Text

2015-11-PROPOSED Operating Test Comments
	ML16036A384
Person / Time
Site:	Wolf Creek
Issue date:	11/13/2015
From:	Vincent Gaddy; Operations Branch IV
To:	;
References
	Download: ML16036A384 (14)
	v • d • e

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. For some reason, when you print page 1 of the JPM, it shows RA1and not A1 - hidden text? It then shows up in the document after you print out the page. Weird. Fixed.

2. Add ALR(s) for annunciators 61A/61B to General Refs since identified in init cond as in alarm. Also add AI 21D-004, SECONDARY RADIATION MONITOR SETPOINT CALCULATIONS Added

3. Add to last sentence of Init Cond that Attach C of OFN is being provided. Added

4. Where does AIF 21D-004-01-03 come from? AI 21D-004 identifies AIF 21D-004-01 in Section 8.0 FORMS but doesnt identify -01, -02 or -03. How is this form controlled? This document is provided by chemistry after base line numbers are determined they provide the current version which is stored in the control room by the RM-11

5. Change Initiating Cue to read Determine what actions are required per Attachment C of OFN BB-07A, STEAM GENERATOR TUBE LEAKAGE since the Initial Conditions state that is what is being performed and not enough info is provided for the applicant to start at Step 1 of the OFN. Added

5. JPM Step 1 - for Standard, use same range for correct answer (107-109) whether by calculation or by straight edge. Changed

6. JPM Step 1 - to confirm, having determination of gpd leakage (107-109) and Required Actions E (Step C5) in the same step marked as a Critical Step means that getting either of the two answers RO (A1) 2 X S wrong means failure of the JPM. Split steps up

7. JPM Step 2 - in Step C5, it has (Action Level 3 - EPRI limit) - what does EPRI stand for? Electric power research institute

8. Terminating Cue for JPM doesnt need to repeat Task Standard. Acceptable to just state When applicant indicates assigned task is complete. Changed

9. With the information given in Init Conditions, and Foldout Page for OFN BB-07A, 2. AFFECTED S/G ISOLATION CRITERIA, IF any S/G level increases in an uncontrolled manner OR any S/G has abnormal radiation, AND NR level in affected S/G(s) is greater than 29%, THEN perform the following.

a. Close affected S/G AFW flow control valves. is it not true that this applies and the AFW flow control valve to D S/G should be closed? If so, this should be added to the Task Standard. The initial conditions did not have the student determine what SG it is in. This step will have already been performed before the crew even gets this deep into this attachment so unless we change the standard to what is everything the crew will do I dont want to add it.

10. PEO - Step 2.1 of OFN BB-07A, SGTL, identifies GE RE-92 as Main Condenser Vacuum Pump Vent Radiation Monitor but Attach C and SY1407300 (Rev 017) have Condenser Air Discharge (I put marked up procedures in PEO folder) Noted

1. Move the Chemistry sample results from Initiating Cue to Initial Conditions. Moved

2. Revise Task Standard to read Using EMG ES-04, Attachment A, the applicant determined RCS Boron Concentration Based On Total Mass to be 1590-1592 ppm. Changed

3. Make sure all handout copies of the NPIS Pressurizer / PRT picture are of good quality so values are easy to read. Dont make copies of copies. Noted

4. JPM Step 3: Make acceptable range 105-106 since this is a calculated value. Changed

5. JPM Step 4: Make acceptable range 1485-1486 since this is a calculated value. Changed E 6. JPM Step 5: Make acceptable range 1590-1592 using the lowest and highest values of previous RO (A2) 2 X X S acceptable ranges. Changed

7. Make JPM Steps 3 and 4 Critical Steps to capture the need to demonstrate how the correct answer is achieved, not just getting the correct answer. Added critical step

8. Discuss option of requiring applicant to also perform some or all of ES-04, Step 9.a, Determine required shutdown margin for Cold Shutdown, using STS RE-004, SHUTDOWN MARGIN DETERMINATION. Attachment A, SHUTDOWN MARGIN CALCULATION SHORT FORM, appears to be a more challenging task which would raise the LOD. Will discuss during validation week. That could stand alone as a JPM without adding it to this one.

