ML15351A435

2015-12 Draft Operating Test Comments

ML15351A435
Person / Time
Site:	Cooper
Issue date:	12/08/2015
From:	Vincent Gaddy Operations Branch IV
To:	Nebraska Public Power District (NPPD)
References
50-298/15-012
Download: ML15351A435 (6)

Text

CN-2015-11 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 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 (A1) S 2 S GENERIC ALL JPMs: remove title of JPM from coversheet, only reference by designator (A1, P1, etc)

Removed title from front page, added title to second page.

GENERIC ALL JPMs: Ensure applicant handouts have JPM designator on them.

Added JPM number to top of operator handout GENERIC ALL JPMs: Every task standard should start with On completion of this JPM, the applicant All task standards revised as per comment.

GENERIC ALL JPMs: Include actual procedural step # on examiner guide.

Added procedure step number to left-most column of JPM steps.

SCHEDULE: JPMs S3 and S6 should be run concurrently, as well as S2 and S7.

GENERIC ALL Scenarios: Potential TS entries dont count for an SRO bean. Only actual TS entries.

Replaced potential TS calls for credit with actual TS condition entries as per NRC prep week validation.

For JPM A1: Listed actual MFLCPR value and limit. Made only identification of actual MFLCPR above its limit critical in JPM step 9.

RO (A2) S 3 S RO (A3) S 2 X E Add a survey map and expected work time in order for applicant to calculate exposure.

Survey map and stay time added, job dose removed.

RO (A4) S 3 S SRO (A5) S 2 S Fill out key for examiner.

Key now provided.

SRO (A6) S 2 S SRO (A7) S 2 S Changed validation time to 10 minutes.

SRO (A8) S 3 S Modify cue, Determine who must approve the exposure limits.

Cue revised.

SRO (A9) S 3 X E Delete SA1.1 as an applicable emergency classification.

Deleted EAL SA1.1.

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. 0 Page 1 of 6 OBDI 202 - IOLE Process

• 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 2 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 3 X S Task standard: aligned and subsequently secures HPCI and prevents restart.

Task standard revised per comment.

Add reference to procedural guidance requiring HPCI secured.

SOP precaution/Limitation added.

S2 D 3 X S Add to task standard: commences depressurization to 500 psig at 40 psig/min Revised task standard per comment.

Validation time = 6 min. Validation time changed to 6 minutes.

S3 D 2 X E Rod should re-couple at 48 steps. Modify IC setup.

Modified auto trigger to delete malfunction when CRDM is inserted to position 48.

S4 D 3 X E Provide completed Att 15 sheets for electrician, steps 13 and 21.

Provided evaluator cues for handing out proper Att 15 markup at the proper steps.

Steps 9, 10 critical. Made steps 9 and 10 critical.

Steps 22, 23 add examiner cue that wait time has elapsed.

Provided examiner cues that the 5 and 15 minute cool down periods are elapsed.

S5 S 2 S Validation time = 10 min.

Changed validation time to 10 minutes.

S6 S 2 S Revised initial conditions, since JPM will be performed in parallel with a Mode 1 JPM.

S7 D 3 E Steps 10, 11, 13, 14 are critical. Made steps 10,11,13, and 14 critical.

Add comment to step 11 that red light comes on at 600 gpm.

Added note per comment.

Validation time = 10min. Changed validation time to 10 minutes.

Add to task standard: separates REC critical loops and starts REC pump C or D.

Revised task standard as per comment.

S8 D 3 S Make 4.1.1 a subsequent handout, if requested.

Added evaluator note to handout 4.1.1 when requested by the student.

P1 D 3 X E Add to task standard, without adjusting potentiometer Revised task standard as per comment.

Add potential examiner cues for Power transfer contactors panel indications, RPS DIV I and II light indications, RPS MG set 1A control cubicle.

Added cues for local indications as per comment.

Add caution statement from procedure at step 4.

Added procedure caution per comment.

Include cue that applicant may elect to go straight to opening breaker on indication of swinging voltage, which is acceptable.

Added evaluator note per comment, denoting what steps may become N/A.

P2 S 3 S P3 D 3 X S Add initial condition that Control Room indications of SFP level are not available.

Added initial condition and removed cues pertaining to control room reading SFP level. 0 Page 3 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 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 4 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 X X X E Add IRM D INOP to turnover sheet to ensure event 3 is an actual TS entry. Potential LCOs dont count.

