ML16293A975

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2016-07 Proposed OP Test Comments
ML16293A975
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/11/2016
From: Vincent Gaddy
Operations Branch IV
To:
References
Download: ML16293A975 (15)
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Text

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link General Comments:

1. Task Standards must be written to encompass all Critical Steps, either directly or by reference to Answer Key.RA1.RA2,RA3,RA4,SA1,SA2,SA3,SA4,SA5,S1,S2,S3,S4,S5,S6,S7,S8,P1,P2,P3
2. Need discussion on Reference Materials vs Required Materials. Is there a distinction between references used to generate the JPM verses materials required to perform the JPM (other than Handouts)? Some JPMs have Reference Materials while others have Required Materials after the Task Standard.

RA1,RA2,RA3,RA4,SA1,SA2,SA3,SA4,SA5,S1,S2,S3,S4,S5,S6,S7,S8,P1,P2,P3

3. Revision numbers of Handouts should be documented if not included in Ref Matls. RA1,RA2,RA3,RA4,SA1,SA2,SA3,SA4,SA5,S1,S2,S3,S4,S5,S6,S7,S8,P1,P2,P3
4. Recommend changing JPM step Standard to Performance Standard to help differentiate between Task and Performance standards. (change to JPM template)

RA1,RA2,RA3,RA4,SA1,SA2,SA3,SA4,SA5,S1,S2,S3,S4,S5,S6,S7,S8,P1,P2,P3 RO S 2 X E How does applicant implement Note 4.2.B in SOP-104A? Note says 1-FY-111B (RA1) should be set 1 gallon less than what is desired. Is this deduction included in calculation on Attach 2, page 1 (step 2.0.B and 2.0.F), or when actual adjustments are made later using Attachment 2? This adjustment would be made when actually performing a Boration per step 3.0D. Does this affect Task Standard or Answer Key? No.

RO S X E Change Initiating Cue to inform US, not SM. Corrected.

(RA2) 0 Page 1 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link RO S 4 X E 1. Change Task Standard to encompass all ICRRs and plots (consider Using (RA3) IPO-002B, calculated Inverse Count Rates and performed 1/M plots using data provided on Attachment 2. Determined criticality predicted Revised as suggested

2. Where would any required action based on 1/M Data obtained on Attachment 2, page 3 of 4 be recorded if this task were performed in the Control Room? The procedure does not clearly state but it would probably be recorded in the Unit Log and a Condition Report would be initiated.
3. The bands of +- 0.1 for all 4 calculations (50/55=0.909, 50/65=0.769, 50/88=0.568, 50/333=0.15) seems to be excessive. What is the acceptable band when calcs are performed in the CR? I believe this comment is a mistake as the band on all 4 is +/- 0.01 not 0.1. Thus the band is tight based on rounding performing the calculation correctly and then rounding up or down incorrectly based on just reading the first 2 decimals points or rounding on the 3rd decimal value. The acceptable band in the control room would be different in that a performer and peer checker would both agree on the value to plot thus no need for a band.
4. Should JPM Step 3 be CB A at 150 steps and JPM Step 4 be CB A at 200 steps? No, the curve changes controlling groups at CBA @ 100 and CBB becomes the controlling Group. However, the Procedure 1 and Answer Key needed to be changed to reflect the accurate points to plot which were CBB @ 35

& 85 respectively which are the same as CBA @ 150 & 200.

5. JPM step 5 Standard - add the Rod Insertion Limit number. Added.
6. With the ECC outside the +/- 500 PCM band, does this require the applicant to denote an action to contact Core Performance Engineering to provide guidance on the startup (IPO-002B, Step 5.2.26 and first bulleted Note before Step 5.1.25)?

This would be correct if that information was provided. As this would be a tighter band than the JPM it becomes very difficult to predict when each applicant would recognize the +/- 500 pcm being exceeded based on plotting variations. Therefore, the information has not been calculated and plotted on the graphs as would be required per IPO-002B, Att. 2 Step 3.2. 0 Page 2 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link RO S 2 X E 1. The survey map, Handout 1, is acceptable for the proposed submittal.