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. Add the word KEY and put the rev number inside the document A3 key rev 0 (see attached file)

Added

2. Revise the Initial Conditions to read The Plant is steady at 100% power, however, the AFD Monitor Alarm has been declared inoperable. Control Rods are in Manual. The following data is present on plant instrumentation. All four NI channels are operable. Move the table of % Power and % Flux Diff to Initial Conditions from Initiating Cue. Added

3. Revise the Initiating Cue to read The CRS directs you to determine the axial flux difference by performing STS SF-002, Core Axial Flux Difference. WCGS Cycle 21, COLR Rev 0, Fig 2.5, Axial Flux Difference Limits is provided. The applicant can sign off the pre-reqs with information given in the Initial Conditions. Is it correct that the applicant will be provided a complete copy of the STS and COLR Fig. 2.5? We normally perform these JPMs in the exam room which has all references so we can give them one or let them find it and use the one in the exam room.

4. Add to Required Materials - WCGS Cycle 21, COLR Rev 0, Fig 2.5, Axial Flux Difference Limits Added

5. Need to explain the -41/-42/-43/-44B (Power Level) and -41/-42/-43/-44C (Power Range Flux Diff)

E RO (A3) 2 X X S

on the Attachment A Form. On the main control board the NIs end with a B since the A one is on the excore instrument panel in the back of the control room. The C ones are also on the main control board and they show the difference in the upper and lower detectors for the power range (delta I)

6. In Section 8.0, some of the numbers are underlined (8.1.1, 8.1.3, 8.3) - what does this mean?

Means that data is required to be gathered by the operator. AP 15C-001 discusses this

7. Make JPM Step 2 a non-Critical Step because this is the mental comparison step Deleted

8. Make JPM Step 3 a Critical Step because this is where the results of the mental comparison are recorded (designated). Added

9. For JPM Step 4, revise the Standard to read Determined that two operable power range channels were outside the acceptable limits of COLR Fig 2.5 and informed the CRS to refer to Tech Spec 3.2.3.

Changed

10. Generic Note - the Standard for all JPM steps is past tense. This standard is commonly referred to as the Performance Standard so as not to confuse with the JPM Task Standard. Noted

11. Revise the JPM Task Standard to read Using STS SF-002, Core Axial Flux Difference, the applicant determined that two operable power range channels were outside the acceptable limits of COLR Fig 2.5 and informed the CRS to refer to Tech Spec 3.2.3. Changed

1. All handouts, refs, and keys need a revision number - both in the title and body of document. Done

2. Add the word KEY inside the documents for Mechanic Key, Operator1 Key, Operator2 Key (see attached files) Done

3. Revise Task Standard to read Using the Projected Dose and Exposure Authorized information on Form EPF 06-013-02 for each individual, the applicant calculated the stay time for TEDE, Thyroid and Extremities, then documented the most limiting stay time and it basis in the Comments section.

Changed

4. Revise Initiating Cue to read Using the , determine for each individual the most limiting stay time U and its basis in the Comments section of the EPF form. Changed RO (A4) 2 X S 5. JPM Step 1 - revise the Standard to read Recognized the Projected Dose and Exposure Authorized dose numbers for TEDE, Thyroid and Extremities on EPF 06-013-02, Emergency Exposure Authorization, for Operator 1. Calculated the stay time for each exposure, then documented the most limiting stay time in the Comments section of the form. Changed for all standards for each calculation

6. The key for determining the most limiting stay time for each individual for all exposures (TEDE, Thyroid, Extremities) is that the applicant CAN NOT round up. Regardless of how many digits the applicant uses for time in minutes, the highest acceptable time to meet the Critical Step is a rounding down of the time. For example: if 0.3258 hr x 60 min/hr = 19.548 min, then either 19.548 or 19.54 or 19.5 min is acceptable. Any rounding up of stay time will result in an UNSAT for the Critical Step and

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link therefore a JPM failure. Ranges are given for this one similar to A2 so I dont understand why this would be an issue here but not in A2.

