ML12297A451

2012-10 - Draft Ops Test Comments

ML12297A451
Person / Time
Site:	Cooper
Issue date:	10/30/2012
From:	Sean Hedger Operations Branch IV
To:	Nebraska Public Power District (NPPD)
laura hurley
References
Download: ML12297A451 (11)

Text

Attachment 10 Page 1 of 11 OBDI 202 - IOLE Process CNS-2012-10 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)

S 2

E S

Where is the acceptability band for the answer defined (2.3-2.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />)? Not apparent in procedure 2.4SDC. Addressed in JPM revision.

RO (A2)

S 2

X E

S The JPM references 6.LOG.60. Believe it is 6.LOG.601.

The attachment filled out is Attachment 3 vice Attachment 1.

Note (b) on Attachment 3 says that if the leak rate is >0.25 gpm, perform an investigation per 0-CNS-OP-109. Are there additional actions the operator needs to perform? Sound like an additional critical step is there. The comments have been addressed.

RO (A3)

S 3

X X

E S

The procedure referenced, 0.49 Schedule Risk Assessment, doesnt address how the applicant is to define equipment boundaries for a tagout/clearance order. Where is this defined? What are the criteria for 2-valve isolation of equipment (200F/500 psig)? RHR most likely meets single valve criteria, but the CCW cooling side (REC) may not be. Verify. Discussed, no need for 2 valve isolation on CCW side.

Are the tasks of identifying the system boundaries and determining the valve positions for the tagout/clearance typically given to separate operators in the plant? Typically, the person that identifies the isolation valves determines their needed position. They are not separate tasks. Added tasks to define which valves needed tags and what the valve positions needed to be.

Drain valves are considered optional as part of an equipment isolation? They are not marked as critical steps in the JPM. Discussed.

RHR-34 is included in the drain boundary in the evaluation criteria, but it isnt included on the Answer Key. Addressed.

If you are isolating the paths in and out of the RHR pump, why not ensure isolation on the RHR-388/389 and RHR-390/391 paths? (Sheet 1). After review, not necessary to be covered in the JPM.

RO (A4)

S 3

X E

S The calculations are for the release, not the release rate. Revised in JPM text.

Where is the acceptable error in the calculation defined (10% - procedure, ops guideline, etc.)? Will discuss as needed during exam administration.

SRO (A5)

S 3

X E

S With the surveillance handout, it doesnt show the date/time stamp on the pre-and post-surveillance RPIS printouts (needed). Actually, the length of time it has been mis-positioned is given in the cue statement, so it is not a very strong critical step. Revised to address this.

The Initiating Cue says to review the surveillance results and determine applicable actions based on your review. The various notifications are actions based on the results of the review. Therefore, they are critical steps to completing the task. These actions should be added to the Task Standard as well.

Revised to address this.

The titles of the management personnel to be notified of the mispositioned rod do not match those in procedure 10.13, Step 10.5. In addition, an action directed in procedure 10.13 for this situation is to initiate a Condition Report (Step 10.6). Revised to address this.

SRO (A6)

S 3

X E

S Are the two individuals called on-call? If so, 0-FFD-01, Section 16, Note 1 prohibits alcohol consumption. The ERO on-call list is different from the list that these individuals are on, so the Note is not applicable. No issue.

0 Page 2 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 The exception applied is Step 16.2.2, vice 16.2.1. Text revised.

Are the two individuals in the follow-up program, where they would need a BAC level lower than 0.04%

to pass? (0-FFD-01, Step 16.3.3). This was discussed. If nothing is mentioned about individuals being in the follow-up program, the applicants will assume it is not an issue. No changes needed.

Are the individuals required to respond to an emergency? (Step 16.3.6) It is assumed that the 2 Station Operators are 2 of the 3 Non-Licensed Operators required on watch in Modes 1-3 per Tech Spec 5.2.2.a. Are these minimum on-shift staffing positions in your E-Plan? If they are, Section 17 of the FFD procedure says that they have to be fit for duty at all times while filling that position. Check to see if this is in conflict with the setup in this JPM. These are not minimum staffing or E-Plan staffing positions. No issue.

SRO (A7)

S 3

X X

E S

If it is part of the task standard to identify that Jet Pump 13 DP is low out of spec, then it needs to be denoted in the critical tasks. This ensures that the applicant doesnt say Check 3 was unsat for a reason different than the reason we expect. Addressed.

Need to provide a copy of the Jet Pump Operability Curves to check the JPM results. This and the Power/Flow Map will be available to provide the applicant upon request.

