ML113000273

2011-07-DRAFT Operating Test Comments

ML113000273
Person / Time
Site:	Diablo Canyon
Issue date:	10/27/2011
From:	NRC Region 4
To:	Pacific Gas & Electric Co
References
50-275/11-07, 50-323/11-07, DC-2011-07
Download: ML113000273 (4)

Text

DC-2011-07 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content

3. Attributes

1. 2. Errors 6.

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 E Change task standard - Determine rod withdrawal hold points as indicated on attached key.

Remove extra space in initiating cue: of_OP L-2 Remove table in task standard and make it the attached key. fixed RO (A2) S E Why are the ranges arbitrarily chosen? Is this the site standard for PCM/PPM? fixed RO (A3) S E See A1 in reference to the task standard. It should be sentence referencing the key. fixed RO (A4) S S SRO (A5) S E See A1 fixed SRO (A6) S E See A2 fixed SRO (A7) S E See A3 fixed SRO (A8) S S SRO (A9) S E Set the range for the first calculation to 4.30 to 4.3424 and calculate the resulting ranges to a truncated value and an exact calculation. 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 resolution on this form. 0 Page 1 of 4 OBDI 202 - IOLE Process

DC-2011-07 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 C1 S These items will be evaluated and fixed during validation week.

C2 S S1 D S2 D S3 D S4 D S5 D S6 D P1 S P2 S P3 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. 0 Page 2 of 4 OBDI 202 - IOLE Process

DC-2011-07 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 Generic for all of the scenarios - simply stating Commenced Boration, or performed some task is not acceptable. Please write the D-2s so that the NRC examiners can qualitatively gauge performance. To do this, place the steps (or manipulations) that will be performed to accomplish the task. The NRC does not operate your plant; therefore, we cant recall from memory what manipulations should occur outside of normal manual manipulations. Adjusting charging flow, starting a standby pump, energizing heaters, etc. dont have to be prescriptive. Manipulations spanning multiple steps do. Apply that logic and revise the D-2s.

Additionally, the D-2 actions with regards to EOP steps needs to be more prescriptive than Checks Turbine trip, checks 4kV buses energized. We like to see the EOP steps and RNOs as applicable restated on the D-2s along with the expected observation.

All of the corrections above do not have to be word-for-word out of the procedure; but, provide a simple statement as to what valve or indication is manipulated or verified.

Example is Scenario 2, Event 1, ramping the turbine. fixed 2 E Event 1 on the D-1: Ramp DOWN.

Event 3: Last row: Evaluating TS? Or entering TS?

Need simple restatement of steps for restoring charging/letdown if this is expected.

Event 7: NOTE: Critical task has measurable attribute of a verbal report (page 14 App D). fixed 3 E Event 1: Place an examiners note that transition to event 2 can occur when power has reached 4 E Event 1: Using procedure OP L-3 fixed NOTE: With respect to events 3&4, it doesnt matter whether we combine them into one or leave it split. The crediting remains the same.

5 E NOTE: The post-DBA LOCA cold leg recirculation alignment is sufficiently faulted in the JPM S4 to make this a different task.

6 E Event 1 D-1: SRO is getting credit fixed Event 4 D-1: should be a Major because it is a transient that could/requires automatic/manual trip 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. 0 Page 3 of 4 OBDI 202 - IOLE Process

DC-2011-07 DRAFT OPERATING TEST COMMENTS SCENARIOS

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 4 of 4 OBDI 202 - IOLE Process