7. Need to discuss whether the basis of the stay time (TEDE, Thyroid, Extremities) should be considered required for a SAT Critical Step. This was added by you and not sure what you want as a basis. We were just going to use which was the most limiting and the answer.

8. Need to discuss the value of the applicant performing the same calculations for 3 individuals instead of 2 (one operator, one mechanic). Can shorten this to 2 if that is acceptable

8. Using the above, revise all JPM steps accordingly. Changed for all 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 RED text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. See comments for A1. Added

2. This is designed to be identical to JPM A1? Yes

3. This JPM can be modified to include an SRO task to differentiate between RO/SRO. Consider revising the Initial Conditions to read GE RE-92 trended up to a value of 4.6E-006 uci/cc and then the monitor failed and is no longer available. Then revise the Initiating Cue to read Determine what actions are required per Attachment C of OFN BB-07A, STEAM GENERATOR TUBE LEAKAGE. In E addition, determine the operational implication of the failed GE RE-92 radiation monitor. Then create SRO (A5) 2 X S JPM Step 3 (Critical Step) with a Performance Standard of identifying TR 3.3.18, Primary to Secondary LEAKAGE Detection Instrumentation. Identify the specific Condition if one exists. Could revise this for that but there is no TRM call for this. The leakage is over 75 gpd and its only one monitor.

4. I couldnt find a copy of the Tech Requirements Manual (TRM) as part of the Ref Material CDs sent to NRC. If the TRM wasnt part of the submittal, send an electronic copy of the TRM to NRC. Sent

1. See comments for A2 - correct those that are applicable to this JPM. Changed

2. Note: A6 ref 3 key is the correctly completed Attach A (boron conc in form match Initial Conditions). This is actually an Answer Key, not a reference. Changed title

3. Note: A6 ref 4 is the incorrectly completed Attach A (boron conc swapped - Hot Leg Loop 3 and PZR). This is actually a handout, not a reference. Changed title

4. Not sure how Required Materials is defined, but it should be identified somewhere in the JPM body that there are two Attachment A forms (one correct - answer key, one incorrect). Recommend adding a Handouts section to the JPM format for next exam. Added a comment to JPM

5. The 4.0 Answer Key would be a scanned copy of the incorrect form with pen and ink changes for the corrections. Noted

6. Not sure why page 18 of ES-04 (Step 10) is included in ref 3 and ref 4 files. Added because this is the step that tells you to perform attachment A

7. JPM Step 1 - what is the impact if the errors are not found: Total mass of 1604.01 instead of correct value of 1590.99. This step is NOT marked as a Critical Step. Not marked critical since you E

SRO (A6) 2 X ?

S could get this wrong but per the task standard the answer is disapprove and determine TS not to get the correct boron addition.

8. Examiner Note prior to JPM Step 5: Revise to read Use the Answer Key of EMG ES-04, Attachment A, to compare with applicant results. Added

9. Initiating Cue: How does the CRS approve or disapprove this Attachment (no place for signature)?

How would this be done in the Control Room? If boron concentration was greater than required then the procedure would continue. If it was less then boration would continue. This step is a verification step that the CRS must agree (approve) to or not move on. We call it approve and yes this is the way they control room would perform this action.

10. Revise Initiating Cue to read: In accordance with ES-04, Step 10.c, check RCS Boron concentration calculated from Attachment A is greater than Cold Shutdown Concentration. If any operational implications are identified, document on the bottom of Attachment A. Changed

11. Add JPM Step 8 (Critical Step) to capture the need to return to ES-04 Step 9 to continue boration to cold shutdown boron concentration - per ES-04, Step 10.c RNO. Added new JPM step to return to step 9 and continue boration

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link

1. A7 ref 1 rev 0 is actually A7 Handout 1 Rev 0 - need to distinguish between references and handouts. Make sure this handout is a clean copy - completed and scanned into a .pdf file (not like the unreadable MS Word copy provided - might be a factor of different versions of MS Word). It is a clean copy we are using MS word 2010.

