ML090200102

2008-12-Draft OP Test Comments

ML090200102
Person / Time
Site:	River Bend
Issue date:	11/21/2008
From:	NRC Region 4
To:
References
Download: ML090200102 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process RB - 2008 - 12 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

3. Attributes

4. Job Content Errors JPM# 1. Dyn (D/S) 2. LOD (1-5) IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia 5. U/E/S 6. Explanation (See below for instructions)

RO (A1) 1 X U 1. (GENERIC COMMENT) Need to identify exactly what is to be handed out to applicants (procedures, attachments, graphs, etc). 2. This JPM has little discriminatory value.

3. Why are the temps given in the initial conditions?

Major revisions made RO (A2) X U 1. Reference the procedure in the Initiating Cue (- in accordance with-).

Minor revisions made RO (A3) E 1. Cue steps 2 and 3 are essentially the same (as identified in the JPM Standard)

2. Do NOT provide the note under the Initiating Cue.

3. Review during validation with full size prints.

Minor revisions made SRO/RO (A4) X U 1. Little discriminatory value.

This JPM is required of all Rad Workers.

Replaced JPM SRO (A5) U 1. Little discriminatory value. First Critic al Step is simple math. Second Critical Step is simple math and knowledge of steam tables. The one non-Cr itical Step is given in the cue. 2. JPM Step 3 is part of JPM Step 4. (Attachment 1 only has 3 steps)

Major revisions made SRO (A6) E 1. Initial Conditions - does "last shift" mean current shift? Consider "at the beginning of your shift all safety levels" and "during your shift, the following changes have occurred."

2. Initial Conditions - first bullet:

Upper Storage Pool is "at" not "a" 3. Initiating Cue - what is the "attached sheet?"

4. Step 4 - the Standard does not identify the correct answer.

Revisions made SRO (A7) X U 1. Initial Conditions - "At the beginning of your shift" 2. Step 1 - this Critical Step is a direct lookup.

3. Step 2 - what is the reference for this step?

Replaced JPM SRO (A8) E 1. Must inform the applicant on the cue sheet that this JPM is time critical. 2. Step 3 - A General Emergency has already been declared. Requirement is to notify state and local authorities within 15 minutes.

3. What method is used to transmit PARs to state and local authorities? How long does it take? This will determine how long applicant has to complete the PARs form.

4. Initiating Cue states "declaration time is the time you received this form." Declaration has already been made.

Minor revisions made 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 Exam ination 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 Attachment 10 Page 2 of 6 OBDI 202 - IOLE Process basically a system reconf iguration 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 fo r 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 c ues 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 wr itten examination. 4. Check the appropriate box when a job content error is identified: Topics not linked to job content (e.g., di sguised 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)na cceptable (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 - IOLE Process RB - 2008 - 12 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

3. Attributes

4. Job Content Errors JPM# 1. Dyn (D/S) 2. LOD (1-5) IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia 5. U/E/S 6. Explanation (See below for instructions)

C1 S 3 E 1. (GENERIC COMMENT) Every JPM must clearly identify the TASK STANDARD (i.e. the predetermined qualitative and/or quantitative outcome) against which task performance will be measured. (See 1021, A ppendix C, Section B.3)

2. Several minor editorial comments 3. Outline (ES-301-2) identifies the JPM as a Low-Power but Initial Conditions do not state the power level.

Fixed C2 S 3 E Several minor editorial comments Fixed S1 D E 1. (GENERIC COMMENT)

All JPM steps must hav e a performance standard. 2. Step 10 - what procedure is used for the Alternate Path?

3. Outline (ES-301-2) identifies t he JPM is for Recirc Pump "A" Fixed S2 D E 1. Step 1 - can the procedure be completed without rotating collar? If not, then the step is Critical.

2. Step 3 - are any of the valves manually shut? If not, then step is not Critical. Fixed S3 D E 1. Step 3 - no operator actions therefore step is not Critical Step

2. Step 4 - applicant cannot finish without going to Section 5.4.7 so step is Critical.

3. Step 5 - no operator actions t herefore step is not Critical.

4. Step 7 - no operator actions t herefore step is not Critical.

5. Step 10 - no operator actions t herefore step is not Critical. 6. Initiating Cue - add "The CRS directs you to rotate-" and add "in accordance with SOP-

0066, Control Building HVAC Chilled Water System, Section 5.4." Fixed S4 D E 1. Step 5 - no operator actions therefore st ep is not Critical.

2. Step 8 - no operator actions t herefore step is not Critical.

3. Step 10 - operator must depress button to restore therefore step is Critical. Fixed S5D EFixed S6 D E 1. Step 5 - no operator actions therefore step is not Critical Step

2. Step 6 - no operator actions ther efore step is not Critical Step

3. Steps 8 and 9 could be Critical Steps depending on how the Task Standard is written. 4. Outline (ES-301-2) identifies the JPM as a Low-Power but Initial Conditions do not state the power level.

