ML14234A356

2014-07 Draft Op Test Comments

ML14234A356
Person / Time
Site:	Cooper
Issue date:	08/04/2014
From:	Vincent Gaddy Operations Branch IV
To:	Nebraska Public Power District (NPPD)
References
50-298/14-07 50-298/OL-14
Download: ML14234A356 (7)

Text

CN 2014-07 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 (A1) D 2 E Interpret Gardel Case. This is not challenging enough for this exam, it is mostly a direct look up, and was used on the 2008 initial exam (in a slightly different format). I did not mark it unsat because it is slightly debatable as a direct look up but I am requesting that it be replaced with a more challenging jpm. After discussion with the licensee, they agreed.

S Replaced with new JPM called RHR NPSH flow limit and renamed as RO A2.

JPM is now Sat.

RO (A2) D 2 E After this JPM was submitted, the licensee called and discussed that their procedures are not very explicit on the order that tags get cleared so they want to remove this JPM and submit another one, write a CR for the procedure issue with clearing tags and I agreed. I marked it as an E because the reference they provided did not completely support the answer, hence the controversy.

S Replaced with new JPM (RHR NPSH flow limit JPM) and JPM is now Sat.

RO (A3) D 2 S This is now the Diesel Fuel Oil JPM and is Sat.

RO (A4) D 2 E KA is wrong-KA G2.1.12 was deleted. It should be G2.1.25 or something similar. Also, this is not an EP JPM so need to fix the outline form ES-301-1 to reflect that this will be RO Admin A1, The NPSH flow JPM will be RO A2, The Diesel fuel oil will be the new RO A3, and RO A4 is the Radiation Protection tabletop.

S The Radiation protection tabletop JPM is Sat.

SRO A1 D 3 E With conductivity at the top of the list, this might cue the applicant that this is the parameter that is out S of spec. Recommend putting them in alphabetical order.

Done. JPM is sat.

SRO A2 D 2 E Need marked up reference to support answer.

S Licensee provided and it is now Sat.

SRO A3 D 3 E Need marked up reference to support answer.

S Licensee provided and it is now Sat.

SRO A4 D 3 S Same as RO Admin JPM A3.

SRO A5 D 3 E This is a time critical JPM. Please mark cue sheet, pedigree sheet as such (ensure it IS NOT on the S sheet that the applicant is given).

Done. JPM is now Sat.

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

• 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

CN-2014-07 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 a (S1) D 3 E Need reference to review. On the 2011 NRC exam. Done.

JPM Step 4 States to open the breaker, but under the standard for Step 4, the candidate is supposed to both open one breaker and close another. Need to make these the same.

Performance Step 9 does not match the standard (it states to put pumps in pull to lock but S the standard states to put breakers in PTL).

Made changes and JPM is now Sat.

b (S2) D 3 E Task standard is incorrect for this one. It uses the normal path task std which is not correct for an Alt Path JPM. Corrected.

For this JPM, the procedure requires contacting system engineer. Does this meet the definition of critical path in that it needs to be independent of crew dynamics? Granted, they dont have to rely on other operator actions. Is step 14 actually critical? Doesnt seem to be to me.

Added cue for system engineer, if asked, to give applicant question on what they recommend. Also, step 14 is critical since it is a perform step and is required to return to three element control and for completion of the task standard.

S JPM is now Sat.

c (S3) D 2 E KA was missing from JPM. Done.

Step 6 should be critical.

S Corrected and is now Sat.

d (S4) D 3 E Missing step 6.3 from 2.2.74 in JPM. Please add.

Licensee took steps to correct JPM by removing control of sec containment dp.

S JPM is now Sat.

e (S5) D E For Step 9, does the operator have to make adjustments? If not, its not critical, if so, it is critical. Step 11, change cue to ask the operator for his/her recommendation. Slightly edit Steps 13 and 14 to indicate that after initial throttling to about 70 gpm, operator can let go of the pump switch.

At validation week we determined step 9 was critical because actions were required in this step. Corrections made to note above step 13 and 14 for how two-handed operation is performed on these two steps.

S JPM is now Sat.

f (S6) D E Bold Step 2 of JPM. Also bold Steps 5, 6, 7, 9, 10, 11.

S Done and JPM is now Sat.

g (S7) D E Please bold the Steps that are critical and not just the standard. Done. Can we shorten this JPM by already having SW in service? Yes, Done. Alter cue in Step 13 to ask for operators recommendation. Done.

S Licensee made all corrections and JPM is now Sat.

h (S8) D S I (P1) S S 0 Page 3 of 7 OBDI 202 - IOLE Process

CN-2014-07 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 j (P2) S S k (P3) S 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 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 4 of 7 OBDI 202 - IOLE Process

CN-2014-07 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 Overall, this scenario appears to be ATC heavy. Anyway to swap one of the rd instrument/component malfunctions to BOP? On D-1 pg. 2 3 paragraph below description should be IF RR pump speeds,not IS.

Event 1: For BOP, provide valve #s for Step 5.7.

