ML14140A135
| ML14140A135 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/02/2014 |
| From: | Chris Steely Operations Branch IV |
| To: | Entergy Operations |
| laura hurley | |
| References | |
| Download: ML14140A135 (10) | |
Text
Attachment 10 Page 1 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS ADMIN JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions)
RO (A1)
S 2
S Applicant Cue Sheet was same color as Examiner handout. Ensure ACS is green like the rest of the applicants handouts. This is a general comment that will apply to all JPMs.
Handouts to be printed on different colored paper than examiner materials Use validation to confirm answer number range.
Validation of this JPM was within number range RO (A2)
S 2
E This borders LOD=1 due to simple calculation. This one needs to be discussed. Also, make the applicant look up the TS on their own. Do not provide them the exact page as this is an open reference portion of the exam.
This is a repeat JPM from 2012. Changed the Applicant Cue Sheet to remove TS 3.9.1 and replace with Technical Specifications and removed the COLR and TS page from the handouts provided to the applicant.
Possible resolution is to provide the applicant with the entire COLR and the entire section 3.9 of Technical Specifications that way the JPM can be performed simultaneously to prevent having to make 12 copies of the entire Technical Specifications.
RO (A3)
S 2
E Circle/Slash procedure handout up to the step the applicant is required to begin for operational validity.
This would be a general comment on all JPM applicant handouts if the applicant is beginning in the middle of a procedure.
Reviewed each JPM handout for tasks started in the middle of the procedure and provided placekeeping as appropriate.
Do not see why Attachment 10.12 is necessary. Procedure directs you to attachment 10.16 for Acceptance Criteria once calculation is complete. On the cue sheet delete the reference in the Initiating Cues about where to look for the acceptance criteria. If you are following 10.9 correctly it will direct you to the right spot. Add on examiner answer key, where calculations are done, that acceptance criteria is not met.
0.12 is there because the procedure body step 7.9.5.17 directs the applicant to Record test results for SI-510B on Attachment 10.12, Results Summary Table. The handout included with the JPM contains the test data page which is not normally place kept. The step numbers are on the data page as an aid as to where to record the data from the steps in the main procedure body. The normally place kept portion of the procedure has been developed and will be provided as an additional handout.
The direction to check the acceptance criteria was added to the cue sheet to direct the applicant to perform not just the calculation but to document it in accordance with step 7.9.5.17 and evaluate it against acceptance criteria. Attachment 10.9 does not direct evaluating the test; it only states where acceptance criteria may be found. This cue was added to ensure that the applicant is absolutely clear as to what is the expected task. This was based upon feedback from validation.
Examiner answer key changed to show that acceptance criteria is not met
0 Page 2 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS ADMIN JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions)
RO (A4)
S 1
U LOD=1 Very simple calculation with no discriminatory value. Perhaps the K/A needs to be replaced if a better admin cant be generated.
JPM changed to evaluate meteorological conditions including wind speed, wind direction, and stability class in accordance with OP-007-003, Gaseous Waste Management and determine that a release is not allowed due to poor stability class. MET data and procedure flowchart provided. K/A changed to 2.3.11, Ability to control radiation releases (RO-3.8).
SRO (A5)
S 1
U LOD=1 Same comment as above. Very simple calculation problem which is actually already done with the applicant needing only to find the calculation error. Not discriminatory for SRO level applicant.
There are three major components for performing this task:
- 1. Calculate total amount of Feedwater on site.
- 3. Determine how long the plant can delay the cooldown (based on time after shutdown and RCPs running)
This JPM contains an error in the calculation of the total amount of Feedwater on site (step 1) and an error for determining how much water is required to conduct the cooldown (step 2).
The JPM then requires the applicant to use the correct curves to determine the maximum time until shutdown cooling conditions need to be met.
This JPM enhanced by adding a third error by the RO in that the wrong curve was used for step 3 in addition to the other 2 errors (No RCPs vs. 2 RCPs). This will extend the RO recommendation time to 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br />.