2. Initial Conditions: add procedure name, rev, and noun name of valve. (see below) Added

3. Initial Conditions - does there need to be a reason stated for performing STN BG-202? Does partial mean only performing Section 8.4? Revise to read The RO has completed Section 8.4 of STN BG-202, CHEMICAL & VOLUME CONTROL SYSTEM VALVE TEST, Rev 1, for BG HV-8357A, CCP A DISCHARGE TO SEAL INJECTION FILTERS ISO VLV. Could be performing for many reasons. Partial is only performing the section needed. Added to initial conditions

4. Initial Conditions - since there are TS implications for given Mode (P&L 4.2, 4.3), does there need to be a statement about TS? Added mode 3 to initial conditions so the correct TS will be used.

5. The procedure uses a term PIT - what does this mean? Position Indication Test

6. Examiner NOTE prior to JPM Step 1 - the applicant will be given the STN handout, but not the TS or Bases. These will be made available to the applicant, but not specifically handed out. Admin JPMs Step 1 are given in the exam room where are the references are for each student. The TS will not be given

-1 U out they will have to look them up.

SRO (A7) X X S 7. JPM Step 1 - with the completed Attachment marked as Unsat for failing the PIT requirement, and Step 2 the Required Action (1) identified that says if the valve is Unsat, the valve fails the surveillance test

-2 and is inoperable - this is a direct lookup. The only knowledge or ability tested is the ability to read.

8. JPM Step 2 - no reference provided for the appropriate portion of TS bases (other than identifying Section 3.5.2) (I found it on top of page B 3.5.2-6) Admin JPMs are given in the exam room where are the references are for each student. The TS will not be given out they will have to look them up.

9. JPM Step 2 - should the applicant be expected to know that CCP A (and CCP B) needs to be evaluated for operability besides the Initiating Cue? Possibly asking for operational implications? If its in the Cue, the LOD = 2. If the applicant needs to determine the evaluation is necessary without a cue, then LOD = 3. No. This is OE from the plant that the CCP has been missed for this. These are new operators and will not know the past OE for everything.

10. JPM Step 2 - the Standard needs to identify more detail about how the applicant determines that CCP A is operable (to avoid them getting it correct by guessing). Also, the Standard states both CCPs may be considered operable, not just A. Should the applicant be required to determine operability of both CCPs? The standard only discusses the A CCP and the student should not be required to know about both since this valve is not associated with the B CCP. Added a comment to step 2 of JPM as to how the student gets to this conclusion.

1. A8 ref 1 rev 0 is actually a handout. It also contains 2 pages but permit header says there are 3 pages (Page 1 of 3). Is a page missing? Page is not used but could be added back if need be.

2. How would this form look if a purge had been initiated then stopped? Is the same form used to reinitiate a purge? How does the SM sign the form a second time? It would be more operationally valid to complete the form with initials/signatures and then scan the form. This form was made off of an archived form that was used in the past so this is exactly what it will look like. We dont like to right on the forms used for JPMs since this could introduce an error in reading we always use a typed form E

SRO (A8) 2 X S

when we can.

3. It would be helpful to generate an Answer Key with errors circled or otherwise identified. Made key

4. Move RM11 indications from Initiating Cue to Initial Conditions. Moved

5. Initiating Cue: Revise to read The Operations Manager directs you to re-start the Containment purge if all conditions are met. This direction would not come from the ops manager it would be from the SM who is spelled out in the initial conditions.

6. Given the Initial Conditions identify that a release had been initiated and then stopped - would the error that is in the Release Conditions (transposed setpoints for the rad monitors) have been incorrect

WC - 2015 - 11 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 Crit Scope Over- Job- Minutia (See below for instructions)

Focus Steps (N/B) lap Link for the initial purge? If so, this is not acceptable for a JPM. No the values are added when the re-initiation is taking place. The only numbers that are on page 2 would be the high limit not the current readings.

