ML120470490

2012-01-Draft Operating Test Comments

ML120470490
Person / Time
Site:	Wolf Creek
Issue date:	01/18/2012
From:	Division of Reactor Safety IV
To:	Wolf Creek
References
Download: ML120470490 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - I OLE Process WC - 2012 - 01 DRAFT OPERATING TEST COMMENTS ADMIN JPM S JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia General: 1. Provide copies of applicable portions of procedures that are referenced in JPMs.

2. Titles of JPMs should generally match title of JPM (see S4)

SRO (A 1) 1. Where is the RO's calculation that the applicant is supposed to review? No procedure for this calculation, skill of the craft.

2. What procedure directs how the calculation is to be performed?

No procedure for this calculation, skill of the craft.

3. Per Corporate Notification Letter, proprietary information should have been submitted in a separate enclosure and appropriately marked.

Will correct in future submittals.

4. For Handouts: what does "see page #5.9 (Boration/Dilution Equation)" mean? Will delete. Applicant should only be given the manual without any cues as to what figures/equations to use.

Only the manual will be given SRO (A2) 1. Initial Conditions: state downpower was just completed however Attachment A indicates the Uniit has been at 60% power for one hour.

Fixed - unit has been down for one hou r 2. Initiating Cue: #2 should read "Evaluate the Acceptance Criteria and document results on Cue Sheet." Don't cue applicant to refer to Tech Specs.

Fixed SRO (A3) Task Standard identifies reference to both the NOTE to SR 3.7.5.2 and BASES for LCO and SR 3.0.4

- as written, applicant would have to identify both to successfully complete JPM.

Will move additional info from Task Std to Examiner Note.

SRO (A4) Form ES-301-1 for A4 title is "Evaluate an Emergency Authorization Exposure."

It should be "Evaluate Emergency Exposure Authorization."

Fixed SRO (A5) 1. Form ES

-301-1 for A5 title and title of JPM could be shortened to "Classify an Emergency using Emergency Action Levels." "Within 15 minutes" is captured in the Task Standard and "In the simulator setting" is captured by the Type Code.

Fixed 2. Is the plan to have the applicant in the simulator for the 5 minutes after the event? Yes Consider bringing the applicant into the simulator after it's put in freeze, give him 5 minutes to evaluate plant conditions and then start the 15 minute clock. This would require revising the Initial Conditions and Initiating Cue.

4. The applicant should be able to use references in the simulator, so no need for any Handouts.

Will use simulator references where possible.

5. Task Standard, Initiating Cue, Required Materials, General References, Performance Step 2 and Performance Step 2 Standard all identify E PF 00 6-007-01 as WCGS Emergency CLASSIFICATION, but form is WCGS Emergency NOTIFICATION

. Fixed 6. Initiating Cue

- why declare a 15 minute time clock? Is this not cueing? Shouldn't a time zero declaration be sufficient?

No 15 minute clock

7. Insufficient info in JPM to verify accurate classification

- will have to be done during validation.

Will add additional info

8. Wouldn't EPP 06

-005, Emergency Classification, be listed as a Ref and used in the JPM steps as this would be the procedure the applicant would use to classify the event?

Include as Gen Ref

Attachment 10 Page 2 of 6 OBDI 202 - I OLE Process WC - 2012 - 01 DRAFT OPERATING TEST COMMENTS ADMIN JPM S JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia 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.

Attachment 10 Page 3 of 6 OBDI 202 - I OLE Process WC - 2012 - 01 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN

-PLANT SYSTEM S JPM S JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia S 1 1. Add to Initiating Cue that all prereqs are met.

Fixed 2. Perf Step 1: for Comment block

- identify NOTE prior to Step 6.1.1?

Note not applicable

- will add its not applicable to Comments block.

3. Perf Step 2: What is the ref for the B10CF? Copy provided? Curve Book (Proprietary)

. Should add comment to source of number.

Done 4. Initial Conditions/Initiating Cue: what is VCT level when low level alarm annunciates?

