ML17137A189
| ML17137A189 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/05/2017 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Entergy Operations |
| References | |
| Download: ML17137A189 (9) | |
Text
WT-2017-03 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:
In general, these JPMs are very well designed. We need to have a general discussion of how admin JPMs will be conducted, i.e. will computers be used or will the room have a bookshelf with a series of available references? Need enough copies of the TS and EPIPs if you are not using computers. If using computers - need to configure to ensure exam security, i.e. approved references loaded on the hard drive and computers disconnected from the network.
Admin JPMs will be administered in the classroom. Each applicant will have a computer (wi-fi deactivated) and an approved references thumb drive (e-cart) that is issued during the examination.
They are only allowed to use the e-cart.
Need to have a copy of the initial conditions/cue sheet that stays with the examiner. Often questions come up during JPMs and examiners need to refer to the cue sheet to determine if the information has already been provided. Either include the cue on the examiner only page or have a second copy of the cue sheet with each JPM. It is best to use colored paper for anything that will be given to the applicants.
Applicant cues sheets will be a different color than the rest of the JPM paperwork. We will provide two copies of the cue sheet (one for the examiner and one for the applicant).
Task standards need to be tied directly to the critical steps of the JPM. Need to be sure that task standards have sufficient specificity regarding what actions must be completed and to what extent.
Made changes to task standards as requested.
It is always best to do more than the minimum number of alternate path JPMs. 5/5/3 should be the target number. If we determine for some reason during validation week that a JPM is not actually alternate path, or if something happens during exam week where applicants take a different direction, then we will have to develop another alt path JPM on the fly. This point has been stressed at the RIV exam workshops and was provided as a comment during the review of the draft outline.
A Standby S8 JPM is being developed as a contingency. This JPM is alternate path and was previously used in one of the last two exams (2014 NRC Exam). Currently we only have 1 JPM from the previous 2 exams, so we have some margin in this category.
The S8 JPM has been replaced with an alt path JPM. All general comments have been resolved.
RO (A1) S 2 E Task Standard: Add to task standard Applicant correctly calculates new values for COLSS constants (as shown on attached answer key) for S Made changes as requested (made this Rev 1).
RO (A2) S 3 E Task Standard: Tie to critical steps by stating Determined time after shutdown to be exactly 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, time to boil to be exactly 34.3 minutes, and time to core uncover to be 2.85 - 2.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> per OP-901-S 131, Shutdown Cooling Malfunction.
Made changes as requested (made this Rev 1).
JPM is now SAT. 0 Page 1 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 (A3) S 4 E Task elements 6 through 10 should be critical steps. They are essential to determining the correct final answer.
Made task elements 6 through 10 critical as requested (made this rev 1)
RO (A4) S 3 S SRO (A5) S 3 X E Task Standard: Applicants review discovered 3 errors as identified in the answer key, and the applicant correctly entered Tech Spec 3.8.1.1 b and d as described in Task Element 2.
Change second half of cue to state: Document the results of your review on Attachment 10.1 and, if applicable, determine any additional requirements that must be addressed and list them on this cue sheet.
S Revised Task Standard and the cue sheet as requested (made this Rev 1).
SRO (A6) S 4 X E Task Element 1 should be a critical step, as the same step is critical in JPM A2.
Task Standard: Determined time after shutdown to be exactly 17 days, determined RCS time to boil to be exactly 34.3 minutes, and determined that the Equipment Hatch, Escape Air Lock, Personnel Air Lock and Containment Closure Impairment Log items must be closed within 34.3 minutes in accordance with OP-901-131, Shutdown Cooling Malfunction.
S Made task element 1 critical and revised the task standard as requested (made this Rev 1)
SRO (A7) S 3 X E Initiating Cue: Review the completed K-Effective calculation in accordance with OP-903-090, Shutdown Margin, Section 7.5, K-Effective Calculation, to verify that current plant conditions are in compliance with Tech Spec 3.1.2.9 and document results and required actions, if any, on this cue sheet or on the handout(s) provided.
Please provide an answer key that shows what the applicant should have identified and marked up.
Revise Task Standard - there is no Task Element 13 in the JPM: Identified critical calculation error, determined the correct K-Effective value to be 0.982-0.984, identified that Keff is not less than required, and identified required procedural and Tech Spec actions per Task Element 6.
Revised initiating cue and task standard as requested. A marked up answer key is included already (circled/bolded numbers indicate errors the applicant should identify). Revised the step standard for Task element 6 to better clarify TS 3.1.2.9 requirements. Made this Rev 1.
SRO (A8) S 2 X E Task element 5: Step should state Calculate dose for 2 teams (4 workers) with shielding installed.