Fixed P1 S 3 E 1. Step 3 - How does the applicant know "needed contents?"

2. Initiating Cue - add "You are directed to supply the SVV Supply Header from IAS."

Attachment 10 Page 4 of 6 OBDI 202 - IOLE Process RB - 2008 - 12 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

3. Attributes

4. Job Content Errors JPM# 1. Dyn (D/S) 2. LOD (1-5) IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia 5. U/E/S 6. Explanation (See below for instructions) 3. Steps 11 & 12 - where does it state that these steps may be done in any order? 4. Steps 15 & 16 - where does it state that these steps may be done in any order? Fixed P2 S 3 E 1. Initiating Cue - add procedure and section 2. Initial Conditions - identify "d iesel" as HPCS Diesel Generator

3. Step 16 - are Required Equipment and Pre-reqs of PEP-0026 applicable? Fixed P3 S 3 E 1. Title - Is this a Manual Start or an Emergency Start?

2. Initiating Cue - add procedure and section

3. Step 1 - add note to Comment s that applicant determines 4.2.2.1 and 4.2.

2.2 are N/A

4. Is a cue for Pre-requisites being complete required?

5. Step 7 - Valve name is incorrect (cut and paste error?)

Fixed Attachment 10 Page 5 of 6 OBDI 202 - IOLE Process RB - 2008 - 12 DRAFT OPERATING TEST COMMENTS SCENARIOS 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 1. At turnover, identify how long has the crew been in LCO 3.0.3. 2. Critical Task (SRV) needs acceptance criteria - what constitutes pass/fail? 3. Critical Task (restore RPV level) - is the critical task the ATC opening FW Pump bypass valve? 4. Event 2 - identify ATC must report that no signal rod scr ams (can't grade a "verifies" step).

5. Event 7 - what verifiable operator actions (ATC and BOP) are to be performed in order for this event to count as a component failure?

Fixed 2 X X E 1. Major event not ident ified (not corrected from Draft Outlines) 2. D-1 still missing Tech Spec events (not corrected from Draft Outlines) 3. Critical Task (restore RPV level) needs a cceptance criteria. Also, make Path 2 not available.

4. Critical Task (restore off-site power) needs acceptance criteria. 5. Event 2 - identify t he procedure used for raising power on the D-2. 6. (GENERIC COMMENT) Where possible, include nomenclature names of equipment (not just equipment designator). For instance, identify FW Pump 'A' and not just FWS-P1A.

7. (GENERIC COMMENT) Include pr ocedure names, not just numbers.

8. Event 3 - identify the applicable TS Condition on the D-2. 9. Event 4 - identify the applicable ARP on the D-2. Will the Accumulator Trouble alarms be received prior to starting the standby CRD pump in all runs of this scenario in that we can count on getting the TS calls?

10. Event 8 - what verifiable operator actions are to be performed in order for this event to count as a component failure?

11. Event 1 - The D-1 lists this as Normal evolution for ALL, but D-2 only identifies actions for ATC. Which is correct?

Fixed 3 X E 1. Event 6 - what will the turbine vibrations be during the event? 2. Critical Task (high turbine vibrations) - explain how this is safety significant. 3. Critical Task (ATWS) needs acceptance criteria.

4. Event 7 - does the CRS give direction to scr am or is it automatic? Isn't the turbine tripped from Event 6? If so, then the CRS won' t direct it to be tripped again. Is the procedure flow is AOP-2, then AOP-1 after the scram? 5. Event 5 - identify what procedure is used to lower power via recirc flow on the D-2. 6. Event 6 - what verifiable operator actions ar e to be performed in order for this event to count as a component failure? Appears to be a precursor to the Reactor Scram event

1. 7. Renumber events and update Forms ES-301-5 and 6. Fixed 4 C E 1. Critical Task (ED) needs acceptance criteria. 2. Critical Task (ARI) needs a cceptance criteria. Steps containing "verify" cannot be used to determine success/failure.

Attachment 10 Page 6 of 6 OBDI 202 - IOLE Process RB - 2008 - 12 DRAFT OPERATING TEST COMMENTS SCENARIOS 3. Event 1 - need SOP-0007 as a reference document.

4. Event 3 - need RCP-15-023 as a reference document. 5. Event 4 - identify ATC must report that no signal rod scr ams (can't grade a "verifies" step). Also, identify this event as a "C" on the D-1. 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 test scenario sets. Additional information on these areas may be found in Ex amination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the iss ue 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 scen ario events and actions.

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

6. TL: Time line constructed, including ev ent and process triggered conditions, such t hat scenario can run without routine exam iner 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 sim ilar 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 interact ions. 9. Based on the reviewer

=s judgment, rate the scenario set as (U)nacceptable (requiring r epair 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.