Added IRM D inop but not bypassed to make IRM H and actual LCO condition entry.

Auto-trigger steam leak when 5 rods are full-in. Auto trigger and booth operator backup instructions added.

Add steps pg 23 for MSIV low level and RPS jumpers. Added steps from 5.8.3 and 5.8.20 for RPS and MSIV jumper installation.

Event 5 Add reference to potential TS 3.3.8.1, and TS 3.4.5 for follow-up. Added reference to 3.3.8.2, RPS EPA Bkrs, (not 3.3.8.1 LOP instrumentation, I had mis-noted it) and TS 3.4.5, for DW atmospheric monitor, and accommodated follow-up question.

Specify Max Safe Temp Limit in critical task. Specified 195°F in parenthesis.

2 X X S Add PC Flooding entry criteria to critical task.

Added PC Flooding entry criteria.

Event 4: Add applicable TS if DW pressure > 0.75psig (3.6.1.4?)

Added potential to enter TS 3.6.1.4. Also added TS 3.4.1 for single loop operation and Stability Exclusion region entry.

Post-major: add 5.3EMPWR actions to D-2.

Added actions for REC and Air Compressors from 5.3EMPWR.

3 X E Event 2: Lower power to 98%. Event 2 is now reduce power to 98%.

Initial power should be 100%. Initial condition is now 100% power.

Also revised end point to All Rods In and revised simulator file to auto delete ATWS when ATC resets the scram.

4 X E Eliminate failed APRM A in initial conditions. Event 2 will remain for a board operator bean, but will not be credited for a TS entry. This is because crew may take no action with 1 APRM already bypassed. Deleted APRM A inop from initial conditions.

Add another event for TS entry (MSL Rad Mon A fails downscale).

Added MSL Rad Monitor A downscale, TS 3.3.6.1 as event 3. Revised subsequent event numbers.

Event 4: Add note that if crew scrams, FW break is auto-triggered.

Added auto trigger to simulator file and scenario notes that FW line break will auto trigger if crew prematurely scrams (if RPS A and B are de-energized).

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. 0 Page 5 of 6 OBDI 202 - IOLE Process

CN-2015-11 DRAFT OPERATING TEST COMMENTS SCENARIOS

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 6 of 6 OBDI 202 - IOLE Process

CN-2015-11 DRAFT OPERATING TEST COMMENTS ADMIN JPMS

4. Job Content

1. 2. 3. Attributes 6.

Errors 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 (A1) S 2 S GENERIC ALL JPMs: remove title of JPM from coversheet, only reference by designator (A1, P1, etc)

Removed title from front page, added title to second page.

GENERIC ALL JPMs: Ensure applicant handouts have JPM designator on them.

Added JPM number to top of operator handout GENERIC ALL JPMs: Every task standard should start with On completion of this JPM, the applicant All task standards revised as per comment.

GENERIC ALL JPMs: Include actual procedural step # on examiner guide.

Added procedure step number to left-most column of JPM steps.

SCHEDULE: JPMs S3 and S6 should be run concurrently, as well as S2 and S7.

GENERIC ALL Scenarios: Potential TS entries dont count for an SRO bean. Only actual TS entries.

Replaced potential TS calls for credit with actual TS condition entries as per NRC prep week validation.

For JPM A1: Listed actual MFLCPR value and limit. Made only identification of actual MFLCPR above its limit critical in JPM step 9.

RO (A2) S 3 S RO (A3) S 2 X E Add a survey map and expected work time in order for applicant to calculate exposure.

Survey map and stay time added, job dose removed.

RO (A4) S 3 S SRO (A5) S 2 S Fill out key for examiner.

Key now provided.

SRO (A6) S 2 S SRO (A7) S 2 S Changed validation time to 10 minutes.

SRO (A8) S 3 S Modify cue, Determine who must approve the exposure limits.

Cue revised.

SRO (A9) S 3 X E Delete SA1.1 as an applicable emergency classification.

Deleted EAL SA1.1.

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. 0 Page 1 of 6 OBDI 202 - IOLE Process

• 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 2 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 3 X S Task standard: aligned and subsequently secures HPCI and prevents restart.

Task standard revised per comment.

Add reference to procedural guidance requiring HPCI secured.

SOP precaution/Limitation added.

S2 D 3 X S Add to task standard: commences depressurization to 500 psig at 40 psig/min Revised task standard per comment.

Validation time = 6 min. Validation time changed to 6 minutes.

