ML15009A350

2014-12 Draft Operating Test Comments - Resolved

ML15009A350
Person / Time
Site:	Callaway
Issue date:	12/17/2014
From:	Vincent Gaddy Operations Branch IV
To:	Union Electric Co
laura hurley
References
50-483/14-12 50-483/OL-14
Download: ML15009A350 (6)

Text

Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process CW-2014-12 DRAFT OPERATING TEST COMMENTS ADMIN JPMS JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia RO (A1) S 2 S -If applicant is using any graphs from OOA-BB-00003 or OTO-EJ-00003, include a marked up key; e.g. Figure 4 and Figure 3 as referenced in JPM steps 4 and 5. Key included

-Change acceptable range for Condition 1 to 16

- 17 minutes. No reason applicant should read <16 given placement of curve.

Change made

- Change acceptable range for Condition 2 to 33

- 34 minutes. No reason applicant should read >34 given placement of curve.

Change made RO (A2) S 2 S -All the values being used are exact numbers, i.

e. no values are being read off of a chart. Instructions say to record all values to 4 decimal places and not to round results. Therefore it is not justified to allow a range of +/- 0.5%. Consider below range, or a different range as discussed during validation.

JPM step 4: Acceptabl e range 1361.0317 to 1361.0318 Changed to (range of 1361.031 to 1361.032 lbm) (3 decimal places rounded or cut-off)

JPM step 8: Acceptabl e range 0.6808 to 0.6809 Changed to (range 0.680 to 0.681 gpm) (3 decimal places rounded or cut-off)

JPM step 10: Acceptable range 0.6044 to 0.6045 gpm Changed to (range 0.604 to 0.605 gpm) (3 decimal places rounded or cut-off)

The 3 decimal round or cut off is based on the example in the procedur e (step 4.9, 6.1.12, and 6.1.13) and the TS limits being 1 gpm, 10 gpm, or 150 gallon per day. 4 decimals is only captured for trending puposes.

RO (A3) S 2 S No comments RO (A4) S 1 E LOD = 1. Little discriminatory value. Modify JPM to test on some additional knowledge such as site vs federal limits, planned special exposures, reportability, calculating internal dose, etc.

Modified the JPM to require the applicant to obtain the airborne dose rate from a survey map. The applicant must also convert DAC to mrem.

SRO (A5) S 2 S -Include an actual value for power in initial conditions. Applicant should know it is near rated power.

Change made

-Include reference to the actual TS action statements wh ich are applicable.

Change made

-Modify cue to read: "Determine if any reportability is required, the shortest time requirement, and the agency requiring notification, if applicable."

Change made SRO (A6) S 3 S -Modify task standard to be more specific: " - identified the following errors: wrong temp reactivity in step 6.8.4, wrong critical boron concentrations step 6.12.4 -" etc.

Change made SRO (A7) S 3 S -The way the task standard is written, step 1 should be a critical step as well.

Revised task standard so step 1 is not critical SRO (A8) S 1 E LOD = 1. Little discriminatory value. Modify JPM to test on some additional knowledge such as site vs federal limits, planned special exposures, reportability, calculating internal dose, etc.

Modified the JPM to require the applicant to obtain the airborne dose rate from a survey map. The applicant must also convert DAC to mrem.

Attachment 10 Page 2 of 6 OBDI 202 - IOLE Process CW-2014-12 DRAFT OPERATING TEST COMMENTS ADMIN JPMS JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia SRO (A9) S 2 S "a Alert" should be "an Alert" in steps 3 and 6 Change 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 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 CW-2014-12 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia S1 D 2 S Changed acceptable range from 100 gallons to 97 to 103 gallons Removed steps 2 and 3 S2 D 3 S Added "without initiating Safety Injection" to Task Standard Added note to clear computer between JPMs

Step 12 no longer a CS

Added information about operator aid to step 13 S3 D 2 S Include normal stroke time range and maximum allowable stroke time in step 17 for examiner's reference. Change made Added "NOT" to step 12

Added "OPEN is the initial position" S4 D 2 S Added "(or B) and secured the respective RCP Oil Lift pump. ' to the task standard. Modified several step to allow for the operator to start either the A or B RCP, since the procedure allows this action S5 D 3 S Added note about stopping pumps if RWST level lowers to 6% S6 D 3 S Added "prior to "A" DG auto trip." to task standard Step 12 is no longer a CS S7 D 3 S Added note between steps 2 and 3 "NOTE: The Operator will select away from NN01 components on the following switches" S8 D 3 S -What is the basis for the time limit? Clarify in step 7 if limit is 9m 30s.