(RA4) However, since it is a quarterly survey, and it was performed on 4/04/16, it will have expired by the time of exam administration. Revise one for the final exam package so that the applicants dont question the date. I am not disagreeing with this request, but I have the following concern. As the next routine would not be performed until probably the first week of July (which is a Holiday week), I may not have available access to the new map until right before the test administration. Further, the new map could possibly change some of the parameters and thus require a complete revision of the JPM right before it is administered. Would it not be safer to just have the examiners tell the applicants to use the map provided as the current map, if they were to question use of the map based on date?

2. Handout 3 - would valves be surrounded by boxes if performed in the plant?

Need to ensure all handouts would be just like if performed in the plant. New handout made to answer Items 2 & 3 with additional emphasis on not distorting the images. Removed boxes from valves. Valve map is available to operators electronically and they can enlarge for clarity. New handout divided picture and valve listing into 2 pages to closely approximate what they would see on the computer.

3. Handout 3 - is the quality of this handout acceptable? Is this what an operator would use? See above.

SRO S 3 S Add to Performance Standard in each JPM step from where the correct answers (SA1) are found in Attachment 8.A. Added. 0 Page 3 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link SRO S 2 X E 1. According to STA-102, Attachment 8.A, Step 4, fourth bullet, a Human (SA2) Performance related SL 1 through 4 event requires a QERC. However, if a PERC for the Event / Issue will be conducted, a QERC need not be performed.

However, the reason for not performing the QERC should be captured in the Condition Report. How is this requirement captured in the JPM? The proposed Critical Step should include knowledge that a QERC isnt is required because a PERC will be performed. Answering both correctly demonstrates the knowledge and understanding of the administrative task. If either is answered incorrectly, then a Critical step is missed which should therefore be a JPM failure. Further, clarification by the applicant is not necessary to demonstrate an understanding of the task. If the JPM included an additional requirement to supply a why the QERC is not required, this would be cuing that a QERC is not required.

2. STA-102, Reactivity Management Program, (labeled Procedure 1) not provided with submittal. I apologize for the omission.
3. Are all 6 pages of Handout 1 needed or is this a standard briefing package?

The Reactivity Briefing Sheet is actually a 6 page package which is the standard by which shift Reactivity Briefs and responses to events such as runbacks are conducted. The entire package should be provided for completeness. JPM says Handout 1 is Reactivity Briefing Sheet for 10000.0 MWD/MTU which is page 1 of 6.

4. Define PERC and QERC in JPM steps. Defined. 0 Page 4 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link SRO S 3 X E? 1. Initial Conditions - why inform applicant that a Fire Protection (SA3) System/Equipment Impairment Form must be initiated? Should they not know this? Yes, they would identify that a Fire Impairment is required. See Item 2 Response for more detail.

2. Initiating Cue - why have the SM tell them how to fill out the STA-738-2? How would this be done in the Control Room? Would the SM not just direct the US to complete the form? Yes, in the case of an actual plant situation requiring a Fire Impairment be processed on shift, that would probably be all the direction that is needed to be given. However, in the artificial world of testing, the applicant does not have all of the information and resources for the actual situation as they would in the control room. Therefore, in order to provide proper focus on completion of the JPM it is necessary to provide clear direction on what determinations are required as many do not have the information to complete. If this direction were not given each applicants response would differ and thus jeopardize the validity of the JPM. Further, it could provide any applicant desiring to appeal a solid case for saying that the JPM did not provide the necessary cue for proper completion of the task. This JPM was on the 2013 NRC exam in this form and I do not see a compelling reason for it to be changed.
3. With the main and reserve tank cylinder pressures below minimum specification, do they still have margin to provide a decreased level of fire protection from that which was provided by design and installation? This ties to the definition of inoperable in STA-738. Attachment 8.A defines Halon system action for inoperability. Since there are no examples of inoperability stated, ensure that this meets the case. Step 8.2.9 of FIR-303 states If any portion of the above described inspection is unsatisfactory for a system, the respective system should be considered impaired. The Fire Protection Supervisor and Shift Supervisor should be notified, and compensatory measures shall be taken per STA-738.
4. The references dont support the answer that this DOES affect Fire Brigade strategy. STA-738, Attachment 8.A only says that Fire Brigade strategy MAY be affected with inoperable fire hose stations [Step 5)]. Provide a reference to support this as a correct answer. Per FPI-505, the Fire Brigade Strategies include Automatic Halon Actuation and Manual Suppression Actuation Stations. As these are both impacted, the Fire Brigade Strategy approved in FPI-505 is obviously affected.
5. Task Standard needs to reference the Answer Key or somehow capture all the critical steps. Reference the Answer Key.
6. Each of the JPM step Performance Standards should identify how the answer is determined, especially on Critical Steps since failure results in JPM failure.