SRO (A6)
S 2
E Same comment as A2.
This is a repeat JPM from 2012. Changed the Applicant Cue Sheet to remove TS 3.9.1 and replace with Technical Specifications and removed the COLR and TS page from the handouts provided to the applicant.
Possible resolution is to provide the applicant with the entire COLR and the entire section 3.9 of Technical Specifications that way the JPM can be performed simultaneously to prevent having to make 12 copies of the entire Technical Specifications.
SRO (A7)
S 2
E Editorial comment - On the Answer key for the examiners put that acceptance criteria is not met and the applicable TS with action statement. Bold or highlight please. Also, DO NOT hand out TS to the applicant. They must determine where to look.
Examiner answer key changed to show that acceptance criteria is not met and attached a copy of the applicable tech spec with action statement identified. Removed the TS handout from the JPM.
Possible resolution is to provide the applicant with the entire section 3.4 of Technical Specifications that way the JPM can be performed simultaneously to prevent having to make 6 copies of the entire Technical Specifications.
0 Page 3 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS ADMIN JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions)
SRO (A8)
S 2
U Appears to be K/A mismatch. Do not see where applicant must have knowledge of exposure limits.
Looks like straight calculation problem.
K/A changed to 2.3.14 Knowledge of radiation or contamination hazards that may arise during normal, abnormal, or emergency conditions or activities (SRO-3.8).
SRO (A9)
S 3
S (Time Critical)
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:
x The initiating cue is not sufficiently clear to ensure the operator understands the task and how to begin.
x The JPM does not contain sufficient cues that are objective (not leading).
x All critical steps (elements) have not been properly identified.
x Scope of the task is either too narrow (N) or too broad (B).
x Excessive overlap with other part of operating test or written examination.
- 4.
Check the appropriate box when a job content error is identified:
x Topics not linked to job content (e.g., disguised task, not required in real job).
x 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 4 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions)
S1 D
3 S
No applicant handout provided to review. Please send.
Will provide a copy of procedure handouts for all simulator JPMs placekept where appropriate.
S2 D
3 E
(Time Critical) No applicant handout provided to review. Please send. Put Time Critical Step in bold on each step where applicable to aid examiners.
Time critical steps bolded at applicable steps Notate Alternate Path Begins Here on the step where applicable to aid examiners. This will be a general comment to apply to all alternate path JPMs.
Alternate Path JPMs revised to include an examiner note that states where each alternate path begins inside of the applicable TE.
S3 D
3 E
Should TE 2 be critical which is starting Lift Oil Pump?
TE 11 critical to start Lift Oil Pump?
TE 2 and TE 11 are not critical because the oil pumps will auto start once the RCP is stopped and will not result in any damage to the RCPs. The expected behavior is that each applicant will start at least one prior to stopping a RCP so as to not test the interlock.
Task Element 7, Make Examiner Note bold and change Examiner Cue to 5 minutes have elapsed. Task Element 8, change wording after OP-901-130 to Acknowledge applicants statement. (do not cue them where to go, if asked, ask for their recommendation)
Incorporated changes to TE 7 and TE 8.
S4 D
2 E
No applicant handout to review.
TE 6 critical?
The as found condition of the valve is closed. The controller is in automatic but the task can be completed by not performing this step.
TE 14, Examiner note, change may raise to raises.
TE 15, Change Examiner Cue to Examiner Note about temperature setpoint being in the Initiating Cue.
Incorporated changes to notes and cues S5 D
2 E
No applicant handout to review.
Initiating Cue Sheet - CRS directs you to reset the CSAS in accordance with Use
0 Page 5 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions) wording from procedure.
Incorporated change to cue sheet S6 D
3 E
No applicant handout to review.
TE 3 - Bus A Transfer Switch is this how it is labeled on panel?
Labeled as Bus A Transfer Bold and notate in TE 8 that alternate path begins here.
