ML14279A080

08 Draft Operating Test Comments

ML14279A080
Person / Time
Site:	Diablo Canyon
Issue date:	08/08/2014
From:	Vincent Gaddy Operations Branch IV
To:	Pacific Gas & Electric Co
laura hurley
References
50-275/14-OL, 50-323/14-OL
Download: ML14279A080 (7)

Text

SITE - YEAR - MONTH 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 RO (A2) S 3 S Changed prompt to specify required boration to be determined in gallons.

RO (A3) S 3 S RO (A4) S 2 E This JPM has only one critical step. This usually would not be a good JPM. Lets discuss.

Added second valve alignment error for discharge source (PWR-01 aligned instead of PWR-01)

SRO (A5) S 2 E To enhance the discriminatory value of this JPM could we have the SRO applicant also determine that the LCO is incorrect and that another one applies?

Though current version meets LCO, it does require SRO to identify error in specified surveillance frequency (as completed calls for 2 hr surveillance when actual requirement is every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).

Updated answer key to clean up text markup on page.

Cleaned up answer key.

SRO (A6) S 2 S Changed prompt to specify required boration to be determined in gallons.

Corrected typographical error on job designation (changed from RO to SRO)

SRO (A7) S 3 S SRO (A8) S 2 E Same comment as A4. Would like to see A4 and A8 replaced with something more discriminatory unless this has been an established weakness at DC.

Added second error for RR-102 (Rad Recorder out of service)

SRO (A9) S 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 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. 0 Page 1 of 7 OBDI 202 - IOLE Process

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

SITE - YEAR - MONTH 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 2 E Do we want to include in the task standard that the results must be reported to the SFM?

That would make the report a critical step.

Agree - Removed report from task standard.

Editorial Comment - Step 2 of Examiner Handout has many sub-steps. Typically I would see these broken down into their own numbered steps. Also, make sure to include real procedure step in our handout so that we can follow the applicant as necessary and to aid in follow up questions.

Reformatted to break into single steps with comment areas. Verified left hand column of handout identifies corresponding procedure step.

S2 D 3 E Step 3.3 - Is the examiner looking for a red light in to ensure Phase A Isolation identified open? Please put exactly what we should see.

Modified description in step 3.3 to clarify indications of mispositioned Phase A valve (monitor light box white light ON and/or control board position light RED)

Added "Note: Alternate Path begins here" above step 2.1 (where examinee notes Phase A isolation RED lights are off)

S3 D 3 E Editorial Comment - Step 2, same comment as S1 with multiple steps included into one big step.

Reformatted to break into single steps with comment areas.

Separated auto-transfer reset into vital and non-vital components, with vital identified as critical steps.

Identified beginning of alternate path (point where examinee identifies RNO for cross-tie to Unit 2 startup power).

S4 D 2 E Step 2.3 - Depressed switch to start fan, should this step be marked critical?

Agree - Updated to include CFCU start as critical Identified beginning of alternate path (point where examinee determines high vibration PK alarm will not reset).

Expanded initiating cue to include note that all P&Ls are complete and to begin at step 6.4 S5 D 1 U Step 3 is the only critical step with the closure of one valve. LOD=1. Please replace.

Modified scenario to go further into failure which requires additional critical step for isolating letdown.

Corrected typographical error (LI-140 was listed as LI-149)

Made all letdown isolation steps critical (added closing of LCV-459 and LCV-460 as critical steps)

Identified beginning of alternate path (point where examinee transitions to OP AP-11, Section B to address in-leakage problem).

S6 D 1 U Step 4 is the only critical step with the operation of steam dumps. LOD=1. Please replace.

Modified to use condenser steam dumps 0 Page 3 of 7 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 Lowered initial temperature to be closer to P-12 and made new IC.

S7 D 3 S Modified initiating cue to state "perform immediate actions" Identified beginning of alternate path with note before step 4.3 (point where examinee determines rods should be moving but are not and takes manual control)

S8 D 2 S Updated task standard to "cold leg" (since unable to align RHR to hot leg due to failure)

Added note to identify beginning of alternate path just before step 4.1 (step where 8703 valve to hot leg loops fails to open)

P1 S 2 S No changes P2 S 3 S No changes P3 S 3 E Editorial Comment - Please place a time start and time stop not, where appropriate, in the examiner handout as this JPM is time critical.

No changes made based on feedback during validation (NRC was able to identify TCOA start/stop from existing documentation Updated directions to indicate JPM is to start at the Aux Board 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 0 Page 4 of 7 OBDI 202 - IOLE Process

resolution on this form. 0 Page 5 of 7 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 General comment for all instrument failures - Event 2 is PT-403 failure low. Please include noun name of this instrument in the D1 and in the event header on the D2. This will apply to all instrument failures for all scenarios.

Added noun name description for PT-403 (RCS Wide Range Pressure Transmitter) and PT-507 (Steam Generator Header Pressure Transmitter) to D1 and D2 event headers.

Noun-name edits for other scenarios are described in explanation section of each scenario.

Consider using Event 1 as a I/C failure instead of raising power. We could start the scenario at 2% and use this slot as an added I/C bean for the ATC.

Would like to discuss in detail; not clear on how to classify Event 1 as I/C failure unless combined with Event 2 (I would expect crew to stop ramp, which could work for giving ATC an additional bean; dont see how it would work if we start at 2%)

2 E E2 - What are the ramifications of moving to the next event prior to re-establishing letdown?

This event is based on plant O/E and the importance of plant parameter prioritization.

The crew is expected to recognize maintaining pressurizer level as the highest priority in this event since RCP bearing temperatures are being maintained by CCW thermal barrier cooling. Failure to reestablish letdown could confuse the diagnostics and/or prioritization since charging would have already been reduced to seals only and filter plugging may appear to be total loss of charging (lag between reduction in flow and high seal filter dp PK alarming).

E8 - Do not see the specific steps that establish feed flow from condensate which is a CT.

Revised location of CT to step that verifies CETs lowering WR level rising (step 10.a RNO) rather than generic direction for establishing flow (step 9.c.4)

From S1 Comments: Reviewed D1 and D2 headers for inclusion of instrument noun names and determined to have already included. Added noun names for Centrifugal Charging Pump, Turbine Driven Aux Feedwater, and Motor Driven Aux Feedwater Pumps to D1 and D2.

3 S From S1 Comments: Added noun name description for NI-44 (Power Range Nuclear Instrument) to D1 and D2 event headers. Noun-name edits for other scenarios are described in explanation section of each scenario. Also added noun name/description for Charging Injection Outlet Valves 8801A/B as well as for MSIV (Main Steam Isolation Valve) and MSLB (Main Steam Line Break).

4 S From S1 Comments: Added noun name description for LT-114, VCT Level Transmitter PCV-456, Pressurizer Pressure Control Valve for all instances in D1 and D2 Headers.

Also added noun description for Residual Heat Removal (RHR) and Containment Spray 0 Page 6 of 7 OBDI 202 - IOLE Process

SITE - YEAR - MONTH DRAFT OPERATING TEST COMMENTS SCENARIOS (CS).

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 7 of 7 OBDI 202 - IOLE Process