ML120180407

12 Draft Operating Test Comments

ML120180407
Person / Time
Site:	Grand Gulf
Issue date:	12/02/2011
From:	NRC Region 4
To:	Entergy Operations
References
50-416/11-301
Download: ML120180407 (6)

Text

{{#Wiki_filter:Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process SITE - YEAR - MONTH 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 (AR1) S 2 E Please provide the examiners the surveillance sheet that mimics what the applicant is required to complete with the correct answers noted in the correct spaces, either in a different color or in bold. Fixed RO (AR2) S 1 U LOD=1 Having the applicant verify that green checks exist by their required curriculum and that no action dates have passed is not discriminatory for an NRC licensing exam. JPM Replaced RO (AR3) S 4 E The Note states that additional components are allowed in order to isolate the MDFP. Please provide examiners a list of other components that they mi ght see from the applicant and could be considered acceptable. A system diagram with necessary components isolated might be helpful. Fixed RO (AR4) S 2 S SRO (AS1) S 2 S SRO (AS2) S 1 U LOD=1 Not discriminatory for an NRC licensing exam. Fixed SRO (AS3) S 4 S SRO (AS4) S 3 E Please give examiners a Radwaste Discharge Permit with the errors highlighted as an answer key. Task Standard says to identify 4 of the 5 errors in the permit but it appears there are six errors noted

as critical. Also do not indicate to the applicant in the Task Standard how many errors they are expected to find. All errors are critical and the expectation is that they will find six without knowing the total amount of errors which is more operationally valid. Fixed SRO (AS5) S 3 E Please provide examiners with EAL sheet and thought process that drives applicants to SS4, Site Area Emergency. 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 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.

Attachment 10 Page 2 of 6 OBDI 202 - IOLE Process 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 SITE - YEAR - MONTH 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 3 E Step 5: 4.2.2a(5) - Depress Recirc Pump B CAV INTLK Reset pushbutton - this step is not marked as critical. Are there any cons equences of not pushing this reset button? Fixed Step 6: 4.2.2a(6) - Same question for the RX WTR LVL Interlock reset button. Not Critical S2 D 3 E Initiating Cue - The CRS directs you- Fixed JPM moves from 5.2.1 to 5.2.2b - What about 5.2.2a which would have the applicant ARM and DEPRESS RCIC MAN INIT pushbutton? And would that step be critical? Manual start at 5.2.2b is correct.

Step 3: 5.2.2b has the applicant start the RCIC RM FAN COIL UNIT - consequences of not performing this step as it is not noted as critical? Not critical

Step 4: 5.2.2d has the applicant delegating closing F268 to prevent flow to the reactor due to disc flexing of F013. Shouldn't this be critical? Not critical S3 D 3 S S4 D 3 E Initiating Cue - The CRS directs you- Fixed S5 D 2 E Initiating Cue - The CRS directs you Fixed Step 1: Should placing the SPMU MODE SEL switch to AUTO be critical? Same thing for Step 1 on Division 2. Not critical S6 D 3 S S7 D 3 E Step 1: Placing CCW pump B hand switch to STOP, critical? If not critical, why is this step taken? Not critical , This step only removes the "standby" feature causing a white indicating light to extinguish and will not prevent or affect pump start and operation. S8 D 3 E Step 1: Place SGTS DIV 2 MOV TEST switch to TEST. Should this be critical? Not critical

Step 2: Place hand switches on P842 to STOP. Understanding that this is not modeled in the simulator, if this step is operationally cr itical then this step must be marked as such. The expectation would be that the applicant w ould ask for another operator's assistance in completing this step. This step does not interfere with the securing of SGTS system. This step allows for a controlled restart of the normal ventilation system later. This step should not be critical for this reason. Step 11: MOV Test switch for SGTS DIV 2 back to NORM. Critical? Not critical P1 D 2 S P2 E Step 1: Standard says Checks OR opens P41-F068A(B). Which one will occur? If it has to be opened then this step becomes critical. Fixed Attachment 10 Page 4 of 6 OBDI 202 - IOLE Process SITE - YEAR - MONTH 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 Steps 2, 3, 4, 5 and 7 are not marked as critical but contain applicant actions. Not critical P3 D 2 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 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 5 of 6 OBDI 202 - IOLE Process SITE - YEAR - MONTH 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 E Quantitative Attri butes of scenario - appears to be 3 crit ical tasks vice 4 in the table. Also, appears to be 6 total malfunctions vice 7. Fixed Recommend adding one TS call to the scenario in lieu of the Normal event in event 2. Fixed 2 E Quantitative Attributes of scenario - Reactivity manipulations are 1 not 2. Reactivity manipulation in event 6 is not count ed as it is part of the Major. Fixed Event 1 - Recommend replacing this Normal with an I/C failure. Replaced

Event 4 - Electric Power Monitoring Assembly Inoperable - give indications of this failure in the D-2 for the examiner. What are the entry conditions for this TS? Fixed Event 5 - Place the actions in the D-2 for putting APRM 'F' in service and bypassing APRM'D' in case the CRS takes this route. Fixed Event 8 - "When 2 max save values of EP-4 Table 10 are exceeded, enters the Emergency Depressurization procedure of EP-2" - what values are the Examiners looking for? Please place in D-2. Fixed 3 E Event 3 - Other than the TS call is there any verifiable crew actions to the transmitter failure? No. The D-2 does not indicate any crew actions and so this could not be listed as an Abnormal. Is there an ONEP that is ent ered for this failure? If so, please indicate on the D-1 and D-2. Fixed 4 E Event 5 - Unisolable LOCA - bus lockout indications are given but what LOCA indications/alarms will be apparent to the applicants/examiners? Fixed Event 3 - What ONEP is used for this Abnormal? Put ONEP on D-1 and D-2. Fixed Event 2 - Replace this Normal with an Abnormal. Replaced 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.

Attachment 10 Page 6 of 6 OBDI 202 - IOLE Process SITE - YEAR - MONTH DRAFT OPERATING TEST COMMENTS SCENARIOS 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.}}