ML17179A003

2017-06-DRAFT Operating Test Comments

ML17179A003
Person / Time
Site:	Comanche Peak
Issue date:	06/19/2017
From:	Vincent Gaddy Operations Branch IV
To:	Vistra Energy
References
50-445/OL-17, 50-446/OL-17
Download: ML17179A003 (7)

Text

CP-2017-06 DRAFT OPERATING TEST COMMENTS ADMIN JPMS 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 blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

4. Job Content

3. Attributes

1. 2. Errors 6.

5.

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

Focus lap Link I am concerned that the most common error would be if an applicant thinks time after shutdown is 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. If so, it is very likely that an applicant would pass based on the error bars provided with the key. Would like to see another time after shutdown so that this isnt a possibility.

The slope of the graphs is gradual enough that the applicant would have to err significantly E in calculation of Time after Shutdown regardless of dates/times provided. CPNPP RA1 2 S recommended solution is to add the Time after Shutdown calculation to the Task Standard and Key to make this calculation a Critical Step. If the applicant then determines the wrong time they will fail regardless of ranging errors placed on graphs.

The task standard should state determined per the attached key.

Task Standard changed as directed.

JPM Now SAT Task standard should state, per the attached key.

Task Standard changed as directed E

RA2 2 Performance step 6 states, Page 13 of 13. Should be Page 14 of 14.

S Page numbers corrected JPM Now SAT 0 Page 1 of 7 OBDI 202 - IOLE Process

Task standard is incorrect and does not match the critical steps. First, the task standard currently states that acceptance criteria is met, which is incorrect. Second, if the task standard states to record data, then recording the data should be a critical step, likewise for the plotting. Based on the listed critical steps, the task standard should state something like, Determined that all readings are within limits, and acceptance criteria for average availability vs outside temperature is unsat, per OPT-1.

U RA3 2 X Task Standard changed as directed S

Finally, for the two listed critical steps, do you want failing to initial to be failing the critical step? If not, then there should be a note in the performance steps stating such.

Performance Step 7 must be initialed as the data sheet requires initials to signify all readings are within limits. Removed the requirement to initial Performance Steps 10 and 12, the recording of data and appropriate circling is sufficient.

JPM Now SAT Would like to see Radiation Worker B initial dose such that she not be allowed to perform work, even with shielding. (Set the initial condition up such that they are coming in sometime in January, say January 20, and Worker B has 15 mrem so far this year, which would obviously all be in the month. Then with the 40 mrem, plus the 15 she already has E

RA4 2 in the month, she would not be able to do the work with shielding.)

S Changes made as requested. Key updated.

Change validation time to 30 minutes.

Validation time changed to 30 minutes JPM Now SAT The task standard is incorrect and does not match the critical steps. The task standard states that saturation temperatures and subcooling are calculated, but they are not listed as critical steps. The task standard should state something like, Reactor System Cooldown rate was calculated to be 106°F based on pressure drop in steam generator 4, and determined LCO 3.4.3, condition A applies, and identified required action and completion time.

Task Standard changed as directed.

I cant seem to match the calculated subcooling on the key for 0930 and 1000 values.

U The subcooling between 0930 and 1000 on the initial key was wrong. It should have been SA1 3 X S 81°F and it has been corrected. Discussion with Chief Examiner during validation week on using highest values.

Change validation time to 30 minutes.

Validation time changed to 30 minutes What temp is used for calculating subcooling margin? Hot or cold leg? Highest or lowest?

Discussion with Chief Examiner during validation week on using highest values revealed that key is in fact correct as there were higher numbers provided that were not being used for the calculation. Also, the subcooling calculation is not a critical step on the JPM.

JPM Now SAT 0 Page 2 of 7 OBDI 202 - IOLE Process

Task standard should state something like, Determined that ROs 1 and 4 license status were inactive, and ROs 2 and 3 license status were active, and determined ROs 2 and 3 were qualified to stand the watch as the Unit 1, RO Task standard changed as directed.

E SA2 2 Initiating cue should state determine which Reactor Operator(s), if any, S

Initiating cue changed as directed.

Change validation time to 15 minutes Validation time changed to 15 minutes JPM Now SAT The same comments as RA3 apply to the task standard. Since the comments are identical, will designate this JPM as edit instead of Unsat.

Changed to match JPM RA3.

E SA3 2 Additionally, the task standard should state something like, determined LCO 3.7.11, S

condition A applies, and identified required action and completion time.

Task Standard changed as directed.

JPM Now SAT Initiating cue #1 is LOD 1 on its own, in that it is simple arithmetic. Initiating condition #2 is LOD 1 in that it is direct lookup, since the value of 5.5 REM is given in the stem. It would U not be LOD 1 the value of 5.5 were to be calculated somehow.

SA4 1 S Changed JPM as directed to have the value of 5.5 Rem be calculated. The STA-501 notification will no longer require an oral report as the event itself did not exceed 5.5 Rem.

JPM Now SAT Why is the JPM not time critical? (From EPP-201, Once indication of an abnormal condition is available, classification declaration must be made within 15 minutes.)

JPM is now time critical E The task standard should reference the information contained in the key.

SA5 2 S JPM is now a one part JPM per Chief Examiner direction during validation week. JPM is now a 15 minute Time Critical JPM and the Task Standard has been updated to reference the key.

JPM Now SAT 0 Page 3 of 7 OBDI 202 - IOLE Process

CP-2017-06 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS 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 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 blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

GENERAL COMMENT

S:

JPMs that have initiating cues to simply respond to any alarms are frowned upon as JPMs, and are better suited for scenario events. There are two on this operating test (S$ and S7). Effort should be taken to remove these type of JPMs from future exams.

4. Job Content

3. Attributes

1. 2. Errors 6.