This also minimizes the amount of time it takes for the Examiner to validate the JPM. Added 0 Page 5 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 ADMIN JPMS

4. Job Content
3. Attributes
1. 2. Errors 6.

5.

JPM# Dyn LOD IC Cues Critical Scope Over- Job Minutia Explanation U/E/S (D/S) (1-5) Focus Steps (N/B) lap - (See below for instructions)

Link SRO S 4 X X E 1. See comments on RA4. They are the same for this one. Incorporated.

(SA4) 2. Procedure STI-501, Section 5.3.1, says that the Shift Manager is responsible for evaluating reportability requirements. Can an applicant argue that this task is not part of his/her scope of licensed duties? I assume this is STA-501 vs. STI-501. No, they cannot argue this as it is an SRO task (SO1112) and SROs are expected to perform duties of the SM in his/her absence with the exception of Emergency Coordinator duties for which they have not yet been qualified. This should not be an issue for this JPM and will not be supported by CPNPP management. Is this something that the Shift Manager, by procedure, can delegate to the Unit Supervisor? Yes Does Task # SO1112 encompass this activity? Yes.

3. Should STA-501 be added to list of procedures to be made available to applicant? Yes. Added as Procedure 3.

SRO S 3 X X E 1. Task Standard needs to include that the applicant has to make the EAL (SA5) classification within 15 minutes. 10 CFR 50, Appendix E, Section IV.C.2. A Critical Step supporting this needs to be added to the JPM as well. Added time to Task Standard and Perform Step 4.

2. Task Standard also needs to identify the Emergency Classification (SS5.1) or reference to Answer Key. Added to Task Standard.
3. If the Plant Computer System has alarm and indication capability, and alarming is the only thing stated that is impaired, can an applicant infer that indication capability is still available? Is SPDS indication still functional? If so, then compensatory indications can be argued as available. The declaration becomes SU5.1, which may have been declared already, with 10 minutes elapsed. Per the bases to SS5.1 it states with respect to the Compensatory measures of the Plant Computer, Indications needed to monitor safety functions necessary for protection of the public must include Control Room indications, computer generated indications (i.e., Plant Computer) and dedicated annunciation capability (ref. 10, 11). The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, remove heat from the core, and maintain the reactor coolant system and containment intact. With reference 11 being ABN-906 which was entered for the loss of Alarm Capability, it is clear that Compensatory Measures are not met and thus the SAE is warranted.
4. Reference Materials is identified as Required Materials after Task Standard (minor edit). Edited.

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. 0 Page 6 of 15 OBDI 202 - IOLE Process

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 7 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job
3. Attributes Content
1. Errors
2. 5. 6.

Dyn JPM# LOD IC Cue Critic Scop Over- Job Minuti U/E Explanation (D/

(1-5) Focu s al e lap - a /S (See below for instructions)

S) s Step (N/B) Link s

S1 D 3 X N U 1. Provide a copy of the Bank JPM used for the modification. Provided

2. The initial conditions dont tell the applicant that the last movement of Control Bank D was outward. Correct. Procedure Step 3.3.15.c moves the affected group outward, thus the applicant knows which direction they were moved.
3. If the cause of the Rod Control Urgent Failure has been resolved by the actions already taken, JPM Steps 14-17 are just a part of the normal restoration process. The need to reset this alarm is a planned condition of restoring the rod to its normal position.

This does not require the applicant to diagnose a problem, and determine from the paths of action what the appropriate one is. Unless there is an instrumentation malfunction, meaning this alarm is in when it should have cleared on its own, this isnt an alternate path JPM. Disagree with comment but will remove Alternate Path designation from JPM.

S2 D 2 X E 1. To complete procedure 1-ALB-5C, Window 1.4, Step 4, both PORV block valves have to be closed. This should be part of the JPM step (only shows one). Added non-critical step with examiner note that step will probably be N/A as applicant has already determined the affected PORV.

2. If part of the Task Standard will be whether the applicant closes the PORV block valve prior to receiving a low pressurizer pressure reactor trip signal, then that needs to be captured in an evaluated JPM step (Critical Step). Added clarification to Performance Standard for Step 13.

