ML14111A351

2014-03-Draft Operating Test Comments

ML14111A351
Person / Time
Site:	River Bend
Issue date:	03/27/2014
From:	Vincent Gaddy Operations Branch IV
To:	Entergy Operations
laura hurley
References
50-458/14-03
Download: ML14111A351 (6)

Text

RB-2014-03 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 (A1) S 3 E E Provide the critical steps in the JPM document. Could not locate the answer key. Could not locate the pictures referenced in the JPM.

S Picture reference removed from JPM, answer key provided and critical steps added. JPM is now SAT.

RO (A2) S 3 E E Designate JPM step 3 as a critical step and fill in values. Change the standard in JPM step 3 from Applicant performed calculation and determined that loop flow was less than 33 kgpm in accordance S with the answer key to Applicant performed calculation and determined that loop flow is 7kgpm +??.

Could not locate the pictures referenced in the JPM.

Critical steps added. Removed reference to pictures in JPM and changed answer key. JPM is now SAT.

RO (A3) S 1 E U This JPM is unsat first because it is not an admin JPM and second, it lacks discriminatory value.

Basically, it is a direct lookup. Could not locate pictures referenced in the JPM of the RGDS.

E JPM replaced. Revision required to show that either of two valves can be tagged out on answer key.

S Revision made, JPM is now SAT.

RO (A4) S 2 E E E The task in the synopsis does not match the task in the initiating cue - which is correct? Need to mark critical steps.

S Synopsis revised. Critical steps marked. Survey map revised. JPM is now SAT.

SRO (A5) S 2 E U This JPM is simplistic and has little discriminatory value.

E After further review and discussion with the licensee, determined that there was discriminatory value and changed LOD to a 2. However, the JPM still needs editing for critical steps.

S JPM revised to add critical steps. JPM is now SAT.

SRO (A6) S 3 E E Need to mark critical steps.

S Critical steps added. Initial conditions edited for clarity. JPM is now SAT.

SRO (A7) S 1 E U Could not evaluate this JPM because I could not locate the marked up copy of STP-050-0700 referenced in the JPM. Need to mark critical steps. Upon receipt of the marked up copy of STP-050-0700, determined that this JPM does not discriminate between a competent and less than competent operator in that it only requires the applicant to plot one given data point on a graph provided.

S JPM replaced.

SRO (A8) S 1 E U This JPM lacks discriminatory value for an SRO applicant. It is a very basic rad worker calculation followed by a couple of direct lookups. Also, student answer sheet does not match the guide.

S JPM replaced. 0 Page 1 of 6 OBDI 202 - IOLE Process

RB-2014-03 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 SRO (A9) S 1 E U JPM step 1 states the applicant will reference the provided pictures. Could not locate any pictures and am not sure what the pictures would involve since there is sufficient information from the cue sheet to complete the JPM.

This JPM lacks discriminatory value for an SRO applicant.

S JPM replaced. JPM is now 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).

• 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 2 of 6 OBDI 202 - IOLE Process

RB-2014-03 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

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

Focus Steps (N/B) lap Link S1 D 3 E E Why are JPM steps 10 and 11 not critical steps?

S Per facility step 10 is critical, step 11 is not critical in that failing to perform the step would not meet station expectations but would not prevent successful performance of the JPM.

Revised critical steps. JPM now SAT.

S2 D 3 E E JPM steps 5, 6, 7, 8, 9, 11, 12, 17, 18, 20 also appear to be critical steps.

Due to simulator problems, this JPM was replaced during validation week. Per facility, S new JPM S2 step 7 is not critical because the MSIV would still close on all auto trips even if MSIV is not in auto. JPM is now SAT.

S3 D 3 S The standard for JPM step 4 is missing a word - doesnt make sense as written. Needs a validated time on the cover sheet.

E Steps 1 and 6 are critical.

S JPM revised. JPM now SAT.

S4 D 3 E E JPM step 2 is a critical step. Revise this JPM so it includes opening the DG output breaker and tripping the EDG. Add an X in the box for RO on the coversheet as the ROs are also performing this JPM.

S JPM revised. JPM now SAT.

S5 D 3 E E JPM step 3 is a critical step; JPM step 5 is not a critical step.

JPM step 3 critical or not? Is it an administrative control or an interlock for the pumps to prevent them both from running at the same time?

S Per the facility, it is an administrative control to prevent both pumps from running at the same time, therefore Step 3 is not critical, and the JPM is now SAT.

S6 D 3 S C1 S 2 E E Make JPM step 4 a critical step.

Take the first critical step in JPM step 5 (in the standard section) and make it the critical step for JPM step 4. Delete the current critical step in JPM step 4.

S JPM has been revised and is now SAT.

C2 S 3 S No comments.