5.

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

Focus lap Link Performance step 7 gives an examiner note that the examinee should only move the rods a minimum of 10 steps based on the note prior to step 8.1, but the initiating cue starts the JPM at step 8.2. Is it expected that the examinee will go back and read this caution? If so, will it also apply to performance step 5, when moving the rod outward?

Yes - The Caution prior to Step 8.1 applies to all of Section 8. The applicant should review this Caution and move the Rods only 10 steps. The procedure does say that 10 E steps is desired to minimize reactivity changes, however, it would not be unacceptable if S1 D 3 S the applicant went slightly over 10 steps. We would like this JPM to be pre-briefed with the applicants.

Change Validation time to 10 minutes.

Validation time changed to 10 minutes Remove With all controls in AUTOMATIC from the initial conditions.

Removed JPM Now SAT 0 Page 4 of 7 OBDI 202 - IOLE Process

Initial conditions and initiating conditions cue the alternate path by stating the size of the leak, and to identify the leak beginning with step 2.3.8. Reword the stem to get rid of reference to leak or leak size, and start the JPM beginning with step 2.3.4.

Reworded the stem, and changed the initiating cue to begin at step 2.3.4.

Combine performance steps 19 and 20, with the examiner note that closing either 1-8105 U

S2 S 2 X or 1-8106 accomplishes the critical task.

S Steps 19 and 20 combined and examiner note added Stop JPM after determining leak has been isolating, with a critical step on whether he starts to put normal or excess letdown in service.

JPM terminated as described above with Critical Steps for each procedural flowpath JPM Now SAT Change validation time to 15 minutes.

S3 S 2 S Validation time changed to 15 minutes Performance step 4 standard is to place 1-HS-2452-2 in pull out, but it was already placed in pull out in performance step 2. The standard in step 4 should be to verify it is in pull out.

Changed Step 4 to Verified in pull-out as directed Move performance steps 7 and 8 to steps 1 and 2, and change the examiner note to E

S4 S 2 indicate that the steps may be performed after step 8.

S Steps moved and appropriate Examiner Notes added as directed Add examiner cue after the (new) performance step 2, that another operator will monitor control rod movements.

Examiner Cue added as directed JPM Now SAT Add to the task standard that RCPs must be secured.

Task Standard updated as directed Performance step 1 standard should be Phase B ACT NOT ILLUMINATED. Step 3 E

S5 S 2 standard should be PASE B ACT - NOT ILLUMINATED. Step 4 standard determined S

phase b NOT actuated, and step 5 standard should be partially actuated.

All performance steps updated appropriately JPM Now SAT Is there a safety significant reason that you would not want to trip the diesel instead of opening output breaker and adjusting voltage and frequency? I am concerned that someone could fail if they tripped the diesel when there is no safety significance for doing S6 D 3 S so.

There is no safety significant reason to not trip the diesel, however, the procedure states to open the output breaker and adjust voltage, thus it would be procedurally incorrect to trip the diesel.

Performance step 7, change standard to remove words (critical) and add examiner note that placing just one of the switches in off is critical.

E The words critical removed from standard and examiner note added as directed S7 S 2 S Performance step 13, change standard to remove the word (critical)

The words critical removed from standard JPM Now SAT 0 Page 5 of 7 OBDI 202 - IOLE Process

During validation, the examiners need to ensure that there is not overlap between this JPM and JPM P3, since both JPMs are using the same procedure, and both are responding to the same event.

Change validation time to 6 minutes.

E S8 S 2 Validation time changed to 6 minutes S

Change task standard to remove reference to tripping the turbine, and add reference to tripping the turbine AFW pump.

Task standard updated as directed JPM Now SAT P1 S 2 S P2 S 2 S P3 S 2 S 0 Page 6 of 7 OBDI 202 - IOLE Process

CP-2017-06 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 Comment: Tech specs should be listed in the D2, as well as the actions required. (i.e., TS 3.7.1.2, action b, restore to operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If tech specs may be entered, the D2 should so state, and the conditions that would require entering them.

Instructions for Completing Matrix This form is not contained in or required by NUREG-1021. Utilities are not required or encouraged to use it. The purpose of this form is to enhance regional consistency in reviewing operating test scenario sets. Additional information on these areas may be found in Examination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided.

1. ES: ES-301 checklists 4, 5, & 6 satisfied.

2. TS: Set includes SRO TS actions for each SRO, with required actions explicitly detailed.

3. Crit: Each manipulation or evolution has explicit success criteria documented in Form ES-D-2.

4. IC: Out of service equipment and other initial conditions reasonably consistent between scenarios and not predictive of scenario events and actions.

5. Pred: Scenario sequence and other factors avoid predictability issues.

6. TL: Time line constructed, including event and process triggered conditions, such that scenario can run without routine examiner cuing.

7. L/C: Length and complexity for each scenario in the set is reasonable for the crew mix being examined, such that all applicants have reasonably similar exposure and events are needed for evaluation purposes.

8. Eff: Sequence of events is reasonably efficient for examination purposes, especially with respect to long delays or interactions.

9. Based on the reviewer=s judgment, rate the scenario set as (U)nacceptable (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory.

10. Provide a brief description of problem in the explanation column.

11. Save initial review comments as normal black text; indicate how comments were resolved using blue text so that each JPM used on the exam is reflected by a (S)atisfactory resolution on this form.

E Made corrections as necessary during validation week.

1 S Scenario now SAT E Made corrections as necessary during validation week.

2 S Scenario now SAT E Made corrections as necessary during validation week.

3 S Scenario now SAT E Made corrections as necessary during validation week.

4 S Scenario now SAT 0 Page 7 of 7 OBDI 202 - IOLE Process