Procedure comments:

1. The logic diagram for procedure 1-ALB-5C, Window 1.4 does not appear to be correct.

According to the diagram, having a PORV not closed AND having a control power fuse issue would cause the alarm. Having the PORV not closed on its own doesnt cause the alarm, per the logic gates (AND gates vice OR gates).

2. Step 4 mentioned above - with the affected PORV already identified in previous steps, it is peculiar that the procedure step says to identify the affected PORV. If there a case where this could be masked up to this point? This may tie into the logic behind closing both PORV block valves in this step. Added both to procedure change CR to be initiated following the test. 0 Page 8 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job
3. Attributes Content
1. Errors
2. 5. 6.

Dyn JPM# LOD IC Cue Critic Scop Over- Job Minuti U/E Explanation (D/

(1-5) Focu s al e lap - a /S (See below for instructions)

S) s Step (N/B) Link s

S3 D 3 X X S 1. Steps 3, 5, and 11 appear to be Critical Steps - they need to be marked as such.

RHRP 1 is not running and thus Step 3 to place pump in Pull-out is the correct thing to do but not critical to completing the task. Step 5 valve is in proper position thus Performance Standard is Observe only - not critical. Step 11 procedure calls for stopping the PDP, but it is not required in order to satisfy the Task Standard and there are no adverse consequences if this step is not performed, thus not critical.

2. Initial Conditions: If RHR Train B is in service, with the plant in Mode 4, is a CCP normally running? Yes It doesnt say, but the JPM says in Step 10 that it was running.
3. Per Step 12.e of the procedure, it looks like both JPM Steps 17 and 18 are Critical Steps. They do not have to be performed in a specific order, but the procedure step indicates that both are needed to meet its intent. Valves are parallel flow paths each capable of 100% of the needed flow. Opening only one valve satisfies the Task Standard of providing injection to the RCS via CCP injection.

S4 D 2 X S Whether the applicant recognizes that the main turbine speed is greater than 100 rpm above turning gear speed or not, the applicant actions are the same. If he/she doesnt recognize it, then the procedure directs them to trip the main turbine anyway. The applicant can successfully meet the Task Standard without recognizing there is a problem. The overall task needs to be reviewed to see if it can be defined better so that pass/fail criteria can be clearly delineated. Then, the Task Standard can be adjusted.

Incorrect as the Task Standard clearly states that they must trip the turbine prior to the HP stop valves obtaining the full open position. The Turbine is not tripped per the procedure until Step 8.7 but the HP stop valves must obtain the full open position to complete Step 8.5. This is also clearly stated in the Performance Standard of Step 14. 0 Page 9 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job
3. Attributes Content
1. Errors
2. 5. 6.

Dyn JPM# LOD IC Cue Critic Scop Over- Job Minuti U/E Explanation (D/

(1-5) Focu s al e lap - a /S (See below for instructions)

S) s Step (N/B) Link s

S5 D 3 X X E 1. The Initial Conditions say that RWST level is at 7% and lowering. Add to Comment block an Examiner Note that applicant should wait until RWST level is < 6% prior to starting JPM. If not, the applicant will go to the RNO column on Step 4a. This directs he/she to perform Step 5, but also directs he/she to do the switchover per Step 4b when level is less than 6%. Would get confusing The Initiating Cue states When RWST level reaches 6%, Perform Att. 1.H. The applicants are going to stand and monitor RWST level and then perform the actions. I believe when you see this performed you will understand that additional clarification is not needed, but if it is you can explain exactly what you want to state and where as I am not sure what should be added as we do not put examiner notes in the Comment Block?

2. TSA-2.8 and it supporting design basis analyses need to be reviewed to see if the 70 second time requirement applies to this alternate path JPM. It depends on a) what the analysis states is assumed to be completed in 70 seconds, and b) what component failures are assumed. This has been reviewed and the analysis assumes a single failure (the one in this JPM) and the Critical Stop time is aligned with the analysis time and actions which must be completed in 70 seconds.
3. IF the Time Critical nature of this JPM is sustained, then it needs to be addressed in the Task Standard statement. The JPM Summary in the Outline submittal discussed the Time Critical nature of the JPM but there is no reference to it in the Task Standard in this Proposed Op Test submittal. Revised per request. I do want to point out that having it marked Time Critical with a Time Critical Time on the page has always been acceptable until this exam. This also applies to SA5.

