whether an applicant would expect a filled out Heat Stress Management Permit as part of the package to make these calculations.

(Editorial) On Step 1 and 2 in the JPM, the comparison values are 500 person-mRem and 50 person-mRem (vice person-Rem).

Discussed at validation. Concerns addressed.

SRO S 1 X X U The JPM is a combination of two JPM tasks. Both of which can be performed by an RO and do not test (SA1) S any specific SRO ability. The second JPM task added to this to distinguish it from RO A1, if given the IPO-010A Attachment 1 as stated, is a direct lookup task with little/no discriminatory value.

Revised as a result of validation.

SRO S 4 X E LCO 3.3.1, Surveillance Requirement 3.3.1.2, requires adjustment of NIS Power Range and N-16 (SA2) S Power Monitor channels if either set is deviating from the output of the calorimetric by 2% RTP. The NIS Power Range channel outputs are the only ones addressed in the Critical Step currently. The other portion should be added to be complete.

Revised.

SRO S 4 S The content here minus the Tech Spec evaluation could be used to address comments on RO A3.

(SA3)

SRO S 4 X E Same comments as on RA4.

(SA4) S Discussed at validation. Concerns addressed.

SRO S 3 X U With the recent change in the emergency planning regulation (10 CFR 50, Appendix E, Section IV.C.2),

(SA5) S there is a regulatory requirement to classify an event with the information available within 15 minutes.

Therefore, it is an additional Critical Step that the applicant meets this time requirement. Even prior to this rule change, site procedure EPP-201, Revision 12, requires EAL classification within 15 minutes (Section 4.3, first Note).

Revised. 0 Page 1 of 7 OBDI 202 - IOLE Process

CP-2012-06 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 (Editorial) The applicable EAL chart is not labeled CPNPP EAL Hot or Cold Conditions, as stated in JPM Step 1. It doesnt have a specific label, but is referred to in the procedure as common or Any Operating Mode.

(Procedure Comment) If EPP-201 is the latest version of this E-Plan implementing procedure, it has not been reviewed/revised since the revision to the emergency planning regulation mentioned.

Recommend review for consistency.

An evaluation of EPP-201 versus the new regulation is in progress, due for completion 6/20/12.

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 7 OBDI 202 - IOLE Process

CP-2012-06 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 S If it is standard for another operator to monitor and take action to maintain Tave within 2F of Tref, this should be cued.

Discussed in validation. Issues resolved.

S2 D 3 S Since several conditions are given in the initial conditions, do no pre-mark the given procedure. Allow the applicant to make that judgment. Also, if the applicant doesnt recognize these, and takes the additional actions, what effect does it have on the rest of the JPM?

Made adjustments to JPMs based on procedural accepted practice for marking N/A on procedures. Adjustments to JPM made as requested.

S3 D 3 S Made change to IC description based on validation comments.

S4 D 3 S Made changes to Step 5 content based on validation comments.

S5 D 4 X E This is denoted as being Time Critical, but it doesnt match the FSAR scenario which S drives the time requirement. For the FSAR analysis (Section 6.3.2.8), it assumes that one of the sump suction valves fails to open (meaning the JPM would need to be alternate path). To match to the time requirement, the actions with this have to be included. The critical steps proposed are not consistent with the 70 second requirement.

(Procedure) EOS-1.3A, Revision 8, Step 4b RNO for failure to have one of the containment sump valves to open directs the crew to secure affected Containment Spray Pump(s) and consult plant staff as needed. How does this course of action support completion of time assumptions made for this scenario in the FSAR?

Validated the JPM. The time requirement is valid per the FSAR, and as it was stated in the draft submittal. Made some adjustments to the examiner cues to ensure that it is administered correctly.

S6 D 4 S Based on validation, there were concerns over whether the electrical plant was modeling grid instability correctly in the simulator. Removed JPM from exam so CR could be written on the condition. Replacement JPM validated, and was acceptable.