Need an answer key that shows what we expect the applicant to indentify. Addressed.

Since there are no errors found on the review of Attachment 14, whether the applicant finds these or not has no effect on what the Task Standard is. These are not critical steps. Addressed in revision.

Fix the ES-301-1 and the JPM title to match the task (Jet Pump and Recirc ops checks). Revised.

SRO (A8)

S 3

S The procedure attachment to use is Attachment 3, not Attachment 2. No issues, attachment ID is for JPM document itself.

SRO (A9)

S 2

X X

U S

A SRO has to be able to make EAL classifications within 15 minutes of the information needed to make the call being available. Reference 10 CFR 50, Appendix E, Section IV.C.2. This JPM needs to be a) time critical for 15 minutes, and b) timed once they have read the cue sheet provided has been read.

The given JPM just looks for the applicant to make the right EAL classification as the Task Standard, which is incomplete. Resolved in revision.

It is unclear why an initial condition is that the conditions occurred 16 minutes ago. Technically by this, assessing the information that late has already compromised meeting the regulation stated above.

Removed from text.

Remove including procedural section from the Directions to Trainees sections. This is based on a validation comment that this would drive some of the applicants to research the EAL Bases without making a timely EAL call first for no reason. Text removed.

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 3 of 11 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 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 4 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 (a)

D 3

X E

S What indications would tell an applicant whether or not Heater Bay dose rates are expected to change excessively? Having this as provided condition test their knowledge of applying this to complete the procedure in the proper sequence.

Due to it saying there are normal radiological conditions in the plant, the applicant can assume that there is no reason for the Heater Bay dose rates to have changed excessively.

Would there be a specified cool down rate for this situation? Added to scenario cues.

Step 9 is not a critical step. Modify to show this. Revision made.

S2 (b)

D 2

X E

S There is nothing in the cue that says whether or not any special monitoring was set up on the EDG during its run. It helps in determining if Sections 8.18 and 8.19 are applicable or not. This should be addressed in the initial cues. Addressed in initial cues.

Do any of the voltage or frequency settings need to be within a certain range to allow for other switches to be operated? Discussed with staff.

Need CR on Simulator fidelity issue identified during validation. CR will be provided after exam.

S2 (b) for SRO-U D

3 X

E S

Make standard for JPM Step 6 match the procedure. Step 10.2.8.2 of procedure 2.2.9 says to allow the pump to run for 10 seconds, and then slowly open the valve. It doesnt say to keep cracking the valve open more and more over 10 seconds.

Step revised in JPM to reflect procedure text.

S3 (c)

D 1

X E

S The initial conditions say that Chemistry has requested operation of the valves per procedure 8.PASS.1. Procedure 2.2.68.1, Section 18, first Note says that the valves shall only be opened when requested by Chemistry per procedure 8.4.1.1. It is directed in Chemistry procedure 8.PASS.1, Step 5.3.1.

Initial conditions revised to be consistent with procedure 2.2.68.1.

S4 (d)

D 3

X E

S It says the applicant checks to make sure the proposed pressure reduction does not exceed a cooldown rate. What is the cooldown rate limit? Starting and end point of pressure adjusted so the applicant will not exceed the 100F/hr cooldown rate.

Procedure 2.2.77.1 says the ramp rate button is called RAMP RATE. The JPM says RATE. Addressed.

If the applicant was an operator in the control room, it would be expected that he/she would pull the alarm cards and take actions in accordance with these. They drive the crew to determine what Tricon active alarms are present with Alarm Codes, and then figure out the corrective action per procedure 2.2.77.1 Attachments 3 or 5.

0 Page 5 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 It is poor form to cue the applicant to keep going in manual and reduce pressure when the problem with the controls has not been identified and given some disposition path. It would not be expected that the SRO would direct the BOP to continue if he/she didnt know if the cause would affect further actions to reduce pressure. Review.

The last two comments were addressed by introducing an accident situation (scram and loss of HPCI) into the initial conditions. Resolved.

S5 (e)

D 3

X X

U S

The JPM steps do not line up with any of the start up sequences in procedure 2.2.67.1.

The sequence of Gland Seal Vacuum Pump startup and the introduction of Turbine Oil Cooling water is different in the procedure vice the JPM, for example. Valve manipulations after that are similar, but not in the same sequence as in the procedure.