Changed time in step 7 to 10 minutes

Removed "30 seconds from cue

Made step 8 a CS

10 minutes is a limit in section 9.2.2.2.3 of the FSAR, which states: "The reactor coolant pump motor bearings are qualified for 10 minutes of operation without cooling water. Pump operation can be terminated or the cooling water can be established within 10 minutes." -Modify Task Standard to read (in part): "-restored CCW to containment (within 10 minutes) and the Reactor Coolant Pumps -"

- Comment incorporated to JPM and also on ES-301-2 for RO and SRO.

P1 D 3 S Bold "JPM is complete" All cues have been bolded P2 D 3 S Place quotations around examiner cues and bold like in P3 Change complete P3 D 3 S Step 6, cues: condense down to a single statement "Breaker initially indicates ON", and after operation "This breaker indicates OFF".

Don't need to include the same statement for each breaker.

Change complete 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 Attachment 10 Page 4 of 6 OBDI 202 - IOLE Process 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 5 of 6 OBDI 202 - IOLE Process CW-2014-12 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 [Spare] -Majors count as malfunctions for overall scenario quality. Should be 7. See NUREG 1021 App D Attachment 2 examples. They do NOT however count as additional malfunctions for an individual operator's "bean count".

Changed total malfunctions -If BOP takes action to lower turbine load on event 3 he gets credit as well.

BOP given credit -Does MSLB occur automatically on reactor trip?

Yes -Page 17 of 23, if CRS directs equipment operator to locally open EN-HV-12 it will not operate. Cue added to page 14 "When contacted has OT to locally open EN-HV-12, wait 3 minutes and report that the valve will not open."

-Make E-0 Att A a separate attachment at the end of the D-2. Direc t the BOP's examiner to reference this attachment, but leave reference to the 2 critical steps in the main body as well. same for all scenarios.

Change made 2 -No low-power (<5%) scenarios in the set. Modify to include a low-power scenario. Modified to a low power scenario

-Define what SG Level is considered "dryout". 0% WR, or something else? 10% WR or (25% WR is adverse containment)

-If this scenario is modified to low power, evaluate how to maximize decay heat for this IC so that CT-1 is more challenging. Evaluated and decay heat has been maximized -How long does it typically take for RCP seal degradation on a loss of all AC?

Degradation will start soon after AC power is lost. The limit to insure the accident analysis is met is 25 gpm per RCP.

-Formatting error page 17 corrected -Identify indications of seal degradation (i.e. what value of seal leakoff would indicate degradation?)

25 gpm per RCP

-Should be 6 Malfunctions corrected -Add an additional component malfunction after the major.

Event 8 added

-Event 4, add Tech Specs. TS added -Event 5, BOP does not perform any verifiable actions.

BOP no longer given credit -Event 4, ATC does not perform any verifiable actions. ATC no longer given credit

-Cue page 26/36, "after completion of step 5" to ensure ATC bean.

Cue added -page 29/36, "cabinet doors are open, or another operator will perform" Cue added 3 -Make E-0 Att A a s eparate attachment at the end of the D-2 Change made -Include steps for reducing turbine load.

Steps have been included 4 -Make E-0 Att A a s eparate attachment at the end of the D-2 -Event 3, TS 3.7.4 Condition A. TS annotated -Event 4, TS 3.4.13 Condition B. TS annotated 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 Attachment 10 Page 6 of 6 OBDI 202 - IOLE Process CW-2014-12 DRAFT OPERATING TEST COMMENTS SCENARIOS comment and explain the iss ue in the space provided. 1. ES: ES-301 checklists 4, 5, & 6 satisfied.

TS: Set includes SRO TS actions for each SRO, with required actions explicitly detailed.

Crit: Each manipulation or evolution has explicit success criteria documented in Form ES-D-2.

IC: Out of service equipment and other initial conditions reasonably consistent between scenarios and not predictive of scenari o events and actions.

Pred: Scenario sequence and other factors avoid predictability issues. TL: Time line constructed, including event and process triggered conditions, such that scenario can run wit hout routine examine r cuing. L/C: Length and complexity for each scenario in the set is reasonable for the crew mi x being examined, such that all applicants have reasonably similar exposure and events are needed for evaluation purposes. Eff: Sequence of events is reasonably efficient for examination purposes, especially with respect to long delays or interaction

s. 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. 2. 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.

General Comments:

1. When submitting final ES-301-5, use designators instead of actual names (i.e. R1, I1, I2, etc) as this document will be publ icly available. 2. Additional operating test comments to be identified during validation week.

3. Ensure all SRO-I's get 2 I/C malfunctions as ATC.