Examiner note exists above TE 7 which is the step that induces the fault that The fault is inserted at the following step and these steps should be performed from memory. An additional bolded note was added in TE 8.
Remove cue to inform applicant to perform SPTAs as they should automatically perform these actions. A cue to remind them that they are the BOP should be ok. Also, what will be the final condition of bus B3 if applicant stops after opening breaker 3-2? Would this be a natural stopping point?
Under normal conditions, the CRS directs the operators to perform SPTAs. The cue was placed in there to give the JPM more operational validity as this is how the stations operators train and behave. This is also how it was validated and ensures this doesnt lead to applicant confusion as to what is expected of them.
The final condition after opening the 3-2 breaker will be that the EDG will automatically close in its output breaker and reenergize the safety bus. This is a natural stopping point for this JPM, but under normal dynamic simulator scenarios, the BOP would perform several other checks and verifications to verify all safety functions. This JPM stops at the beginning of the safety functions as this is what we are examining for.
S7 D
2 S
No applicant handout to review.
S8 D
3 E
Applicant handout provided with this JPM.
Bold note on TE 6 that alternate path begins here.
There is an examiner note above TE 6 that describes the events that are about to take place. A bolded note has been added to TE 6.
TE 7 is a critical step and is able to be done in the CR. What would Ops Management expect? Shouldnt this be done in the CR instead of locally?
The critical element is to close the valve and is done from the control room. Later in the procedure it describes securing from the lineup which includes stopping the pump. The pump stopping is not a critical element but was only added to the JPM in case the applicant also decided to perform this step and the examiner and the booth operator would have some
0 Page 6 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS
- 3. Attributes
- 4. Job Content Errors JPM#
- 1.
Dyn (D/S)
- 2.
LOD (1-5)
IC Focus Cues Critical Steps Scope (N/B)
Over-lap Job-Link Minutia
- 5.
U/E/S
- 6.
Explanation (See below for instructions) guidance.
P1 S
2 S?
Procedurial editorial note: step 11.4.2 of OP-009-003, says to close the Nitrogen/Instrument Air supply valve but does not give the actual valve number NG-827B.
Consider adding the valve number to the procedure.
The valve number and nomenclature is contained in the procedure and the handout provided.
It is not in a clear location but is located under step 11.4.8. This has been identified and captured on a document of issues to address after exam security has been relaxed for this exam.
Is there air available after a SBO? If not, then TE 5 is not critical and reduces this JPM to very few critical steps. Lets discuss.
There are Nitrogen accumulators for these valves that allow operation during a SBO. The concern in this JPM is that the station batteries are degraded so that control signal to the valve is the means of the loss of control not motive force. Air must be bled off in order to manually operate the valve. This JPM is a high priority for an important operator action in accordance with WF3 PRA.
P2 S
3 E
Do not see the alternate path through this JPM. Lets discuss.
Alternate Path is inserted at TE 13 when no voltage is indicated and the method of correcting it is to depress the SUPS014AB Inverter Operate Pushbutton TE 14. Examiner Note added to TE 13 designating the beginning of the Alternate Path.
P3 S
3 S
TE 4 has the applicant open all Non-Safety load breakers. Dont see these (as given in examiner handout) listed in the procedure. How does the applicant know which breakers are non-safety? Are they noted as such on the panel? Also, are there any breakers not listed? Is it critical if any safety related breakers are turned off?
Procedure improvement will be generated after exam security has been relaxed to add more detail to the procedure. The bus itself identifies a safety section and a non-safety section. If an applicant were to open a safety related breaker and not reclose it that would constitute a failure of the JPM.
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.
0 Page 7 of 10 OBDI 202 - IOLE Process
$ 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:
x Topics not linked to job content (e.g., disguised task, not required in real job).
x 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 8 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS SCENARIOS Scenario Set
- 1.
- 2.
TS
- 3.
Crit
- 4.
- 5.
Pred
- 6.
TL
- 7.
L/C
- 8.
Eff
- 9.