Why are Task Elements 2 & 5 not critical when the other dose calculation steps are critical? If we are going to make the dose calculation steps critical, then we need to add the numbers to the task standard or create a small answer key that can be referred to.
Revised task element 5 as requested. Concerning task elements 2 & 5, the applicant can determine 0 Page 2 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 that the 1-Team Work-Minutes are less than the 2-Team Work-Minutes and therefore not calculate 2-Team dose, and for this reason, the dose calculations are not critical. The task elements have notes stating this possibility.
Added a small dose calculation key for dose calculations.
Revised task standard: Applicant calculates dose with and without shielding, dose to install and remove shielding (as shown on the dose calculation key), and calculates that 1 team (2 workers) is required, and directs job to 1 team without shielding installed.
Made this Rev 1.
SRO (A9) S 3 E Revise task standard to be more specific as to the exact EP call and timing requirement.
Please give the applicants the entire EPIPs and charts and allow them to find the correct sections to refer to - please do not hand out an abbreviated procedure or chart. This is part of the 15 minute classification time.
Revised task standard as requested. The applicants will have the entire E-Plan procedure and all charts. Made this Rev 1.
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 3 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 S 2 S S2 D 3 X E Task Element 3 - should be a critical step, or the step standard should state that if pressurizer pressure reaches below 1250 PSIA (where RCPs must be secured), then the applicant has failed the JPM.
Added Examiner Note to task element 3: If pressurizer pressure reaches below 1250 PSIA (where RCPs must be secured), then this task element becomes a critical step and the applicant fails the JPM.
Task Standard: Applicant reduced RCS pressure and stabilized between 1300-1400 PSIA, established Safety Injection System flow in accordance with OP-901-112, Charging or Letdown Malfunction, using HPSI Pump A, and turned the trend in pressurizer level back towards the 33-60% band.
S Revised task standard as requested. Made this Rev 1.
S3 D 3 X E Task element 9 - We will need to evaluate during validation week as to the best way to cue the 5 minutes having been passed. I would rather not have to provide a cue here, as it signals that something is up right at the alternate path transition point. It needs to be very clear that the applicant has read the step, understood it, and is waiting the 5 minutes before we give any kind of cue. The better cue might be the SM asks which step you are on and then if the applicant provides a good explanation of the step, then provide the 5 minutes have elapsed cue.
Revised Examiner Cue: Approximately one minute after the applicant turns off the RCP and the applicant has read this step and is waiting the 5 minutes, then cue 5 minutes has elapsed. Made this Rev 1.
S4 D 2 E Task Element 11: It does not appear to be procedurally acceptable to open only one of the steam supply valves. The step standard should state Both steam supply valves should be opened per procedure. For the purposes of this JPM critical step, at least one valve must be opened. We would provide a comment if an applicant only opens one valve, but they would not fail that critical step.
Added requested information to Task Element 11. Made this Rev 1.
S5 D 2 X S S6 D 4 X E Task Element 3: we will need to have a cue ready to provide to the applicant as to the 0 Page 4 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 times for the EDG coming up to rated speed and voltage. They will want to know the times.
Added cue as requested to task element 3.
Task Element 30 - Step should be a critical step. Standard should state what actions need to be taken - applicant goes to raise on speed adjust and picks up around 0.1 MW such that reverse power trip does not occur.
Made task element 30 critical. Step standard: Raised EDG A Speed Adjust and picked up approximately 0.1 MW such that reverse power trip does not occur.
One-step alternate paths should be an exception rather than the norm. Be sure to minimize the number of one-step alternate paths on future exams.
OK (made this Rev 1)
S7 S 2 S S8 D 1 U This is a two-step JPM that may not provide the exam team with enough to evaluate.
While there appears that there may be some distinctiveness in the diagnosis phase of the JPM, we would need to see that during validation week. The safest decision at this point would be to replace this JPM with an Alt Path JPM.
This task requires three manipulations based upon an evaluation of the system alignment. I would like to see how it validates. We are currently developing another JPM (one from the previous two exams) to replace this JPM.
S JPM replaced during validation week. JPM is now SAT.
P1 S 3 E Please explain how the time critical aspect of the JPM will work when there is a 30 min hold that will be cued with time compression.
Task Standard: Add the critical time to the task standard.
Revised Task Standard to: Applicant aligns EFW Pump suction to the Auxiliary Component Cooling Water system in 30 minutes or less from the start of the JPM.
Moved the Stop Time ___ line to between task elements 4 and 5. The 30 minute time compression should not be part of the critical time and this move fixes this.
Revised task element 4 step standard to: Both valves are open in 30 minutes or less from the start of the JPM. Made this Rev 1. 0 Page 5 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 S JPM is now SAT.