Event 2: Can we delete the cue about the DG being inoperable? The whole point of a TS call is that the SRO makes that call. However, the statement is supposed to be in the ARP, so I dont know if we can remove it.

Event 3: Add a bit more on ATC actions (like the fact that the power is increased using RR pump flow, maybe add in component #s and descriptors?)

Event 4: Add a possible TS call to the D-1.

Event 5: Ok Event 6: Need to revise cue to say once 5% power CHANGE. What is the BOP verifiable action (not apparent on D-2). Either need to make this clear on D-2 or remove the BOP from the D-1. Also, b/c the downpower is in response to the component malfunction in event 6, it does NOT count as a separate malfunction (also, can only count it as either a reactivity or a malfunction for the ATC, not both).

Event 7: Merge with event 6. Renumber the following malfunctions accordingly. Also, note that you can only count a reactivity manipulation as either a normal or a reactivity for the ATC, not both. In this case, delete the normal off the D-1 and keep the reactivity.

Event 8: Is there a need for a lead evaluator cue, or will it happen after a certain amount of time? CT looks ok, but what is the basis for 25 psig? Is it in an analysis somewhere? What are the BOP actions?

Event 9: For the CT, what is the basis for the 1337 psig limit?

Event 10: What verifiable actions do the BOP perform? It is unclear on the D-2 if the BOP actually physically trips the SAC1A pump or if he just directs that it is done locally.

If its done locally, what is his verifiable action?

Event 11: Ok. CT ok.

Event 12: Ok. Is there any CT with the RCIC downscale failure based on the other prior malfunctions (no FW, no HPCI). Are the other sources enough to maintain level is the operator fails to catch this malfunction?

Overall, there are a lot of malfunctions in this scenario. Too many?

Scenario 1 was completely rewritten with new instrument malfunctions added and S critical tasks enhanced for bounding conditions and the scenario is now Sat.

2 E Overall, this scenario has some complexities associated with the counting and categorization of the events. Some are classified as normal, but also include a malfunction component. Again, you cannot double count one event as two items for the same person (i.e. as a normal and reactivity event for the ATC, its one OR the other). Only 1 ATC action before the major, so at risk for meeting the required minimums.

Event 1: Add specific component/designators.

Event 2: Look at BOP actions, the first block didnt make sense to me. The D-2 states CRS directs BOP to put A train in service, but that is not part of the D-1 or the overview of the event. Also, remove end cue as the lead examiner does NOT cue the next event.

st Event 3: Typo in Note on 1 page. Again delete end statement as lead examiner does 0 Page 5 of 7 OBDI 202 - IOLE Process

CN-2014-07 DRAFT OPERATING TEST COMMENTS SCENARIOS NOT cue the next event.

Event 4: Classified as a normal but there is a malfunction piece. However, no diagnosis because the information comes from the local operator.

Event 5: Where does this event fit into the scenario. It seems unrelated to the rest of the scenario. But it does have an abnormal procedure entry.

Event 6: Same note about double counting. This may have multiple simulator malfunctions but is only 1 event, and so only counts as 1 component malfunction. Also delete end statement as lead examiner does NOT cue the next event.

Event 7: As a practice, please include the malfunctions as they occur in the mitigating strategy after the major and dont put them after. It makes it much harder to evaluate performance if were having to flip back and forth between pages, and we MUST at least know where the malfunctions occur. As an example, under event 7, need to include the fact that a drain valve failed to close when the ATC is doing the SDIV vent and drain valves closed verification step. Need to do this for all malfunctions after the major.

Event: Make a new event for the PCIS failure as it is a separate malfunction. Is it necessary for this scenario however? It was unclear in the D-2 how this malfunction impacts or complicates the mitigating strategy. CTs appear ok, but what is the basis for the 25 psig limit? Also, is there any safety significance if the torus exceeds 10 psig? If so, should that also be a CT?

S Scenario 2 was modified to correct the comments above and critical tasks were enhanced for bounding conditions and the scenario is now Sat.

3 E Again, do not count 1 event more than once per position (cannot count event 1 as a N and an R for the ATC, its one or the other). Notice that there is a pipe break in every scenario on this exam. Predictable?

Event 1: Add specifics, especially what rods should be moved and the rod positions.

Event 2: OK Event 3: Is BOP expected to start SW pump or not? Clarify.

Event 4: Perhaps provide a brief description of required TS action?

Event 5: Delete end statement, next event NOT lead evaluator cued.

Event 6: See statements in Scenario 2 comments about the flow of malfunctions following the major.

Event 7: CT does not match EOP step, either revise or explain the basis for the difference.

Event 8: OK Event 9: OK Explain how events 8 and 9 affect the overall mitigation strategy or complicate the event?

Overall note: this scenario had a lot of procedure steps that were just copy and pasted into the D-2. We need to know which of the actions the operators are expected to take.

S Scenario 3 was modified to correct the comments above and critical tasks were enhanced for bounding conditions and the scenario is now Sat.

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. 0 Page 6 of 7 OBDI 202 - IOLE Process

CN-2014-07 DRAFT OPERATING TEST COMMENTS SCENARIOS

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 7 of 7 OBDI 202 - IOLE Process