ML16336A576

2016-10 Operating Test Comments

ML16336A576
Person / Time
Site:	Diablo Canyon
Issue date:	10/20/2016
From:	Vincent Gaddy Operations Branch IV
To:	Pacific Gas & Electric Co
References
Download: ML16336A576 (6)

Text

DC October 2016 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 SRO (A5) S 2 X U The handouts potentially cue the applicant since the U2 SF that does not meet all three S requirements is out of alphabetical order and by himself on the handout.

Is this supposed to be the SRO from Crew E? Do you need to state that the Crew B SRO is not available and a Crew E will swap into the crew>

Why are you just asking for SRO level staff on the watch bill since this is only 4 people?

Need to change the initialing cue to ensure all minimum crew composition.

This JPM has a validation time of 20 minutes but the Bank JPM that was modified for this JPM reviews the whole crew with a validation time of 15 minutes.

Handout 3 (OP1.DC37) not contained in the file - Licensee provided a copy.

Need reference material for the crew composition requirements (Eplan)

Resubmitting a new JPM similar theme testing the same ability Changed JPM to evaluate specific watch standers Revised initiating cues and handouts JPM Sat SRO (A6) S 3 X E Need to add to the initiating cue include the reason for the selected action S Step 3.2 of the JPM should be a critical step due to if the applicant does not identify the inoperable smoke detector then actions A.1 and A.2.1 would be valid actions.

Need to make sure that the handouts are large enough to be able to be legible. 8.5x11 are a little small for prints and charts to be able to read.

Updating JPM Revised TS tracking sheet Removed TS handout. TS will be available in the room JPM Sat SRO (A7) S 1 U This is LOD 1 S Step 2.2 of the JPM is marked as a critical step but the JPM gives them this information in the remarks section of the procedure. This JPM has an initial faulted input and a TS call that the TS is referenced in the procedure.

Updating the JPM to remove remarks and identification of exceeding the 10 sec.

Changed the JPM to 2 separate parts with actions.

JPM Sat SRO (A8) S 2 X E The initiating cue is cueing the focus on the exposure limits which is the basis for the S approval or non-approval.

Additionally, the critical step just identifies that the approval decision is the only item required for the task.

Need to remove the last sentence of the first bullet since the second bullet has the applicant document recommendations and the basis for those recommendations.

The task standard mentions the reason for not approving.

Both critical steps and task standard should be the same.

Update the critical steps and initiating cue Updated the JPM to include comments above.

Added que to provide basis for recommendations JPM Sat SRO (A9) S 2 S References not sent with the JPM. Licensee provided reference 0 Page 1 of 6 OBDI 202 - IOLE Process

DC October 2016 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 General Comments:

Need to ensure answer keys are made for all the JPMs Need to ensure that all references are available that are used or referenced in the JPMs and 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 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 2 of 6 OBDI 202 - IOLE Process

DC October 2016 DRAFT 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 S1 D 3 S What is the initial rod height of the failed rods?

Remove critical step for the rod control selector switch in manual S2 D 2 S JPM page 5 and 8 are blank I think there might be a typo in NOTE in JPM Step 7.3 (May?)

Updated JPM S3 D 3 S S4 D 2 S Clarified that a minimum of two PORVs are required to be open to meet the task standard S5 D 3 E There is nothing in the initiating cue to direct aligning for injection phase. What S indications would the operator have to determine that injection phase is the proper lineup? Indications given in the JPM JPM Step 2 - Initial conditions state that EOP E-1 is in progress. Why would the operator think that ECA-1.1 would be in effect at this time? Do we need to cue them?

Updated cue in step 2 JPM Sat S6 D 3 E JPM Step 4 - Is there any adverse action if the switch is not operated? No S adverse action JPM Step 11 - Should not need to cue the operator that Steps 4.b and c are complete since 4.b status is in the cue and 4.c is performed by the operator.

JPM Step 16 - Same discussion as Step 11 for completion of procedure step 4.d Updated cues.