P2 S 3 X S P3 S 2 E Task Standard: Add the critical time to the task standard. Realize that this JPM may be time critical in the sense that there is a TCOA associated with it, however the allowed time being as long as it is (54 min) means that an applicant could fail the JPM on time prior to getting to 54 minutes based on 2X validation time (assuming no progress being made).
Revised Task Standard: Applicant isolates RWSP from Purification in accordance with OP-902-009, EOP Standard Appendices, in 54 minutes or less from the start of the JPM.
Made this Rev 1.
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.
- 3. 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 6 of 9 OBDI 202 - IOLE Process
WT-2017-03 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 General Comments:
In general, these are solid scenarios and the critical tasks are well-defined.
Scenario #4 is the only scenario where EOP contingencies (functional recovery for a CE plant) are examined. NUREG-1021 requires that EOP contingencies be part of the op test. Therefore, Scenario #4 must be run during exam week - we will want to run this scenario on a 3-crew day.
OK TS calls: Can you please add the LCO time requirements to the TS calls on the D-2s?
Also, it would help us if you could somehow make the TS calls standout in the D-2s using bold type or underlines.
Added a line with all caps that reads TECH SPEC CALL on the center of the page just before the information about the specific tech specs. I also bolded and added time requirements to the tech specs themselves.
Is there a way to gray the text or the background for the steps that are marked N/A in the D-2s? This would help with readability as the examiner follows along during the scenario.
Grayed the text for steps that are N/A.
1 X E This scenario needs an additional EOP-based critical task. Use of the pushing of reactor trip pushbuttons is LOD-1 when considering it as a critical task. If you are going to have a scenario with this as a CT, there needs to be two additional critical tasks that provide the exam team with a more significant CT set with which to evaluate crews. The potential additional CT here is to have the crew need to take action to isolate the faulted SG - make sure any failure does not overlap the last couple of exams. Or you could have the Reactor Trip pushbuttons not work and need to open breakers or emergency borate.
I would rather add a malfunction requiring the use of Diverse Reactor Trip (DRT). This keeps the CT as an ATC CT (essentially, the ATC would attempt to trip the reactor using the normal trip buttons and then when the reactor doesnt trip the ATC would use another set of push buttons (DRT) on the same control panel to trip the Rx. I can certainly add an additional malfunction (fail DRT) which would require the use of breakers - this would require the BOP to take action to trip the reactor from a different control panel. Note: I will wait for NRC feedback before I make changes to the scenario.
This scenario has 5 abnormal events if you count the loss of vacuum. It is fine if you want to count this event as an R because it can be described as a controlled abnormal 0 Page 7 of 9 OBDI 202 - IOLE Process
WT-2017-03 DRAFT OPERATING TEST COMMENTS SCENARIOS condition. Realize in the future that you can substitute an I or C for an R or N.
Essentially there does not have to be an R and an N on every scenario anymore.
See note 2 at the bottom of the 301-5 form.
We put an R in every scenario so that we can mix and match scenarios and always maintain the minimum requirements in a scenario set.
The D-2 needs the actions of Attachment 2 of OP-901-112 in the event that letdown is secured.
Attachment 2 actions added.
Can you place the Attachment 2-A, E & F graphs at the back of the D-2?
Attachments 2-A, E & F graphs moved to the back of the D-2.
Made the D-2 Rev1.
S Scenario is now SAT. Will be used as spare.
2 S Could you place a reminder to record the times associated with the RCP lack of CCW in the D-2s? Just put something to the effect Loss of CCW to RCPs start time: _____.
Also, please add a place to record the time when the RCPs are secured.
Added a reminder as requested. Made D-2 Rev1.
3 S Critical Task #2: How long until the EDG B fails on overheat? Need to add this to the critical task description and to the D-2.
Approximately 20 minutes.
Revised CT 2 description: prior to failure of Emergency Diesel Generator B due to no Component Cooling Water which occurs in approximately 20 minutes. This task .
Updated D-1 and D-2.
Made D-1 Rev2 and D-2 Rev1 This scenario is a good candidate for the 2-crew day.
OK 4 S The scenario needs to be run on three crews - need to swap Scenario 3 and Scenario 4 on the ES-301-5 and run Scenario 4 on a 3-crew day.
OK. I will make the changes to ES-301-5 when the spare scenario is identified.
Same request for reminders to record times for the 3 minutes associated with loss of CCW to the RCPs.
Placed a reminder to record the times associated with the RCP lack of CCW in the D-2; moved EOP graphs to the back of the D-2. Made the D-2 Rev1. 0 Page 8 of 9 OBDI 202 - IOLE Process
WT-2017-03 DRAFT 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.
- 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 9 of 9 OBDI 202 - IOLE Process