1. A9 CR001 ref 2 rev 0 is actually a handout, correct? Relabeled

2. For the Initial Conditions - the scenario is that the Crew Shift Mgr (SM) declared the SAE and completed the EPF 06-007-01, Wolf Creek Generating Station Emergency Notification form? The SM would then be designated the Site Emergency Mgr per EPP 06-001, Step 7.1.3. Per this step, the SM may NOT delegate Authorization of Notification of Off-site Authorities and PARs so its not clear why/how the Off-Site Emergency Mgr (in the EOF?) is preparing the Emergency Notification form.

Added words to the initial conditions to set up all EP facilities are activated. Once the facilities are activated, the responsibilities are shifted to the Site Emergency Manager (TSC), then to the Off-Site Emergency Manager (EOF). The non-delegable duties are the responsibility of the Emergency Manager, which will be the OFF-Ste Emergency Manager once the EOF is activated. The Emergency Managers are performing SRO level actions when completing the Emergency Notification.

3. On the Emergency Notification form (EPF 06-007-01), Step 4, Emergency Classification, it has TIME: 30 min ago. The timeline for this JPM scenario isnt clear - is this task a follow up notification that occurs after the initial SAE classification and notification? What EPP describes this task? This is a PAR only with no change in classification. EPP 06-007 step 7.1.1 requires an Immediate Notification be made for the change in protective action recommendation. The time of the original Classification will not change. The timeline for this JPM starts when the EDCP is handed to the Applicant, and stops when the Applicant hands in the form. The 15 minute time requirement starts when the Applicant receives the form, and ends with the time the Applicant writes in section 8, TIME/DATE of PAR Only, on the Emergency Notification form.

4. JPM Step 2 - What is the basis of the 15 min Time Critical requirement? Per NUREG 1021, this U

SRO (A9) ? X X X S

must be a regulatory requirement or NRC commitment. It needs to be clearly identified in the Standard. The 15 minute criterion is delineated in NEI 99-02, Revision 7, section 2.4, EMERGENCY PREPAREDNESS CORNERSTONE. Additionally, 10 CFR 50, Appendix E, Section IV.C.2 requirements state By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

The change in the Protective Action Recommendation is a change in the emergency condition.

5. JPM Step 1 - What EPP describes the EDCP? EPP 06-012, DOSE ASSESSMENT, provides directions on utilizing the EDCP program to develop protective action recommendations.

6. List of Required Materials is difficult to determine. Suggest using bullet format or at least separate the list by 1),.., 2), 3) etc. Separated them as a list.

7. JPM Step 1 - identify that the procedure step is from EPP 06-006. Revised the JPM to include the steps from EPP 06-006 and EPP 06-007. This should provide a clearer understanding of what information is provided on the KEY and how that information was derived.

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 RED text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

WC - 2015 - 11 Rev 1 PROPOSED OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

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

Focus Steps (N/B) lap Link

1) Will any of the steps prior to Performance Step 13 (Step 6.2.13) prevent CCP B from being started? The pump has to run in order to be lost later. If so, they are Critical Steps. No.

2) To manually control flow from the NCP, BG FK-462 has to be in MANUAL.

Performance Step 14 (Step 6.2.14) is a Critical Step. Agreed. Marked as critical.

E 3) The annunciator response actions say to adjust flow to maintain pressurizer level on S1 D 3 X S program (Performance Step 19). It appears to get credit for this action, the applicant needs to adjust flow, which will restore pressurizer level to program band. The Task Standard makes no mention of restoring level to program band. Revised Task Standard to include adjusting charging flow to maintain PZR level, including the reference to the ALR.

4) Recommend referencing the annunciator response procedure in the Task Standard.

1) The Task Standard needs to mention that the actions took place. Such as, upon failing to restore one CCW pump in each operating train,.. Revised Task Standard to E include the inability to align the Service Loop to a running CCW pump and included S2 D 2 S the reference to OFN EG-004.

2) A reference to the procedure used to complete the actions needs to be included in the Task Standard.