S7 D 3 E In SOP-802, Step 5.3.2.C, it says to perform the following steps to shift to single train S operation. The subsequent actions are at the same outline tier level. Are there some sub-steps missing under 5.3.2.C [Item 1) and 2) for example], or are the rest of the actions the sub-steps to accomplish this?

Reviewed during validation. Issues addressed.

S8 D 4 S Made changes based on validation comments.

P1 D 3 E Questions:

S 1) Step d: Does the applicant have the keys/tools to unlock the valve? Does he/she 0 Page 3 of 7 OBDI 202 - IOLE Process

CP-2012-06 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 need to get them from somewhere else?

2) Step g: Did a step somewhere else open the AFW pump SSW suction high point vent valve? It is assumed opened here in this attachment, wasnt sure if a note is needed in the cue.

Comments were resolved during validation.

P2 D 2 U Unless there are some specific challenges on locating the valves involved in this one, or S challenges with their operation, it is difficult to see the discrimination value of this JPM.

During validation, it was confirmed that the draft JPM was unsatisfactory. A new JPM was developed and validated during validation week to replace this. Issues resolved.

P3 D 3 X E ECA-1.1A, Attachment 3, has three methods to add makeup to the RWST: From the S CVCS Blender, from the opposite units RWST, or from the Spent Fuel Pool. The cue tells the applicant to go align RWST makeup per this attachment, starting with Step 1d. This implies that the alignment for the CVCS Blender path is to be implemented. However, the cue tells the applicant to move on to the section aligning the other units RWST prior to completion of the CVCS Blender alignment. Then, the JPM stops steps part way through this alignment, not completing down to the point where water is transferred [starting the Refuel Water Purification Pump, Step 2c.2)L)]. As written, this JPM doesnt direct the applicant as to what method of refilling the RWST is directed, and neither of the methods addressed are completed. Therefore, there is no way to meet the JPMs task standard to align emergency makeup to the RWST with the critical steps provided.

Where is a PB key available? It says it is provided, but where does the applicant get one if he/she has to do this in real life? Good to test their knowledge on this.

Does obtaining the key mean that the other unit has been notified about the lineup to take from their RWST? May need to be added to the cues/initial conditions.

Reviewed during validation. The staff indicated that it is acceptable practice for an operator to be taking action to align more than one method of RWST makeup at a time, as presented in the JPM. The JPM was revised to address one method only, and the task standard was adjusted to match.

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: 0 Page 4 of 7 OBDI 202 - IOLE Process

$ 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 reviewers 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 7 OBDI 202 - IOLE Process

CP-2012-06 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 Is there a time requirement to secure the EDG when SSW is lost?

S I spotted the CCW pump trip response, but I didnt see the SSW trip response. Are there any actions for the operator?

If the first malfunction goes to a reactor trip, we need to check who is assigned to complete this to see if they can get their minimum exam attributes in the other scenarios.

Comments were resolved during validation.

2 E For securing the RCPs, is there a critical parameter (SCM, RCS pressure, etc.) that S drives when they need to be stopped?

Same question with establishing feed and bleed: are there critical parameters that if exceeded, would result in feed and bleed critical task not being met?

Similar comment on S/G instrument failures and reactor trip issue.

Comments were resolved during validation.

3 E Any time requirements with the S/G tube rupture isolation and cooldown critical tasks?

S Comments were resolved during validation.

4 E Similar question on SI and CS manual initiations: are there RCS/Containment pressures S that they need to initiate them before resulting in core/containment damage?

Since scenarios 1 and 4 have SSW pump trips (more action in this one), we will need to look at who is scheduled for which scenarios and ensure that they are not getting component failures they havent seen already in the test.

To meet the intent of NUREG-1021, ES-301, Section D.5.c, the low power scenario needs to be used in the exam.

Comments were resolved during validation. Plan is to use this scenario in the exam, with #1 as the spare.

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. 0 Page 6 of 7 OBDI 202 - IOLE Process

CP-2012-06 DRAFT OPERATING TEST COMMENTS SCENARIOS

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 7 of 7 OBDI 202 - IOLE Process
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