U/E/S
- 10. Explanation (See below for instructions) 1 E
E3 - pg. 9/27, the examiner note says that SRO should determine that a power reduction is required within 60 minutes. Caution says that it should be 15 minutes.
Appears Caution is correct when compared to OP-901-102.
The Technical Specification 3.1.3.1c directs a power reduction in accordance with the COLR Figure 3. This is a graph that requires that the power reduction be started within 15 minutes and must be completed within 60 minutes. Both statements are true.
Editorial note: pg. 16/27, reverse the order of these examiner notes for readability.
Notes have been reversed Examiner note pg. 17/27, what is this note saying? Lets discuss.
This note describes that the sequence of events of event 4 will carry on after events 5 and 6 are complete. Specifically the reactor will trip (Event 4), then 2 contingencies will need to be performed while in SPTAs. Since these are described as discrete events, they were given specific sections in the D-2. If one examiner is evaluating the ATC during the scenario, this examiner will use pages 18 and 19 (Event 5). The BOP evaluator will not use pages 18 and 19 but will use page 20 (Event 6). The crew will transition back to SPTAs after events 5 & 6 have been completed and the examiners will proceed to page 21 which is still in event 4 prior to Event 7.
Critical Task note pg. 18/27, does this mean the CT is not met if it hasnt been started prior to step 2 or if it has not been ordered?
This means that the CT is not met if the crew does not recognize the condition and take actions to perform the task. If the CRS reads from the procedure to verify Reactivity Control to the ATC and the ATC or CRS does not recognize that the Safety Function is not met and proceeds to subsequent steps, then the CT is not met. I anticipate that this will occur from the ATC by memory, but the CT is not exceeded until the procedure step is read from the book by the CRS to the ATC and the step missed.
E5 - pg. 19/27, Close VCT Discharge Valve, CVC-183 is marked CRITICAL. What does this mean? It doesnt appear to be a CT but marked as a critical step as in a JPM which would be incorrect for a scenario.
This was done to annotate the steps needed to complete the critical task. If this step is not performed, then the task is not complete. These can be removed if desired.
0 Page 9 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS SCENARIOS E6 - pg. 20/27, why 443F on the CT?
443qF was chosen as this is the TS cooldown limitation based on TCOLD 543qf E4 - pg. 21/27, If SI happens will TC be < 443? What if crew inserts and unneeded SI?
This could potentially be a write in CT.
If the crew delays tripping the main turbine, SI will actuate (RCS pressure of 1684 PSIA).
This actuation of a SI would not necessarily affect the ability of the crew to mitigate the accident that will be occurring. This would not be a critical task as it does not challenge a fission product barrier such as an unmitigated cooldown challenges the RCS barrier. If the SI were to occur and RCS pressure were to reduce below shutoff head for a considerable amount of time, then RCS temperature will continue to lower. If the crew stops the steam flow to the turbine, then RCS pressure would quickly rise slowing and then stopping the SI flow which would improve RCS temperature. There are scenarios where SI could occur but the crew would still be able to halt the cooldown. The CT performance should be parameter based off of RCS TCOLD.
2 E
E2 - Need to work through the Pump in Lead table with facility to get a thorough understanding for examiners.
This would be best accomplished during prep week.
E4 - Appears that if the crew does not start the standby TCCW pump, and incorrectly allows the reactor to trip, this would become a write-in CT.
Not sure what the critical task would be. There is no safety significance allowing the main turbine to trip. In this scenario if the turbine were to trip due to high vibration the plant would experience a Reactor Power cutback (automatic rapid power reduction by dropping selected CEAs) and not a Reactor Trip.
E5 and D1 - Editorial note change not before Thot reduced below 520F to after Thot reduced below 520F.
Critical Task statement changed on D-2 and D-1 for this scenario.
3 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 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.
0 Page 10 of 10 OBDI 202 - IOLE Process W3 - 2014 - 04 DRAFT OPERATING TEST COMMENTS SCENARIOS
- 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.