ML13099A285

12 Draft Operating Test Comments

ML13099A285
Person / Time
Site:	Grand Gulf
Issue date:	12/10/2012
From:	Chris Steely Operations Branch IV
To:	Entergy Operations
laura hurley
References
Download: ML13099A285 (8)

Text

SITE - YEAR - MONTH 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 (AR1) S 2 E Task Standard - Tech Spec spelled Speck Corrected Step 1 - Notes section states that R643 pt. 6 reads 311F and 215F for a cooldown of 96F/hr. Should be 313F and 212F for a 101F/hr which violates Tech Specs.

Corrected General Comment for all JPMs - Place Task Standard on cover sheet or next page for easy reference by examiners.

Corrected RO (AR2) S 4 E Initial Conditions - Change pump is to be replaced to is being replaced Corrected Can you provide the system drawing with tagged components highlighted for examiners?

Highlighted drawings will be available for examiners within the JPM package.

Step 1 - States that the operator must determine minimum tagout boundaries.

Examiners need all correct components that could be tagged out in case applicants come up with more than what is on the jpm.

Should be no other components, from validation and prep week.

Step 1 - Should HS M611 (Control Room Handswitch) be marked critical as well?

NO. With power supply being tagged handswitch is not critical.

RO (AR3) S 3 E Initiating Cue - For consistency The CRS directs you Corrected Step 2 - EN-RP-201 not EN-PR-201 Corrected Step 3 Notes - Can the Radiation Protection Manager approve to meet the critical step?

Does it have to be both? Can it only be the Plant General Manager OR the RP Manager?

JPM corrected to indicate both approvals are required. 0 Page 1 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 Step 4 Standard - no approval is required. Per 6.1 of 10-S-01-17 appears that EPM or ED approval is required to increase to Federal limits although not necessary under these conditions.

Per step 6.1.3 the limits are raised to the federal limit (5 Rem) upon declaration of an Alert. EPM or ED approval is required to go above the federal limit of 5 Rem.

Therefore no approval is required to go up to 5 Rem during an Alert.

RO (AR4) S 2 E Initial Conditions - All actions for Control Room evacuation have been completed Corrected Need to work through this jpm with you. Dont see how applicant makes the determinations necessary with the one given image of WR level and WR pressure.

Sufficient information is given to determine Narrow range level and knowledge of high level isolations for HPCS and RCIC.

SRO (AS1) S 3 E Please include log for examiners with the ONEP steps that are complete next to the correct time in the log. This will help the examiners in case follow up questions are necessary.

Examiner log key included.

SRO (AS2) S 2 E Please provide examiners an answer key that highlights the path to the correct color determination. This will be necessary for follow up questioning.

Answer Key included.

SRO (AS3) S 4 E Cover sheet shows this jpm to be Modified. Outline shows the jpm to be New. Which is correct?

NEW. JPM corrected.

Same comment as AR2 about providing a system drawing highlighting the correct components tagged out, including ALL correct components in case applicant goes beyond what jpm requires. Perhaps we should be looking at a tagout jpm for both SROs/ROs that only has around four or five components.

Highlighted prints included Step 1 does not indicate which of the list of components is critical.

Step 1 is not critical due to the SRO is only reviewing what has already been prepared. 0 Page 2 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 SRO (AS4) S 3 E Same comment as AR# Step 3.

See comments for AR3 Please provide examiners path to show how applicant determines Unusual Event Answer Key Provided SRO (AS5) S 3 E Provide answer key to examiners that highlights path applicants take to make correct recommendation.

Answer Key Provided 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 3 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 2 E General Comment - Can Note spaces be reduced in order to get more steps per page.

This will reduce paper printout.

Note spaces have been reduced on all JPMs Should step 1 and 2 be critical?

NO. As discussed during Prep week, during an emergency start of the CRD pumps the discharge valves are not closed per our procedures.

S2 D 3 E Step 2 critical?

Step 2 is now critical S3 D 2 E CRS directs you Corrected Step 1 - Should be 1H13-P601 per the procedure.

Corrected Step 1 - if applicant allows MSIV to reopen in this step are there any consequences?

Should it fail the jpm?

NO. If the operator releases the pushbutton unintentionally then the test should be performed again correctly.