Procedure comments:

1. If the design basis assumption is that RWST switchover for the CSPs occurs within 70 seconds when the RWST level reaches 6%, then the EOS-1.3A, Attachment 1.H is written in a way that delays the operator action. Verbatim compliance with the procedure doesnt allow any switchover action until RWST level is below 6%. Depending on the RWST drain down rate, and the stroke time on the valves, this may lead to lost valuable time in completing the task. Analysis and Procedure are in agreement and validated, no further action necessary.
2. The way that Step 4.b.3) is written, it will not drive an operator to take the action in the RNO column for the CS HX outlet valve. The apparent intent is to complete the RNO actions if CS flow is 0 gpm for any train. However, it doesnt say, VERIFY containment spray flows are greater than 0 gpm or equivalent. This was captured and was the driving force behind the change back to the bank JPM. 0 Page 10 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job
3. Attributes Content
1. Errors
2. 5. 6.

Dyn JPM# LOD IC Cue Critic Scop Over- Job Minuti U/E Explanation (D/

(1-5) Focu s al e lap - a /S (See below for instructions)

S) s Step (N/B) Link s

S6 D 2 X E If there are any procedural prerequisites that need completion prior to this task, something needs to be said about them in the Initial Conditions. None Procedure comment: If the bus is transferred to offsite power, and taken off of the EDG, what procedure step opens the EDG output breaker? The only steps shown in the procedure for opening the EDG output breaker are if there is a potential EDG overload condition. Step 5.7.K directs the operator to a different procedure section to shutdown the EDG. In this case it would be Section 5.3. Step 5.3.G would open the breaker.

S7 D 2 X E For JPM Step 9, will the applicant ask the SRO which loop to set it on? They shouldnt as the ROs are allowed to select the Loop for a recorder. Is there a typical one they are trained to select to? No.

S8 D 3 S P1 D 2 X E 1. What is the definition of desired tank level for the Stuffing Box Coolant Tank? Where is this information provided? It is physically marked on the Sight Glass.

2. Recommend saying that it is the PDP discharge valve in the Task Standard.

Incorporated.

P2 D 3 X E 1. Verify that there are no time assumptions for manual actions on this JPM. Load shedding for a SBO typically has an assumption about how long it takes operators to complete it. It would be documented in the sites SBO submittal and the NRCs SER for the submittal. Hopefully SBO timed actions are captured in the sites time critical operator action program. The CPNPP load shedding performed per this attachment is to extend battery life and is not credited in the SBO SER.

2. Procedure Attachment 2.A, Step 2.c: If transferring power for XEC1-1 load breakers from Unit 1 to Unit 2, shouldnt there be a step to place XEC1-1/00/BKR-1 in the OFF position? The way the procedure steps are written, it looks like the supply from both the Unit 1 and 2 side are being placed on the bus at the same time. Breaker operation is such that operating one of the breakers to the ON position places the other breaker in the OFF position due to manual slide bar.
3. If any of these breakers are inside panels that cannot be opened for equipment control reasons, pictures of the breakers will be needed for Examiner aides. Panels should be opened unless there are specific safety concerns with opening them. They should all be accessible.

P3 D 3 X E 1. The RSP is within a locked cage. It is assumed that the applicants will have the key to enter this area. Verify that there are no issues with access to this area. Have verified that there should be no known obstruction to performing the JPM.

2. What is acceptable boration flow rate in this JPM? Is there a minimum level that needs to be achieved for success? Completing the configuration provides an adequate flow which cannot be directly regulated. There are no criteria associated with this. 0 Page 11 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 CONTROL ROOM/IN-PLANT SYSTEMS JPMS

4. Job
3. Attributes Content
1. Errors
2. 5. 6.

Dyn JPM# LOD IC Cue Critic Scop Over- Job Minuti U/E Explanation (D/

(1-5) Focu s al e lap - a /S (See below for instructions)

S) s Step (N/B) Link 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 12 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 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 X E 1. Event 3: It looks like this event counts for two Tech Spec calls, not one. I have not been able to get a clear answer from the NRC in the past on this. Some Chief Examiners have told me that each TS entered counts as 1, some have even stated that each Function entered counts as 1. In this case 2 TSs are entered and I will count it however, you want it to show on the forms.