22% What will VCT level be when 200 gal are added?

Alarm will be cleared

7. Perf Step 8: for Comment block

- identify NOTE prior to Step 6.1.5?

Note not applicable

- will add its not applicable to Comments block. 8. Perf Step 9: Is this step Critical? Yes 9. Perf Step 14: Is t his step Critical?

No 10. Perf Step 15: for Comment block

- identify NOTE prior to Step 6.1.12?

Move Examiner Note to Comment block

11. Perf Step 16 and 18: Could be Critical is counter is not initially reset?

Counters auto reset

12. Perf Step 20: for Comment block

- identify NOTE prior to Step 6.1.17?

Note not applicable

- will add its not applicable to Comments block.

13. Perf Step 21: for Comment block

- identify NOTE prior to Step 6.1.18? Note not applicable

- will add its not applicable to Comments block.

14. Perf Step 22: After questioning the CRS, applicant should record the step N/A? (add to Standard)

Fixed 15. Perf Step 24: Standard block

- should the applicant adjust BK FK

-110 if required, not FK

-111? Fixed

16. Perf Step 25: for Comment block

- identify NOTE prior to Step 6.1.21.2?

Note not applicable

- will add its not applicable to Comments block.

17. Perf Step 26: procedure step 6.1.22 missing from Perf Step block.

Fixed 18. Perf Step 27 and 28: assuming simulator works, these steps would not be Critical.

Fixed 19. Perf Step 29: is this step Critical?

No 20. Perf Step 30: is this step Critical?

No S 2 1. Perf Step 3: Standard

- For Loop 1 actions are not Critical.

Will identify

2. Perf Step 4: Standard

- observing pressures is not Critical. Step is not Critical.

Revised standard to include no SI

3. Perf Step 5: while initial loop in service was Loop 4, is applicant opens Loop 1 valve and keeps Loop 4 valve closed, does applicant meet intent of procedure?

Yes - revised Task Standard to either valve with the desired press band

5. Can SI actuations be blocked with pressure above 1920 and below 1970?

yes 6. Perf Step 7: Standard

- monitoring NPIS computer points not Critical. Move to Comments block.

7. Don't need procedure pages 22

-50. Okay S 3 1. Attachment D, steps D.1 and D.2.1 should be place kept on handout.

Okay 2. Perf Step 1: Examiner NOTE should also state that step D.2.1 has already been performed.

Fixed 3. Perf Step 4

- this step is Critical.

fixed 4. Perf Step 6

- this step is Critical if applicant placed controller in MANUAL.

fixed 5. Only need procedure pages 1

-11 and Attachment D to be submitted.

Okay S 4 1. Perf Step 1: Standard

- should state applicant found seal leakoff > 8 gpm, not 8 gpm.

Recorder scale only goes to 8 gpm

Attachment 10 Page 4 of 6 OBDI 202 - I OLE Process WC - 2012 - 01 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN

-PLANT SYSTEM S JPM S JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia 2. Given NOTE prior to Step 1 of OFN, applicant should not be allowed to perform procedure steps 1

-3. It should be expected that the applicant transition immediately to Attach B directly or to Attach E then to B. Leave as written

3. Perf Step 10: Standard

- states that > 8 gpm with pump bearing/seal temp stable requiring Attach B but Attach E states >8 gpm with temps stable OR increasing. Only row of Attach E table that should be highlighted is the third row.

Fixed 4. Perf Step 18

- add Examiner Note row in order to record time of stopping RCP (TIME OF RCP TRIP:

___________)

will add 5. Perf Step 19

- not Critical (action is in Perf Step 20) fixed 6: Perf Step 20: add Examiner Note row in order to record time of trip (TIME OF RCP ISOLATION

-

___________)

will add S 5 1. Title on ES

-301-2: "Perform EMG E

-0, Attachment F, Automatic Signal Verification" Changed 2. Initial Conditions: what is the event? Consider adding identification of the event.