Second, the procedure is being used to run RCIC to observe performance of the equipment. The alternate path is that there is a failure of the auto control, so the CRS directs the operator to take manual control to continue to raise turbine speed. The set up is not an emergency situation where RCIC flow is needed to the reactor and no other options are available. Therefore, why would the CRS direct the operator to continue a manual run of RCIC when there has been a control failure that needs to be promptly identified and corrected? This isnt conservative decision-making.

The JPM needs to be reviewed versus the procedure to make sure the steps are correct so that critical steps can be properly identified.

At validation, JPM replaced with acceptable JPM. Comments:

1)

The task standard needs to be modified to say that actions of Attachment 3 will be completed through Step 1.7. Revised to address.

2)

(Procedure comment) Review Attachment 3 steps 1.3.7 and 1.3.8. Appear to not be organized in the procedure outline structure correctly. Condition Report will capture this after the exam.

S6 (f)

D 3

X X

E S

To aide the examiners, note where the JPM steps are and what procedure.

Establishing minimum SGT flow is an objective at startup. Ensuring 800 scfm is indicated on SGT-FI-545 should be part of the critical tasks.

Does not removing the Reactor Building H&V System from service (procedure 2.2.73, step 6.3) affect their ability to address this task?

Procedure Comment: The alarm card referenced here provides checks to help determine the problem. However, when a problem is found (SGT-DPCV-546A closed, for example),

it doesnt give any direction on how to respond. This sets up your operators for potential confusion on how to deal with problems identified here.

Replaced with different JPM based on validation - too few steps with verifiable operator action. Comment on the replacement: When the A SGT high moisture alarm is received,

0 Page 6 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 the annunciator procedure says to start B SGT and secure A SGT. The JPM and the CRS cue say to secure A SGT and start B SGT. These are different. What is the site expectation?

Revised to be consistent with annunciator and system operations procedure.

S7 (g)

D 3

X E

S Specify what the APRM desired reading values are in the JPM.

Will all 6 APRMs need adjustment? Which ones?

Comments addressed with examiner note in the JPM allowing performance of one or up to six APRM gain adjustments.

Change JPM step 8 to record the initial APRM value vice the desired APRM value. See Step 5 of procedure Attachment 1. Revised to address comment.

S8 (h)

D 3

S (Procedure comment) In procedure 2.2.8, section 32. Need to clarify what the expectation is for several times in these procedure steps.

P1 (i)

D 3

S P2 (j)

D 3

X E

S If the procedure tells the applicant where the equipment locker is, how can any knowledge be demonstrated about where to pick up the equipment unless they are asked to show where the cabinet is located? The JPM note says this isnt necessary, but we would argue that it is.

Information about the equipment locker location added to JPM.

The initiating cues say the fire protection header is intact. This appears to be addressing Step 1.2.1.1.b.1 where it checks that the header to see if it is damaged and unavailable.

Is there any case where the header could be undamaged, but unavailable? Saying intact addresses the physical condition, but it doesnt address whether it is available to use or not.

Statement in Initial Conditions added to say that the Diesel Fire Pump is operating.

With the various valves that the procedure says to ensure they are in a certain position, how many of their positions would change? Those that do not change would not be critical steps for the JPM.

Validated and addressed.

Is there a reason that valves SW-118 and -120 are operated in the JPM in a different order than those written in the Step 1.2.1.1.b.6?

Revised to be consistent with the procedure step order.

What in the JPM tells the applicant that a portable fire pumper will not be used? Affects procedure step performance.

0 Page 7 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 Statement in Initial Conditions added to say that the Diesel Fire Pump is operating.

The Task Standard says that fire water is being injected. The steps completed align fire water to RHR, but it doesnt appear that the water is being injected.

Task Standard revised to be consistent with JPM task.

On ES-301-2s, change this from Safety Function 2 to 8. Addressed on ES-301-2s.

P3 (k)

D 3

X X

E S

Where does the drain tubing come from? What is the expectation for how it is attached correctly?

Addressed in JPM Examiner notes.

When the tube is removed, since it is potentially contaminated, what is the applicant supposed to do with it per your RP procedures? Added examiner notes to reference RP requirements for dealing with the tubing in the JPM (reference procedure 0-HOSE-CTRL.

Where can a 1/32 hex key be obtained in the plant?

Addressed in JPM Examiner notes.

The Task Standard needs to state that the flow is adjusted to the flow rate or the flow rate band per the procedure. Task Standard has been revised to address comment.

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 8 of 11 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.

0 Page 9 of 11 OBDI 202 - IOLE Process CNS-2012-10 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 X

E S

The description of the power ascension (Event 1) is not in the D-2s.