S4 D 2 E Step 5 critical?

Now is Step 6, No. Does not affect the performance of the task.

S5 D 3 E CRS directs you Corrected Step 4 in the procedure about starting RHR PMP A(B) N/A?

Added to Notes section that Att. VI step 4 should be N/A due to pump already running Step 6 references JPM steps 7 and 8 are not critical to be done sequentially. Do not see a Step 8.

Corrected step numbers and added to the Notes for step 5 instead of Step 6 0 Page 4 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 S6 D 2 E CRS directs you Corrected S7 D 2 E CRS directs you Corrected S8 D 2 E CRS directs you Corrected Could not find 04-1-03-D21-1 in references. Will verify with jpm on site next week.

Located in the (06) Surveillances folder.

P1 D 2 S Please have another RCA jpm as a backup to this one, maybe one that is not in containment. Not sure this one will be very valuable to us due to limited steps and having to discuss rather than directly show. Want to walk through this one first before making the decision.

Changed JPM to another location within the CAA, used during Prep week.

P2 D 2 E CRS directs you Corrected Step 2 - Missing L for the word lit Corrected P3 D 2 E This jpm borders LOD=1. Please look at a replacement.

After Prep week decided to keep JPM.

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: 0 Page 5 of 8 OBDI 202 - IOLE Process

$ 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 6 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH 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 Event 1 - Is the D2 inclusive on page 9 of all steps required by the applicants to lower output? (Question asked because there is only three items on this page)

Yes Event 3 - Include ONEP procedure number for the Loss of CCW and Reduction in Recirculation Flow.

Done Event 4 - Include ONEP procedure numbers for Feedwater System Malfunction and Reduction in Recirc.

Done Event 6 - Include ONEP procedure number for Loss of AC. (General comment moving forward please include procedure numbers for all EOPs, AOPs, NOPs, ONEPs, etc)

Completed for all scenarios Event 6 - Loss of AC/Loss of CCW cant be counted as a component failure if there is no action by the applicants to correct the event. Looks like event 6 leads to event 7 and should just be counted as the Major.

Resolved by combining events 6&7.

Event 7 - Enter EP-2 (General comment, include names of all EPs) Done Event 8 - Crew is to secure RCIC flow. Include procedure steps in D2 that detail how to secure RCIC flow. Done 2 E Event 5 - Failure of two IRM channels is counted as a component failure for the ATC. I dont see any actions by the ATC to correct the issue. Does the applicant bypass the channels? If there are no actions to correct/bypass then this is not counted as an instrument failure but only as a TS call by the CRS. This was changed to a single IRM channel failure so that the applicant does perform actions. The TS for this event was moved to another event added during the prep week walk through.

Event 7 - This event (CST Rupture) leads to the scram which is event 8 and the Major.

Therefore, event 7 cant be counted as a component failure. Event 7 and 8 are the Major. Qualitative attribute table needs to be corrected. This is the same comment as in scenario 1. Combined the events in the same way as scenario 1 as discussed during prep week.

Event 9 - Recommend changing this event with something that has substantive actions by the crew to correct. Sending personnel to restore affected components and busses will not satisfy the component/instrument failure count. This was changed to RCIC failure to initiate and does not start using initiate pushbuttons. Actions for this were added to the D2. 0 Page 7 of 8 OBDI 202 - IOLE Process

SITE - YEAR - MONTH DRAFT OPERATING TEST COMMENTS SCENARIOS 3 S Any editorial comments for scenarios 1 and 2 would apply here as well. All comments addressed.

4 E Event 5 - A single control rod drift that is corrected can be counted as a component failure. Two rods drifting that lead to the scram have to be counted as the Major. If the CRS goes conservative and orders the scram on the first drift then the ATC will not get the bean count. Event 5 should have only one drifting that gives the ATC a chance at getting the bean. Event 6 is now the second drifting rod and the scram. Done as written Also, as discussed during prep week I added the Heater Drain Pump Vibration event.

This scenario had 3 events containing LCO calls. The NR Level instrument failure was removed in lieu of adding the Heater Drain Pump. The level instrument event was solely for LCO entry and added no other value to the 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 8 of 8 OBDI 202 - IOLE Process