1) Step 11 of the procedure is aligning CCPs for normal charging. This is part of the task standard. It is a Critical Step. Revised to mark as a Critical Step.

2) Step 13 accomplishes the isolation of the BIT, which is part of the Task Standard. If the Task Standard says it is isolated, how can it be isolated if only the inlet or the outlet flow paths are closed? To isolate, both would need to be closed. Closing either the inlet or the outlet valves will stop BIT flow. However, to complete the step, both will E need to be closed. Removed the note.

S3 D 2 X X S 3) Reference the procedure in the Task Standard.

4) Revise reference to the critical task in the JPM. This term is scenario test specific.

5) Does this JPM overlap with Scenario 4, Event 5? Checked for overlap. The scenario with the S/G Fault into CTMT terminates at EMG ES-03, step 5 and does not isolate the BIT. The scenario with the inadvertent SIS isolates the BIT in EMG E-0, step 5 and does not address aligning charging.

6) Check for overlap with Scenario 5, Event 3.

WC - 2015 - 11 Rev 1 PROPOSED 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

1) Performance Step 7 (Step 6.2.6): For the expected actions, they are not stated in a provided procedure. Have these actions been reviewed by an operations representative to confirm that these are acceptable actions to address the situation?

Yes. We have performed this JPM during Annual/Biennial requalification exams. AP 21-001, step 6.3.12.8 states that during equipment malfunctions which result in a transient, the Operator shall make a conscious decision on controller operation based E

S4 D 2 X on understanding of the transient and what manual actions are likely to be effective in S

mitigating it. The actions provided in the JPM are the probable actions that the operator can take to mitigate the failure.

2) With the failure of AB PK-507, how likely is the applicant going to be to continue with the procedure steps? The equipment is not in the state that is expected for continued system startup. Therefore, it wouldnt be logical that the applicant would proceed.

What is the expectation here for operations?

1) If the applicant doesnt direct someone to perform Attachment A, the SBO DG will not supply power to the bus. Critical Step.

2) How long does it take for an operator to perform Attachment A?

U S5 D 2 X 3) What indications does the control room operator have as to whether Attachment A S

was successfully completed or not?

4) Recommend including the referenced procedure in the task standard.

5) Does this JPM overlap with Scenario 4, Event 7? Replaced this JPM.

S6 D 1 X U This JPM has low discriminatory value. Recommend revision or replacement. Replaced

1) This JPM has low discriminatory value. Recommend revision or replacement.

2) The only verifiable action the applicant takes is manipulating switches in the pre-start alignment (Step 8.1.4). This is not reflected at all in the proposed task standard. This is a really difficult one for us. We are required to provide an ESFAS JPM per the NUREG. Our ability to do this is very limited as we do not have any of the ESFAS S7 D 1 X U panels in the simulator. In the past, we have used faulted JPMs that are handled in EMG E-0, Attachment F, which you told us to not use. For example, if we have a number of valves/dampers that did not position, Attachment F provides the direction on how to fix that. We could develop one or two that were simulated in the actual control room, but that would certainly not be ideal. We have several Attachment F JPMs that have multiple failures. - Replaced JPM

WC - 2015 - 11 Rev 1 PROPOSED 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

1) The Note before Step 7, OFN BB-07A, says that if leakage is less than 30 GPD, the alert set point should NOT be set above 30 GPD. The indicated leakage is 23 GPD.

If the applicant sets the new alert set point to 33 GPD, as is stated in the JPM, he/she is taking action in conflict with this Note. This Critical Step is not correct. Changed the initial leak rate to 20 so the new number is 30 which is within the note range.

2) What is the basis behind the +/- bands used with the acceptable values? If reading off of a graph, the defined marks are 0.2E-6 Ci/cc apart. Half of that is typically given as an acceptance band (0.1E-6 Ci/cc). Is there a defined reason for this? Changed tolerance to suggested value.