2. Same issue with time critical actions in Scenario 3. These are assumed to be evaluated worst case with minimum staffing. Why cant these be applicable? Both event time lines assume 3 ROs.
3. Making Critical Task transitions based on procedure transition is not the best situation. Can they be tied to parameters? CPNPP has attempted to find parameters to tie critical tasks to in all cases but has been unsuccessful at finding clearly defined parameters which would constitute a pass/fail decision for most cases. Will gladly take any input the NRC has and attempt to find a basis for that parameter but usually do not find a defendable basis.

2 X E 1. Event 6 - there doesnt appear to be any verifiable action to be performed by the BOP in order to obtain Component failure credit. That appears to be correct. Corrected on ES-D-1.

2. Events 7&8/CT TSA-2.14 for emergency boration says that it is assumed to be initiated within 15 minutes in all cases (see TRM 13.1.31 Bases). As long as the applicants take care of this action shortly per the foldout page, it doesnt conflict with the critical task. However, if they continue through EOS-0.1A, and get to the emergency boration later than 15 minutes after the loss of power to DRPI, then they meet the critical task. However, they do not meet the design basis assumption. Recommend working the time assumption into the critical task. Added to CT statement.
3. Event 9/CT The goal of bleed and feed is to ensure RCS heat removal prior to RCS heatup and pressurization. Therefore, if the RCS heats up, or pressure increases, prior to establishing bleed and feed lineup, wouldnt that the basis for the critical task?

No as in accordance with STI-214.01, this time is based on SG parameter indication. In this case, the criterion is based on having only a single CCP and thus the 25 minute time is not applicable to this PRA assumption. What does the supporting analysis support for the pass/fail criteria on these parameters? This may be in the background information supporting the 25 minute PRA time assumption for starting bleed and feed, or in the licensing basis.

3 X E The Risk Significance Determination table says that the SGTR timed operator actions do not apply because the crew staffing is less than what is assumed for timed operator validation. The note is incorrect. The times for the SGTR analysis do not apply because the conditions are not the same as those assumed in the analysis. The additional failures which must be included for evaluating the applicants voids the Time Line for the SGTR event. In reviewing the timed operator action procedure (STI-214.01, Section 6.4.3, Step G; and Attachment 8.B, TCA-1.9), the minimum shift staffing for the design basis accident is the minimum staffing for the control room (1 SRO and 2 ROs). Although evaluating this in the exam would not count as a validation activity (not licensed operators), the time assumptions are measurable performance indicators that the 0 Page 13 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 SCENARIOS applicants are expected to meet if they are licensed. The time assumptions need to be part of the SGTR Critical Task. No, in accordance with STI-214.01 these times apply for the following conditions which are not met for this examination and thus are not applicable:

Initial Conditions:

- Unit at 100% RTP Event Conditions:

- Rod Control is in Manual

- Large SGTR occurs constituting the flow for a complete single tube

- Loss of offsite power occurs.

- 1 intact SG ARV cannot be opened from Control Room

- 2 intact SG ARVs must be fully opened for cooldown phase.

4 X E 1. Events 7&8 - They are associated with TCA-1.7 (not TSA-1.7). Time requirement of 14 minutes. Justify why this is not a critical task. The times for the Inadvertent SI analysis do not apply because the conditions are not the same as those assumed in the analysis. The additional failures which must be included for evaluating the applicants voids the Time Line for the Inadvertent SI event. Additionally, the time consideration assumes 3 ROs.

2. Event 6 - In the Executive Summary, it says the NI fails high. In the event description, it says it fails mid-scale. The detector fails high to a value which generates an alarm and Rod Stop but below the level which would generate a Reactor Trip. So it is characterized correctly.
3. No Reactivity Briefing Sheet? (Event 2 - Raise Reactor power to 6% to 8% in preparation for Turbine Startup) No.
4. Why Event 1 prior to power increase (which is known to applicants at turnover)?

Attempting to satisfy Chief on not being predictable in scenarios, so placed a malfunction that would not prevent the MODE change prior to the MODE change.

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 reviewers 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. 0 Page 14 of 15 OBDI 202 - IOLE Process

CP - 2016 - 07 PROPOSED OPERATING TEST COMMENTS REV 2 SCENARIOS

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 15 of 15 OBDI 202 - IOLE Process
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