ML13108A249

CP-2013-04 Draft Operating Test Comments

ML13108A249
Person / Time
Site:	Comanche Peak
Issue date:	04/08/2013
From:	Kelly Clayton Operations Branch IV
To:	Luminant Generation Co
laura hurley
References
50-445/13-004, 50-446/13-004
Download: ML13108A249 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - I OLE Process CP - 2013 - 04 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 RO (RA1) S 3 E S Is it possible to change something in the course of actions from the original JPM other than the numbers for the calc to more adequately meet the intent of the definition of a modified JPM?

We need to discuss what constitutes a modified JPM iaw NUREG

-1021. Done. Talked to HQ and interpretation of 1021 defn that the course of the JPm must be significantly altered to be a modified JPM was not met with this JPM as written.

Since the bank JPM was better than the proposed JPM and bank count was good this JPM was replaced with its bank (the draft JPM did not meet the intent of a bank JPM per CE and HQ

-consulted on call) and JPM is now Sat.

RO (R A2) S 2 E S For step 7, the SG with largest pressure drop is SG3 not SG1, so the JPM key is incorrect.

Licensee m ade the recommended changes and the JPM is now Sat.

RO (R A3) S 3 S RO (R A4) D 2 S SRO (S A 1) S 2 U S TS call is direct look

-up as written. Licensee rewrote JPM and it is no longer direct lookup.

JPM is now Sat. SRO (SA2) S 3 E S For step 7, the SG with largest pressure drop is SG3 not SG1, so the JPM key is incorrect. This JPM has a good example of what the NRC considers a good TS call (ie not direct look

-up). Licensee m ade change and JPM is now Sat

. SRO (SA3) S 2 E S Task Standard is incorrect (uses old bank JPM standard). Fire zone affected is for wrong unit

. Licensee reworked the JPM and it is now Sat.

SRO (SA4) S 2 E S Several parts of this JPM are direct look

-up and also not discriminating.

Key with marked up procedure not provided or page numbers for reference answers not located in JPM standard either. One or the other would be sufficient.

Licensee made recommended changes and JPM is now Sat.

SRO (SA5) S 3 E S Need a marked up key for this JPM.

Done. JPM is 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).

Attachment 10 Page 2 of 6 OBDI 202 - I OLE Process 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 CP - 2013 - 04 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 D 3 E S Q: Does simulator not model the boric acid filter bypass valve?

Answer, No.

It would help to send a copy of the drawing with this JPM. Change the two control rods that drop to prevent memorization errors (from original JPM). JPM perform step 2 has nomenclature errors. BA XFER pumps not Boric Acid pump 1 or 2. What does conduct of Ops say about this evolution or in general being directed to use a procedure and then jumping to an operator aid? This seems like it is very confusing the way it is layed out in the procedure and attachments. Perform step 5 in JPM the standard should state that this step was completed above in step 2 of the JPM standard. At the end of the JPM is seems to me that since the procedure has you verify flow to ensure you are borating to the RCS then the JPM standard should also have this but the JPM does not include this step and although not critical in this case for success it is an important step to complete the task but it is not in the JPM standard. Why?

Rewrote JPM and stop at Attachment 2. Licensee will write CR to correct procedure issues with ABN-107 issues in transitioning between attachments at end of exam week

. Licensee made the changes recommended and JPM is now Sat.

S 2 D 2 S During Val week: Change val time to 4 minutes, put note for examiner that if valve isn't shut for 8 minutes then secure JPM.

Licensee made the changes recommended and JPM is now Sat.

S 3 D 2 E S Q: What happens if the applicant exceeds the five minutes for closing the valve at the end of the JP M for seal water? Licensee Answer - he fails the JPM. This is Time critical so add this to the cue sheet and JPM standard.

S 4 D 3 S S 5 D 3 S Add "Not time critical" to the cue sheet for the applicant since this is normally a TCA JPM when ran in normal path (this is alt path). Licensee made the changes recommended and JPM is now Sat.

S 6 D 3 S S 7 D 2 E S Add cue for examiner that if applicant desires to wait until letdown is isolated to complete the JPM to inform him as the CRS to "finish the procedure steps he was assigned.

" JPM is now Sat.

S 8 D 3 S P1 S 3 S P2 S 3 E S ES-301-2 Outline does not reflect that this is a low power JPM (code L). Delete "AS" on first bullet of JPM step 7 standard section. Made changes and JPM is now Sat.

Attachment 10 Page 4 of 6 OBDI 202 - I OLE Process CP - 2013 - 04 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 P3 S 3 S 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 5 of 6 OBDI 202 - I OLE Process CP - 2013 - 04 DRAFT OPERATING TEST COMMENTS SCENARIO S Scenario Set 1. ES 2. TS 3. Crit 4. IC 5. Pred 6. TL 7. L/C 8. Eff 9. U/E/S 10. Explanation (See below for instructions) 1 X E S Disagree with the critical tasks. Controlling parameters for one inst/comp failure is not usually a critical task.

Also, I would recommend that you put the crit task in the D

-1 summary as well as identify which event on the first page of D

-1 the crit task occurs in.

Called HQ to confirm proper interpretation of CT definition and use in scenarios and they concurred that inst failures by themselves are not critical tasks unless they create further problems by delayed action or inaction that then causes reactor trip and/or ESFAS. This creates a CT which is added to the scenario (note that it is not an expected or planned CT during development or otherwise). Changed critical tasks in all four scenarios.

2 X E S Disagree with the critical tasks. Event 2 crit task is not as risk significant as failing to start an RHR pump in event 8. Controlling parameters for one inst/comp failure is not

usually a critical task.

Changed critical tasks in all four scenarios.

3 X E S Disagree with the critical tasks. Event 1 crit task is not as risk significant as failing to start a SI pump in event 6. Controlling parameters for one inst/comp failure is not usually a critical task.

Changed critical tasks in all four scenarios.

4 X E S Disagree with the critical tasks. Controlling parameters for one inst/comp failure is not usually a critical task.

Changed critical tasks in all four scenario

s. 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.

Attachment 10 Page 6 of 6 OBDI 202 - I OLE Process CP - 2013 - 04 DRAFT OPERATING TEST COMMENTS SCENARIO S 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.