ML15007A110

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2014-12 Draft Operating Test Comments
ML15007A110
Person / Time
Site: River Bend Entergy icon.png
Issue date: 12/12/2014
From: Vincent Gaddy
Operations Branch IV
To:
laura hurley
References
Download: ML15007A110 (7)
v • d • e


Text

RB 2014-12 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) D 3 E No marked up key provided S Keys provided and JPM is now Sat.

RO (A2) D 2 E No marked up key provided S Keys provided and JPM is now Sat.

RO (A3) D 3 E No marked up key provided S Keys provided and JPM is now Sat.

RO (A4) D 3 E No marked up key provided Keys provided and JPM is now Sat.

After Draft outlines were submitted and before the draft exam was submitted the licensee requested S

and received permission to change the A4 RO Admin JPM topic and corresponding JPM. The licensee selected the topic of Determine Containment Water Level During Containment Flooding for the A4 topic in place of the original A4 topic of Calculate dose/Determine DAC hours due to licensee pre-validation (not NRC) comments about the original JPM not being an RO task at their plant.

SRO A5 D 3 E No marked up key provided S Keys provided and JPM is now Sat.

SRO A6 D 1 U No marked up key provided- Unsat because it is too easy with no actions needed to be taken.

When you give an applicant a JPM on the NRC exam they dont usually expect to find that everything is good and it doesnt allow them to demonstrate much either. This is discussed a little bit in the NUREG but the goal is not to trick the applicant and this might appear to be a trick (at least to them when doing it) if they cant find anything. This leads to the JPM going long on time and frustration on the part of the applicant. I really think you need to give them one or two parameters out of spec that require them to enter the TRM or TS and alter the JPM accordingly. This also hits more of the SRO activities (ie entering the TS or TRM for chemistry issues). Also, as an applicant if I dont know what I am doing and I default to everything is good for this JPM then I pass.

The JPM needs to show more meat versus what you have-the JPM is good but one or two step JPMs are not allowed and this one is not really one step as you have written the JPM-the applicant has to take the data you give them, compare each parameter to a standard value, and if it exceeds it, then take action. So there are really several steps that need to be expanded in the JPM itself. I know this is an optics issue but we really need to break out the steps to show the parameters and their associated S standard value and then the actions taken when you modify the JPM.

Keys provided and other corrections made as recommended and JPM is now Sat.

SRO A7 D 3 U No marked up key provided-cant review this because I cant see how you got to your conclusions without a marked up key and more guidance in the JPM.

S Keys provided and JPM is now Sat.

SRO A8 D 3 S SRO A9 D 3 E No marked up key provided S Keys provided and JPM is now Sat. 0 Page 1 of 7 OBDI 202 - IOLE Process

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 2 of 7 OBDI 202 - IOLE Process

RB-2014-12 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 a (S1) D 3 E Step 13 should be marked as critical for completion of JPM and it is not as submitted. No validation time was entered for the JPM either.

S Corrections made and JPM is now Sat.

b (S2) D 3 E Based on the task standard and actions in the JPM steps 11 and 12 should be marked as critical for completion of JPM and they are not as submitted.

S Corrections made and JPM is now Sat.

c (S3) D 1 X U A two-step JPM is not acceptable for the NRC exam. Suggest using a turbine stop/control valve surveillance JPM. They are looking in the bank to verify it has not been used but do S not believe it is on the audit or the last two NRC exams.

New JPM and it is now Sat.

d (S4) D 3 X E Missed step 5.6.11.3 to close valve E12-F037B in JPM. Also, need to add words to the JPM step 4 notes and standard to state that when amps are reduced to 91 amps or slightly below that then the JPM step is met. Question: Does the 91 amps correspond to roughly 4500 gpm as you mention in the notes? If not, need to ensure those items are matched for S amps at or below 91 amps.

Corrections made and JPM is now Sat.

e (S5) D 3 E JPM step 11 and 12 are the same step, copy paste error. The two steps in the procedure are for suction with outside air (step 4.1.3.2) and with recirc air (step 4.1.3.1) of procedure SOP-0043, section 4.1. Also, step 12 was marked as critical and it is not since it is a verify step and the damper is already open -one damper not two as indicated in the JPM).

S Corrections made and JPM is now Sat.

f (S6) D 3 E Need validation time on this one.

S Done and is now Sat.

g (C1) D 3 S h (C2) D 3 E Typo on page 5 of JPM, step 2 in JPM (step 1.2 of procedure).or 3.1.6 Action A.1 should be there, not A!1.

Also, when you submit the JPMs, any marked up copies of things need to be submitted for the key, for the examiners during admin week, and also for the final ADAMS package upload. The procedure STP-500 is a marked up item that I do not have to review with the S JPM as well as the reactivity plan, which is also needed to follow along with the JPM.

All key items were submitted and the JPM is now Sat.