Not germane so intentionally left off

3. Perf Steps 2 and 3: Procedure identifies valves as "AE" not "EA" as identified in the JPM

- which is correct? Fixed 4. Perf Step 7: not a Critical Step (action is in Perf St ep 9) Fixed 5. Task Standard and Perf Steps 7 and 9: valve description s for all three valves don't match JPM descriptions verses Attach B.

Will review all description sources at validation

6. Examiner NOTE for Perf Step 8: doesn't identify BG HIS-8160. Will review all description sources at validation S 6 1. Title on ES

-301-2: "Align Safeguards Bus to Alternate Power Source" Fixed 2. Perf Step 2: Examiner NOTE

- performing steps B1 through B12 should not constitute a failure?

Note to be deleted

3. Perf Step 4: Standard

- should be "- tagged out from Initial Conditions," not "Initiating Cue" fixed 4. Perf Step 7 and 8

- steps are not Critical fixed 5. Perf Step 16

- is this step Critical? Can Task Standard be accomplished is this step is not performed? No, not Critical

6. Perf Step 17: Comment block

- NOTE before step C7a?

Add to Comment block

7. Perf Step 18: Comment block

- NOTE before step C7b?

Add to Comment block

8. Perf Step 25: step is not Critical Fixed S 7 1. Title on ES

-301-2: "Determine IR Instrumentation Malfunction" Fixed 2. Perf Step 1: Comment block

- NOTES before step 1?

Will add to Comment block

3. Perf Step 4: should submit Figure 1 with decision path highlighted Okay 4. Perf Step 6: should submit Figure 3 with decision path highlighted O k ay 5. Perf Step 10: Add to Standard that selection of FR

-H5 over FR

-S2 constitutes JPM failure.

Fixed 6. Perf Step 11: Standard

- second bullet should be SE NI

-3 6 B Fixed 7. Perf Step 15: Standard

- add that applicant also determined source range NOT ENERGIZED Added 8. Perf Step 16: how does applicant determine either IR channel is under compensated? What is NI

-35B were overcompensated? Gamma metrics is used to diagnose one or both undercompensated

P1 1, For cues, do not give End State (charged). Provide indications that enable the applicant to determine the End State Example: window is red/green, light is on/off, etc.

Okay 2. Perf Step 2: Are there voltage or speed indicators? If so, what are the expected valves? Speed Attachment 10 Page 5 of 6 OBDI 202 - I OLE Process WC - 2012 - 01 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN

-PLANT SYSTEM S JPM S JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia indication is sound (cue), volt meter is available and will read zero until field is flashed Also, renumber the Cues 1 and 2, not 2 and 4.

fixed 3. Perf Step 3: How is "at speed" defined?

Sound leveled off

4. Don't need to submit all pages of the procedure, just pages 1-4. okay P2 1. Perf Step 2: What key is required to unlock the cabinet? Location? One key in the CR Also - Last sentence of the Comment block is part of the Task Standard (not required in Comment block).

Moved 2. Why can't the applicant open the cabinet? exam security Would eliminate need for photos and would be more operationally valid.

3. Perf Step 4: What length of fire hose is required? Do all Fire Brigade Lockers contain this length of hose? Fire Brigade lockers and fire hose house contain numerous sections of hose

4. Is a spanner wrench required to secure the coupling to the standpipe fitting? Available If so, where is it located?

Fire hose house P3 1. Title of JPM isn't on Form ES-301-2. Fixed 2. Perf Step 1: for the Standard - if valve is found open, then step is not a Critical Step.

Added words

3. Perf Step 3: Examiner NOTE states applicant may continue to throttle EC

-V076 until full open but Perf Step 1 makes this valve full open.

Changed to EC V128

4. Perf Step 4: step is not Critical per the Task Standard.

Not Critical

5. Perf Step 10: Given retake exam will be given in January, is it likely STN GP

-001, PLANT WINTERIZATION will be open? If so, then Cue should read another Operator will perform this step.

Fixed 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 Attachment 10 Page 6 of 6 OBDI 202 - I OLE Process resolution on this form.