Event 3s steps are from procedure 6.RCIC.201, Step 4.3. For event 3, what are the BOPs indications that the valve failed to close? All of the indications shown are what he is supposed to verify, but it doesnt say what gives the indication that it didnt work as expected. Also, this would look better as an normal evolution if he has more than one step that he completes. Can the outboard valve pass the test, with the inboard valve failing the test?

For Events 5/6, is there a reason why the reactor must be scrammed if PC cannot be maintained below 1.5 psig? The critical task is written to the RPS set point, but procedure 2.4PC directs the crew to scram if they cant maintain pressure equal to or below 1.5 psig. Trying to define the correct Critical Task.

There is credit given in the ES-301-5 for a Major event and a component failure for Event 6. Per NUREG-1021, ES-301, Section D.5.d, this cannot be done. It is one or the other.

For Event 8, component failure credit is given to the ATC. If RCIC is isolated earlier after its event, what actions would the ATC take to inject CRD flow?

For ED on drywell temperature, what is DW/T-5 trying to protect against? The step says to initiate an ED if drywell temperature cannot be maintained less than 280F. This step has to be in there to protect against drywell temperature hitting a higher value that could cause a negative consequence in containment. Whatever this is, this is what the Critical Task should be written to measure against. Look in the EOP bases.

All comments here and from validation addressed.

2 X

X E

S On the ES-301-5, there is no one shown as the BOP for this scenario. This needs to be revised.

What is the basis for the 3 minutes (HPCI initiation critical task)? It isnt mentioned in in 2.4CSCS.

The Critical Task for Event 7 is not satisfactory. It needs pass/criteria. The rods have to be inserted prior to parameters reaching a certain value, a certain amount of time, before changing to another procedure, etc.

For Event 8, what happens if the runback of the recirc pump fails to occur? By the procedure step invoked for action (2.0.1.2), it appears that the failure of the pump to automatically runback has safety significance. If this is the case, this needs to be checked to see if there is a Critical Task associated with this or not.

What is the basis for the 10 minutes on the Event 9 Critical Task?

0 Page 10 of 11 OBDI 202 - IOLE Process CNS-2012-10 DRAFT OPERATING TEST COMMENTS SCENARIOS Items evaluated during validation and addressed.

3 X

X E

S ES-301-5: Event 7 is either the major event or a I/C failure. It cant count as both.

Discussed.

Event 1: If the power transient is greater than 10%, it may require securing hydrogen injection per Step 4.2. Does this need to be added to the D-2? Reviewed in validation.

Event 2: According to 2.4RR, Attachment 4, having any recirc pump scoop tube in lockout will prevent an automatic 45% recirc pump runback from occurring for neither pumps. Event 2 is a RFPT trip, which looks like it will cause a 45% auto runback signal (2.4MC-RF, Section 2.3). If this is the case, one of the operators will have manual actions to lower recirc pump flow to match demanded conditions? Reviewed during validation.

Event 3: What procedure has the RFPT restart steps? Resolved.

Event 8: There has to be some measurable performance indicator to judge against for the Critical Task. Resolved.

Procedure question: If you have Event 1 occur, how does procedure 2.4RR give you a path to restore to normal operation? It seems to leave the crew in manual local control of the recirc pump scoop tube with no path forward. Discussed with staff for corrective action.

From validation, believe there are some operator actions in Event 6 for upcoming MSIV closures on high steam space temperatures. Verify. Revision made to scenario to address comment.

4 X

E S

Event 2: If IRM A is bypassed, how can it be operable? Discussed and justified during validation.

Event 5: Any TS LCO 3.5.1 implications with an ADS valve fuses pulled? No.

Post Validation Comments:

1) For Event 5, it was found in validation that there is an entry/exit in TS LCO 3.6.1.4 on drywell pressure; TS 3.3.5.1 on taking the SRV to ADS Inhibit - need these added in.

Added Tech Specs into scenario guide.

2) For Event 2, TS and TRM LCOs, state what action is required based on action statement entry. Revisions made to address comment.

3) For Event 3, there was an entry into TS LCO 3.3.3.2 Condition A for 30 days. In the revision, it says it is considered but not applicable. Change was made to address Event 4 vice 3.

General comment: For steps from procedures, the procedure and step numbers should be referenced so they can be compared to the procedure if needed. Addressed.

Instructions for Completing Matrix

0 Page 11 of 11 OBDI 202 - IOLE Process CNS-2012-10 DRAFT OPERATING TEST COMMENTS SCENARIOS 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.