S3 D 2 X E Rod should re-couple at 48 steps. Modify IC setup.

Modified auto trigger to delete malfunction when CRDM is inserted to position 48.

S4 D 3 X E Provide completed Att 15 sheets for electrician, steps 13 and 21.

Provided evaluator cues for handing out proper Att 15 markup at the proper steps.

Steps 9, 10 critical. Made steps 9 and 10 critical.

Steps 22, 23 add examiner cue that wait time has elapsed.

Provided examiner cues that the 5 and 15 minute cool down periods are elapsed.

S5 S 2 S Validation time = 10 min.

Changed validation time to 10 minutes.

S6 S 2 S Revised initial conditions, since JPM will be performed in parallel with a Mode 1 JPM.

S7 D 3 E Steps 10, 11, 13, 14 are critical. Made steps 10,11,13, and 14 critical.

Add comment to step 11 that red light comes on at 600 gpm.

Added note per comment.

Validation time = 10min. Changed validation time to 10 minutes.

Add to task standard: separates REC critical loops and starts REC pump C or D.

Revised task standard as per comment.

S8 D 3 S Make 4.1.1 a subsequent handout, if requested.

Added evaluator note to handout 4.1.1 when requested by the student.

P1 D 3 X E Add to task standard, without adjusting potentiometer Revised task standard as per comment.

Add potential examiner cues for Power transfer contactors panel indications, RPS DIV I and II light indications, RPS MG set 1A control cubicle.

Added cues for local indications as per comment.

Add caution statement from procedure at step 4.

Added procedure caution per comment.

Include cue that applicant may elect to go straight to opening breaker on indication of swinging voltage, which is acceptable.

Added evaluator note per comment, denoting what steps may become N/A.

P2 S 3 S P3 D 3 X S Add initial condition that Control Room indications of SFP level are not available.

Added initial condition and removed cues pertaining to control room reading SFP level. 0 Page 3 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 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 4 of 6 OBDI 202 - IOLE Process

CN-2015-11 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 X X X E Add IRM D INOP to turnover sheet to ensure event 3 is an actual TS entry. Potential LCOs dont count.

Added IRM D inop but not bypassed to make IRM H and actual LCO condition entry.

Auto-trigger steam leak when 5 rods are full-in. Auto trigger and booth operator backup instructions added.

Add steps pg 23 for MSIV low level and RPS jumpers. Added steps from 5.8.3 and 5.8.20 for RPS and MSIV jumper installation.

Event 5 Add reference to potential TS 3.3.8.1, and TS 3.4.5 for follow-up. Added reference to 3.3.8.2, RPS EPA Bkrs, (not 3.3.8.1 LOP instrumentation, I had mis-noted it) and TS 3.4.5, for DW atmospheric monitor, and accommodated follow-up question.

Specify Max Safe Temp Limit in critical task. Specified 195°F in parenthesis.

2 X X S Add PC Flooding entry criteria to critical task.

Added PC Flooding entry criteria.

Event 4: Add applicable TS if DW pressure > 0.75psig (3.6.1.4?)

Added potential to enter TS 3.6.1.4. Also added TS 3.4.1 for single loop operation and Stability Exclusion region entry.

Post-major: add 5.3EMPWR actions to D-2.

Added actions for REC and Air Compressors from 5.3EMPWR.

3 X E Event 2: Lower power to 98%. Event 2 is now reduce power to 98%.

Initial power should be 100%. Initial condition is now 100% power.

Also revised end point to All Rods In and revised simulator file to auto delete ATWS when ATC resets the scram.

4 X E Eliminate failed APRM A in initial conditions. Event 2 will remain for a board operator bean, but will not be credited for a TS entry. This is because crew may take no action with 1 APRM already bypassed. Deleted APRM A inop from initial conditions.

Add another event for TS entry (MSL Rad Mon A fails downscale).

Added MSL Rad Monitor A downscale, TS 3.3.6.1 as event 3. Revised subsequent event numbers.

Event 4: Add note that if crew scrams, FW break is auto-triggered.

Added auto trigger to simulator file and scenario notes that FW line break will auto trigger if crew prematurely scrams (if RPS A and B are de-energized).

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. 0 Page 5 of 6 OBDI 202 - IOLE Process

CN-2015-11 DRAFT OPERATING TEST COMMENTS SCENARIOS

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 6 of 6 OBDI 202 - IOLE Process