ML091490499

2009-03 - Draft OP Test Comments

ML091490499
Person / Time
Site:	Fort Calhoun
Issue date:	03/27/2009
From:	Brian Larson NRC Region 4
To:	Omaha Public Power District
References
50-285/09-301, FC-2009-03 50-285/09-301
Download: ML091490499 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process FC - 2009 - 03 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) E 1. Title should be "

Calculate Shutdown Margin with Inoperable CEA s" (match 301-1)

Done 2. NUREG 1021 Appendix C requires all JPMs must have a clearly identified Task Standard (B.3)

Done 3. Appendix C requires JPMs to have Initia l Conditions AND Initiating Cues (B.1)

Done 4. JPMs need Answer Keys when possible Done 5. JPM coversheet should identify whether Ti me Critical or Alternate Path (Yes/No)

Done 6. Performance Standards and Task Standards are written in past tense.

Done 7. Initiating Cues should/shall include refe rences to appropriate steps in appropriate procedures/attachments (just like in real life). If given direction to complete an action already started, the handout shall include appropriate initials/signatures/etc.

Done 8. Provide a copy of all reference/handout material in or der to validate the JPM.

Done 9. On JPM coversheet - differentiate between references and handouts.

Done 10. Step 3 - not Critical?

No 11. Step 4 - what is basis of range?

changed RO (A2) E 1. See 2-9 above Done 2. Steps 1 & 2 - what is basis of range?

changed RO (A3) E 1. See 2-9 above Done RO (A4) U 1. See 2-9 above Done 2. No Critical Steps? Fixed 3. Initiating Cue is not written as a directive. How is applicant supposed to know where he is supposed to go inside the RCA - what maps to review - what to discuss with RP? Fixed 4. What are the initial conditions?

LOCA in progress? RHR in service? Fixed SRO (A5) E 1. See 2-9 above Done 2. Change title to "Review Shutdown Margin Calculation with Inoperable CEAs" Done SRO (A6) E 1. See 2-9 above Done 2. Use bullets for listing info rmation in Initial Conditions.

Done SRO (A7) E 1. See 2-9 above Done SRO (A8) E 1. See 2-9 above Done 2. What is Ops Department expectations of the CRS/SM if errors are found on Attachment 4? Not authorize release SRO (A9) E 1. See 2-9 above Done 2. Identify regulatory requirement and/or commitment for 15 minutes to classify the event.

Revised 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 Attachment 10 Page 2 of 6 OBDI 202 - IOLE Process 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 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 FC - 2009 - 03 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) J1D2 E 3. Step 13 - does procedure steps 5.1 and 5.13 apply?

Yes What procedure directs the Mode Selector Switch to be placed in OFF?

OI-RR-1 Add ref to list on JPM coversheet.

Done 1. Renumber as S1 - see Draft Outline Comments Done 2. Need page 4 of OP-ST-CEA-0003 wi th initials/date for pre-reqs Done 4. Add steps to JPM for all NOTES and CAUTIONS - "Applicant reviewed NOTE/CAUTION" This is applicable to all JPMs. Done where practical J2 E2. Verify if all valve mani pulations are Critical Steps.

Done 1. Renumber as S2 Done J3 E3. Verify if all valve mani pulations are Critical Steps.

Done 1. Renumber as S3

2. Step 1 of Attachment 9 missing from JPM. Fixed 4. Step 6 of Attachment 9 missing from JPM. Will applicant be able to recognize loss of IA at this step and not have to go to Step 7? Fixed J4 U6. JPM Step 4 - procedure step 5 - says TDB-III.7.a and TDB-III.7.d, RCS Pressure and Temperature Limits, not III.25. Fixed 1. Renumber as S4 Done 2. JPM doesn't qualify as Alternate Path - see Appendix C, Section C.2 Fixed 3. Add to Initial Conditions that RCP-3A motor is COLD. Any other info needed in the

Precautions section?

Done 4. Will need a completed Pre-reqs section with initials/date Done 5. Step 1 completed? (Controlled Bleedoff)

Yes - needs signed off - Done

7. JPM Step 6 - Annunciators are A6 and A5, not D5 Fixed 8. Caution before Procedur e Step 10 - add to Initial Conditions that no one is in containment.

Done 9. JPM step 12 should be step 10 Fixed J5 E3. Verify if all valve mani pulations are Critical Steps.

Done 1. Renumber as S5 Done 2. What procedure step is JPM step 2?

Should this step be in the procedure?

Revised JPM 4. What procedure guidance is provided to di rect the applicant to transition to 12.a?

Revised JPM

5. JPM step 9 - not Critical?

Critical - revised JPM J6 E 1. Renumber as S6 Done FC - 2009 - 03 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS At tachment 10 Page 4 of 6 OBDI 202 - IOLE Process

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) J7 E3. JPM step 4 - no need to wait to provide OI-EE-1 attachment. Add to Initiating Cue since pre-reqs should be signed off.

Done 1. Renumber as S7 Done 2. Between JPM step 2 and 3 - add step for reading Caution with an Examiner Cue that System Operations has been notified.

Done 4. JPM steps 7 and 13 - what is basis for 25 volts?

Ops Rep verified J8 E4. Will procedure steps 7.9, 7.10 and 7.11 be signed off in the copy provided to the applicant?

Yes 1. Renumber as S8 Done 2. Change Initiating Cue to all Title Case for procedure, lower case for the rest.

Done 3. Add to Initial Conditions that pre-reqs are met - and complete the initial/date on copy provided to applicant.

Done 5. JPM is missing procedure step 7.12 Fixed 6. JPM is missing procedure step 7.14. Fixed 7. Add last step to JPM - applicant signs the surveillance test and notifies shift manager the test is complete.

Revised JPM to 2 channels only P9 E3. May need to add river level greater t han 983.5 ft and Containment temperatures less than 150°F to Initial Conditions. (see Cautions prior to procedure step 12.c) and whether or not an SIAS/CIAS has occurred.

Done 1. Renumber as P1 - see Draft Outline Comments Done 2. Change JPM such that the Control Room is performing AOP-11. Using cues, direct the applicant to perform various local operat ions in 2 areas of the plant.

Done P 10 E 1. Renumber as P2 Done P 11 E 1. Renumber as P3 Done Other 1. Are any JPMs designed to run simultaneously?

Yes 2. Index for Plant Procedure files are corrupt.

Resent 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 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.

Attachment 10 Page 5 of 6 OBDI 202 - IOLE Process 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 6 of 6 OBDI 202 - IOLE Process FC - 2009 - 03 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 1. For Tech Spec calls - Identify the applicable Condition(s).

Done 2. Need all data (partially complete surveillance, turnover sheets, etc) given to crew at watch turnover.

Done 3. Add procedures and titles to all D-2s.

Done 4. Identify key annuciators that alarm.

Done 5. Provide more detail for E-00 steps.

Done 6. Event 7 is not a Major Transient. Fixed 2 1-5. see above Done 6. What procedure directs actions for Event 1?

Replaced event

7. Event 4 - more detail on D-2's.

Done 8. Event 8 - move SPTAs to Event 7.

Done 3 1-5. see above.

Done 4 1-5. see above.

Done 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.