3) Task Standard: The alert and alarm set points are changed for what device? How are they changed (using the G. A. Monitor System)? What procedure and section is used to do it correctly (Section 6.3 of SYS SP-121)? GE RE-92 added this to the task standard. SYS SP-121 is used and is kept by the RM-11 in the control room E

S8 D 3 X (simulator as well). This procedure was going to be used and we would just replace it S

after each JPM instead of handing it to the student which would be artificial. I added the SYS SP-121 to the references and yes that is the correct procedure and step used to perform this setpoint change.

4) Step 6.3.1.6 of SYS SP-121: If the Supervisor RM-80 database screen isnt displayed, what action(s) can the applicant take? If the procedure is performed correctly then that will be the screen displayed. The step asks this question to ensure it is, if it is not then the steps were performed wrong (OE ) so it asks to ensure or you cant go on.

5) Are the Channel Item identifiers for the RM-11R the same as for the RM-23? That is the assumption with the Channel Items listed to change the alarm and alert set points (009 and 010). SYS SP-121, Attachment A has these listed for the RM-23, but there is no similar list for the RM-11R. They are all the same. The monitor this JPM is changing the setpoint of is GE RE-92 and it does NOT have an RM-23 associated with it.

1. The Task Standard needs to indicate that the applicant bypassed the boric acid filter to establish flow using the procedure. The way it is written, an applicant could argue that the Task Standard was met if he/she opened BG HV-177, misinterpreted the cue given about the amount of boric acid flow, and stopped the JPM. Changed task standard.

2. Would the required amount of boration flow be achieved without performing steps A9 RNO d and e? Need to validate that these steps are not critical. This flow path through the plugged filter and the bypass around it come back together on the downstream side.

E P1 D 3 B If the filter is plugged and the bypass is opened then the flow would go around the filter S

and it would not matter if the filter inlet and outlet are closed at all since it all goes to the same outlet line. No those steps are not critical to establish greater than 30 gpm flow.

However this would be a procedure use and adherence issue.

3. What do the asterisks in the standard actions represent? This valve has a wire and plastic lock tab on it that must be broken to remove and then the valve handwheel can be turned to reposition it. The asterisks are only to show that this is not a procedure guided step but one that just needs to be completed in order to accomplish the task.

WC - 2015 - 11 Rev 1 PROPOSED 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

1. Need to add the time critical element to the task standard and to the step within the JPM that denotes when the time critical actions have been completed. What is the maximum time completion that can be considered satisfactory? Removed all time elements from this JPM

2. Delete through step B5 on the initiating cue. This phrase cues the applicant as to what the time critical task is. The examiner will stop the JPM after the time critical task is complete. Left in since the time element was removed.

3. Does WC management (Ops and Training) that a Time Sensitive Action is to be treated the same as a Time Critical Action for purposes of grading (pass/fail)? If so, then change the initiating cue to state: THIS IS A TIME CRITICAL JPM. Removed all time elements from this JPM

4. Delete the phrase, MINIMIZE YOUR VERBALIZATION. Deleted

5. How do we ensure a realistic simulated time for donning the flash suit? How much time would be expected to obtain the equipment in step B3? Will we already have the necessary dosimetry for the JPM prior to this point? Removed all time elements from this JPM

6. Performance Step 1: Standard should simply state that the applicant recognizes that E these actions were already taken in the initiating cue. This is only here as starting P2 S 3 X S point to ensure all students get the exact same staring point

7. Performance Step 2: Change cue to state Loud clunk noise if that is what was intended. Fixed typo

8. Performance Step 5: Do not allow an option for actually entering the cage - delete this option from all parts of the JPM. The applicants will need to simulate entering the cage and the examiners will use the pictures for all JPMs. Deleted extra

9. Be sure to label Picture 1 and Picture 2 as such. Labeled

10. If this JPM will be evaluated versus an assumed operator action time, then the source document showing the time sensitive action needs to be reviewed to ensure that that initial conditions and assumptions of the task are accounted for in the JPM.

Where does the JPM task start? What is the status of the elevators? What is the status of security, and can they assist in this scenario? How much time for response? Etc Removed all time requirements from the JPM. This was just designed to be a task performed by the student not a validation of our sites ability to perform a task in a given time frame.