JPM Sat S7 D 3 E JPM Step 7.4 - insert a line to document VCT pressure since closing LCV-112B S or 112C is not a critical step if less than 28 psig. We will also need a trend track for the parameter during the JPM administration.

Added note JPM Sat P1 S 3 E JPM Step 2 - How many drain caps are required to be removed? Procedure says S both. Need to annotate this in the JPM since it is a critical step.

Updated critical step Revised cues to match type of valves being operated. (needle vs. ball)

JPM Sat P2 S 2 U Not an Alternate path JPM. You are already in the RNO and the JPM cues you S that there is not flow which flow into the next step. There is not a decision point by the operator that would change the direction of the procedure. The only other 0 Page 3 of 6 OBDI 202 - IOLE Process

DC October 2016 DRAFT 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 option of the operator would be to say JPM complete after being told that there is still tank flow.

Handout was not correct for the JPM Updated the handout to provide control indication for the alternate path. Include full procedure as handout Updated cues for 8992 breaker closure, initial conditions and manipulation of 8994 valve and control room indications JPM Sat P3 S 3 E JPM is not an alternate path as stated on the outline. It is supposed to be S alternate path. Licensee sending an updated version.

Revised JPM to make alternate path If the operator does not recommend placing the TSC on the other generator and is cued to do so it does not meet the definition of an alternate path.

JPM 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).

$ 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 6 OBDI 202 - IOLE Process

DC October 2016 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 Y Y Y Y Y Y Y Y E Event 1 - is placing the makeup control switch in STOP the only action? No will S need to manually maintain level for the remainder of the scenario Event 5 - The D-1 states that leak is from Loop 4 but the D-2 states Loop 3.

Does this have any effect on the operations to respond to the event? -

Corrected Added OP-5 as potential procedure Swapped events 3 and 4 Added notes concerning potential post scenario critical task it plant tripped during event 4.

Scenario Sat 2 Y Y Y Y Y Y Y Y E D-1 Event 4 annotates the leak on Loop 3 instead of Loop 1. Updated to reflect S Loop 3 Annotate which pump and control switch will be operated to start second CCP Remove the it is and they are statements for the D-2s. Annotate when a component is required to be operated when not in the required position or if values are not as expected.

D-2 updated with above comments Reduced leak rate to 100 gpm to avoid premature SI Added PK11-21 reference and TS 3.4.13 Scenario Sat 3 Y Y Y Y Y Y Y Y S Page 7 remove ) from end of sentence in the middle of the page.

Event 4 - What are the expected target gallons and flow rate for the boration?

Updated scenario for above comments Added CT to manually trip the reactor prior to 92% WR SG level.

Changed field cue for pump shaft shear Removed SI portion of CT since valves perform the function Made various editorial changes during validation Scenario Sat 4 Y Y Y Y Y Y Y Y E Event 1 - The verifiable actions associated with the low temp are cued by the S instructors. The failure to start just requires a TS entry that would be the same as the low temperature. This event could be just a DG startup with a fault and get the same results. I think the goal of this event is to lose the DG and get a TS call. Changed event one to address above concerns Event 3 - Is there procedural guidance for the isolation/securing of the TDAFW pump. PK04-03 is referenced in the D-1 but there are not any actions associated with the procedure in the D-2. Plant trains as conduct of ops Event 4 - Input is 829 is the input for the Mn Bk Xfmr Annun. The D-2 has 827 as the input. Updated the scenario to reflect the correct input 0 Page 5 of 6 OBDI 202 - IOLE Process

DC October 2016 DRAFT OPERATING TEST COMMENTS SCENARIOS ATWS should be a Major Event instead of malfunction after EOP. Annotated ATWS as a Major Event.

Corrected initial conditions on D-1 to be 72%

Scenario Sat General Comment Need to add the following clause to the bottom of the CT tables:

Per NUREG-1021, Appendix D, if an operator or crew significantly deviates from or fails to follow procedures that affect the maintenance of basic safety functions, those actions may form the basis of a CT identified in the post-scenario review.

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 reviewers 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