E During validation, requested that the LPRM be changed so its not so close to C1. C2 has been revised, but I believe Step 12 Action should be changed to select B on the function switch now, not A. Please review and if required, revise. 0 Page 3 of 6 OBDI 202 - IOLE Process

RB-2014-03 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 5.

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

Focus Steps (N/B) lap Link S JPM has been revised to select B instead of A. JPM is now SAT.

P1 S 2 S No comments.

P2 S 3 E E If JPM step 4 is critical, why isnt step 5?

Why are JPM steps 6, 7, 8, and 9 not critical steps?

Also, needs a validated time on the coversheet.

S JPM revised and facility provided explanations on what steps are critical and why each step was or was not. JPM is now SAT.

P3 S 4 E E There are no designated critical steps for this JPM.

S Critical steps added. Changed termination point. Changed task standard and terminating cue to reflect new termination point. JPM is now 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).

$ 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 4 of 6 OBDI 202 - IOLE Process

RB-2014-03 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 1 E E E E Event 1 - Add details to define what actions are required to Perform STP-509-0101.

Event 2 - Add APRM B inoperable while I&C testing in progress to the initial conditions and place APRM B in Bypass also as an initial condition so that the SRO will have to enter LCO 3.3.1.1 When APRM F fails. APRM B can be restored when APRM F fails and tech spec 3.3.1.1 has been entered or at the discretion of the lead examiner.

Event 4 - Add the ATC to the D-1 for event 4 and delete the BOP. Also add the scram reset to the D-2s for event 4.

Event 5 - Add the ATC to the D-1 for event 5 since he has to reduce power for the SRV.

Also, what are the UOs verifiable actions? Does he put SPC in service? If so, add to D-2.

Event 6 - Change critical task 1 to 110 degrees versus the 105. This is in accordance with EOP-2 and tech spec 3.6.2.1. Also, revise outboard vs. inboard MSIVs. It looks like they got mixed up in the D-2.

Event 8 - Change critical task 2 to Isolate the steam leak outside primary containment prior to reaching the max safe temperature value (200 degrees) in the main steam tunnel.

S Revisions made. Scenario now SAT.

2 E E E Event 1 - Add details in event 1 for putting the third FRV in service.

Event 2 - Add details on Step 90 (summary of basic steps performed)

Event 3 - Remove the BOP from the bean count on the D-1 for event 3 as he has no actions to perform. Also for the RB operator, have him report the fuel pool level at 22 10 so the TS must be entered.

Event 4 - Is HPCS aligned? If so, provide steps, if not, whats the verifiable operator action?

Event 5 - add the resetting of the half scram and add detail for what subsequent steps have to be performed by the UO.

Change critical task 2 to Initiate actions to emergency depressurize prior to level reaching -186 and initiate low pressure injection. Also, critical task 1 needs a quantitative end point.

There is only one I/C failure for the ATC for the entire scenario. There is only one I/C failure for the BOP prior to the main event.

S Revisions made. Scenario is now SAT.

3 E E E Event 1 - Provide detail on swapping the CCP pumps.

Event 2 - There is no credit for the BOP in this event as he has no documented actions to perform. Does the SRO have to enter TS 3.3.6.1 since only 2 channels are required to be operable and typically there are 4 channels available?

Event 3 - Add details on what Step 7 entails.

Event 4 - Add details on starting CRDH pump B, HDL pump D, and CCS B.

Event 5 - Add the LCO number to be entered (3.1.5.B). Add the action for the ATC to place the mode switch in shutdown. What is UOs verifiable operator action? Cannot take credit for action taken in Event 4. For events 4 and 5, need to edit discussion of what T.S.s are applicable when. When does the TS for the Mode switch to shutdown 0 Page 5 of 6 OBDI 202 - IOLE Process

RB-2014-03 DRAFT OPERATING TEST COMMENTS SCENARIOS immediately apply? In Event 4 or 5?

Event 6 - Add detail how feedwater is terminated. Why is lowering level to -56 a critical task? Also, both critical tasks need a quantitative endpoint. And the second critical task is not listed in the events section of the D-2, although it is listed at the end of the scenario.

There are two event 3s listed on the D-1; renumber so they are correct for the ES-301-5.

S Scenario has been revised. Scenario is now SAT.

4 E E Event 1 - Add summary of Step 91A actions.

Event 2 - Document what action the BOP takes or delete the BOP from event 2 on the D-1 form.

Event 3 - What are UOs verifiable operator actions? Put these actions in the D-2.

Event 4 - Add detail on the swapping of HDL pumps. Add actions taken by the BOP or delete All from the D-1 and replace with ATC.

Events 6 Revise critical task 1 to read Emergency depressurize prior to exceeding the PSP limit. Both critical tasks need a quantitative endpoint (See previous sentence for an example).

S Scenario has been revised. Note that it does not meet the recommended malfunctions number on the D-1. Note that this is the spare scenario.

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. 0 Page 6 of 6 OBDI 202 - IOLE Process