11. The first step is to start at the elevator and make an announcement. This is not part of the Attachment B actions that the applicant has been tasked with, per the JPM cue. This is only to ensure a constancy

WC - 2015 - 11 Rev 1 PROPOSED 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

1. Need to have a discussion on clarifying the JPM initial conditions that will be provided to the operator. Does the applicant need to know that the NN15 inverter has been energized per steps 4.1 and 4.2? These are the initial conditions that the other steps have been performed by someone else.

2. Missing word in initiating cue: Inform the Control Room when NN01 is energized from NN15 on the bypass transformer via the static switch. Added

3. Delete from cue: The NN15 manual transfer switch Kirk Keys and NK79 transfer switch key are in your possession. Moved to initial conditions

4. Why does the JPM artificially start at step E.4.3.3 instead of E4.3.1? Starting at E4.3.3 is not operationally valid and cues the applicant to realize that this is the first E step where action needs to be taken. This part of the JPM is assumed to have been P3 S 2 X S completed by a different operator. This part of the procedure doesnt add any value to the JPM except make it longer (this JPM is 20 minutes as it is). This first two steps have you walk up and down two floors twice then perform the major parts of the procedure and then have you go back upstairs a third time. We can start there but it will prolong the JPM and add no value.

5. Make all of the same changes to the P3-B version of the JPM. Why does the P3-B version have a 20 min validation time and the P3-A version validate at 15 min? Times were put in before real validation and after we only corrected the one we plan on using. Fixed

6. The Task Standard should reference the correct procedure to be used accomplishing the task. Added reference to the task standard 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 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 RED text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

WC - 2015 - 11 PROPOSED 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. Ensure all Critical Tasks have sufficiently defined acceptance criteria, including appropriate references identified.

2. Ensure Ops Dept has verified all Tech Spec calls.

E 3. In D-2s, highlight procedure entry and transitions to assist the Examiners ability to 1

S follow applicants actions.

4. In D-2s, ensure that every verifiable operator action is identified. For example, turbine load changes and dilution/boration events should include every switch or button manipulation. DONE

1. Ensure all Critical Tasks have sufficiently defined acceptance criteria, including appropriate references identified.

2. Ensure Ops Dept has verified all Tech Spec calls.

E 3. In D-2s, highlight procedure entry and transitions to assist the Examiners ability to 2

S follow applicants actions.

4. In D-2s, ensure that every verifiable operator action is identified. For example, turbine load changes and dilution/boration events should include every switch or button manipulation. DONE

1. Ensure all Critical Tasks have sufficiently defined acceptance criteria, including appropriate references identified.

2. Ensure Ops Dept has verified all Tech Spec calls.

E 3. In D-2s, highlight procedure entry and transitions to assist the Examiners ability to 3

S follow applicants actions.

4. In D-2s, ensure that every verifiable operator action is identified. For example, turbine load changes and dilution/boration events should include every switch or button manipulation. DONE

1. Ensure all Critical Tasks have sufficiently defined acceptance criteria, including appropriate references identified.

2. Ensure Ops Dept has verified all Tech Spec calls.

E 3. In D-2s, highlight procedure entry and transitions to assist the Examiners ability to 4

S follow applicants actions.

4. In D-2s, ensure that every verifiable operator action is identified. For example, turbine load changes and dilution/boration events should include every switch or button manipulation. DONE

1. Ensure all Critical Tasks have sufficiently defined acceptance criteria, including appropriate references identified.

2. Ensure Ops Dept has verified all Tech Spec calls.

E 3. In D-2s, highlight procedure entry and transitions to assist the Examiners ability to 5

S follow applicants actions.

4. In D-2s, ensure that every verifiable operator action is identified. For example, turbine load changes and dilution/boration events should include every switch or button manipulation. DONE

WC - 2015 - 11 PROPOSED OPERATING TEST COMMENTS SCENARIOS 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 RED text so that each scenario used on the exam is reflected by a (S)atisfactory resolution on this form.