ML14310A419

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2014-10 Draft - Operating Test Comments
ML14310A419
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 10/24/2014
From: Vincent Gaddy
Operations Branch IV
To:
Entergy Operations
laura hurley
References
Download: ML14310A419 (6)
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Text

GG - 2014 - 10 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content
1. 3. Attributes
2. Errors 6.

Dyn 5.

JPM# LOD Explanation (D/S U/E/S (1-5) IC Cues Critical Scope Over- Job- Minutia (See below for instructions)

)

Focus Steps (N/B) lap Link RO (AR2) E S RO (AR3) E Revise the initiating cue Where the fuse(s) is/are located to include panel and terminal location to Identify the panel and terminal board location(s) for the fuse(s).

Revise the initiating cue What is the fail position for Z51-F001 when air is removed, to What is the fail position for Z51-F001 when the fuse(s) is(are) removed Edit comments were incorportated.

RO (AR4) E Change initial condition Max expected radiation exposure for containment entry is 2,000 mrem/hr. to Max expected dose rate for containment entry is 2,000 mrem/hr.

It is not clear from the initiating cues if this would be considered an emergency activity that would change the max dose allowed - clarify in the JPM.

The initiating cue, Calculate the maximum stay time before the current exposure limit is exceeded. Is not clear if this is based on 10CFR limits or plant admin limits (unless they are the same). Clarify.

The initiating cue Considering only TEDE and your exposure inside containment. Doesnt make sense as a stand alone cue; combine with the second initiating cue.

Revised the JPM as indicated above.

RO (AR5) E I would like to replace this JPM as it appears to be challenging from a logistical standpoint for exam administration. Will discuss on feedback phone call.

Will replace.

This JPM was replaced.

SRO (AS1) S No Comments.

SRO (AS2) S Provide a completed Attachment II of 01-S-06-5 to the JPM. Discuss the completed form critical steps with the facility.

Will provide.

This will be provided to the applicant.

SRO (AS3) S Is it necessary to tell the applicant to Use the Shutdown Operations Protection Plan (SOPP),

provided.? Seems like they should figure that out on their own.

Will revise.

This was revised.

SRO (AS4) E It is not clear from the initiating cues why the calculations for operator #1 and #2 are required for completing this JPM. These are critical steps.

Revising the initiating cue.

This was revised.

SRO (AS5) S No comments.

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 1 of 6 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 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 6 OBDI 202 - IOLE Process

GG - 2014 - 10 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 CR1 S No Comments.

CR2 S No Comments.

CR4 S No Comments.

CR5 S No Comments.

CR6 S No Comments.

CR7 S No Comments.

CR8 S No Comments.

CR9 S No Comments.

PS1 E General Comment - Include noun names with the alpha numeric designators (e.g., P53-F001) in the initial conditions.

Steps 1, 2, and 3 - Could not tell from the JPM if the valves listed had to be closed or not.

If the valves do not have to be closed (i.e., they are already closed), it is not a critical step.

These are not critical steps - no revision necessary.

Added noun names.

PS2 S No Comments.

PS3 S No Comments.

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 3 of 6 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 4 of 6 OBDI 202 - IOLE Process

GG - 2014 - 10 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 - Add CRS to all events in the event type box on the D-1s.

General Comment - Correct the event numbers on the D-2s (upper right hand corner of form).

Event 3 does not count as an event for the ATC as there are no verifiable actions taken according to the D-2.

Event 4 does not count as an event for the BOP as there are no verifiable actions taken according to the D-2.

Event 5 does not count as an event for the ATC as there are no verifiable actions taken according to the D-2.

Event 6 does not count as an event for the BOP as there are no verifiable actions taken according to the D-2.

Add places the reactor mode switch in shutdown when directed to the ATC actions on the D-2 for Event 7.

2 E General comment - Add CRS to all events in the event type box on the D-1s.

Event 2 does not count as an event for the ATC as there are no verifiable actions taken according to the D-2.

Event 3 does not count as an event for the BOP as there are no verifiable actions taken according to the D-2.

Event 5 - Add steps taken by the BOP to isolate RCIC to the D-2s.

Event 7 - Add specific steps taken by the BOP (including breaker numbers) for re-energizing bus 14AE.

3 E General comment - Add CRS to all events in the event type box on the D-1s.

Add one BOP malfunction for the BOP prior to the major event..

4 E General comment - Add CRS to all events in the event type box on the D-1s.

General comment - Remove EAL call from the scenario (page 13).

Event 1 - Add details to the D-2s on what valves are closed, pumps secured, etc to reduce loads on SSW A.

Event 4 does not count as an event for the ATC as there are no verifiable actions taken according to the D-2.

Event 5 - Change R to C for event type on D-1.

Change critical task 3 to Crew inserts control rods by manual scram and/or normal rod insertion per EP-2A step Q-1 following the ATWS.

5 E General comment - Add CRS to all events in the event type box on the D-1s.

Event 5 does not count as a TS call since a TS is not entered.

Event 8 - Provide details in D-2s on how HPCS is to be restored.

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 5 of 6 OBDI 202 - IOLE Process

GG - 2014 - 10 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 6 of 6 OBDI 202 - IOLE Process
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