I (P1) S S j (P2) S S k (P3) S U Could not perform since the procedure aid inside the panel was missing when we tried to S validate it. Replaced with new JPM and it is now Sat. 0 Page 3 of 7 OBDI 202 - IOLE Process

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 7 OBDI 202 - IOLE Process

RB-2014-12 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 U General Comments for all four scenarios:

Did not use the NRC standard form for scenarios.

1) Critical tasks are required to be in the Expected operator actions column for the examiner of record to grade them. You have it in the column with role-playing from booth and at the end. The CTs need to be in big, bold letters so that they can easily be seen in the D-2 forms. I also sent RB the ANO scenario files during outline reviews that detailed the format that would meet the requirements and that had good critical tasks. I confirmed via Waterford scenario forms (D-1 and D-2 forms) that River Bend is an outlier. I also sent them Waterford D-1 and D-2 forms to demonstrate this difference.
2) There needs to be space, per NUREG-1021, for the examiner to take notes during the scenarios, and the time column needs to be blank with a space for the examiner to write in the time the action was taken.
3) Also, just putting in the D-2 that the ATC is expected to complete the actions of AOP-32 is not acceptable. Per the NUREG, all important verifiable actions for each event must be in the D-2 form for grading purposes.
4) You must have two TS calls in each scenario, where the SRO applicant is required to enter the LCO in order for us to be able to grade him/her appropriately to the grading criteria we have. Having only one TS call in the scenario means that the applicant could never fail the exam (assuming they were an Upgrade and they only performed the one scenario that was short a TS call).
5) The major alarms that are generated for each event need to be at the top of the event in the D-2 guide.
6) The ARP for the major alarms associated with the event need to be listed in the guide.
7) More major valve manipulations we need to have the noun name and the numerical name in the guide.
8) The event descriptions in the D-1 guide need to be replicated exactly in the D-2 guide for the corresponding event. Example, steam flow instrument fails downscale in the D-1 form and then having steam flow instrument failure in the D-2.
9) Scram actions needs to be in each scenario at the time of the Scram for each board operator.
10) All major ARP, AOP, and EOP actions need to be put into the guide. See #3 above.
11) When putting the numerical name for a procedure in the guide, use the noun name for it at least once in the applicable event/section of the D-2 form so that the examiner can follow along and it makes sense. We dont have the procedure numbers memorized so that association with the corresponding noun name can be made from memory.
12) Several events were re-characterized as TS only or removed from the exam (on all four scenarios) because there were no verifiable operator actions on the S boards in the control room as required by NUREG-1021. This was a problem on the previous scenarios earlier this year on the March exam but still seem to 0 Page 5 of 7 OBDI 202 - IOLE Process

RB-2014-12 DRAFT OPERATING TEST COMMENTS SCENARIOS be a problem on this exam.

All corrections necessary for the scenarios to meet the requirements were completed however the format is still wrong but the licensee ran out of time to correct the format issues so we agreed to use the incorrect format for this exam. The licensee was sent example scenarios with all the details needed for the ES-D1 and ES-D2 forms prior to outline submittal (ANO sample forms were sent since they are part of the Entergy fleet and should be the same format) and during draft exam submittal the Waterford ES-D1 and ES-D2 forms were sent from their last NRC exam and they still did not follow it due to time constraints and the number of repairs necessary to make the scenarios acceptable for administration.

2 U See comments above.

All corrections necessary for the scenarios to meet the requirements were completed however the format is still wrong but the licensee ran out of time to correct the format issues so we agreed to use the incorrect format for this exam. The licensee was sent example scenarios with all the details needed for the ES-D1 and ES-D2 forms prior to outline submittal (ANO sample forms were sent since they are part of the Entergy fleet S and should be the same format) and during draft exam submittal the Waterford ES-D1 and ES-D2 forms were sent from their last NRC exam and they still did not follow it due to time constraints and the number of repairs necessary to make the scenarios acceptable for administration.

3 U See comments above.

All corrections necessary for the scenarios to meet the requirements were completed however the format is still wrong but the licensee ran out of time to correct the format issues so we agreed to use the incorrect format for this exam. The licensee was sent example scenarios with all the details needed for the ES-D1 and ES-D2 forms prior to outline submittal (ANO sample forms were sent since they are part of the Entergy fleet S and should be the same format) and during draft exam submittal the Waterford ES-D1 and ES-D2 forms were sent from their last NRC exam and they still did not follow it due to time constraints and the number of repairs necessary to make the scenarios acceptable for administration.

4 U See comments above.

All corrections necessary for the scenarios to meet the requirements were completed however the format is still wrong but the licensee ran out of time to correct the format issues so we agreed to use the incorrect format for this exam. The licensee was sent example scenarios with all the details needed for the ES-D1 and ES-D2 forms prior to S outline submittal (ANO sample forms were sent since they are part of the Entergy fleet and should be the same format) and during draft exam submittal the Waterford ES-D1 and ES-D2 forms were sent from their last NRC exam and they still did not follow it due to time constraints and the number of repairs necessary to make the scenarios acceptable for administration.

Instructions for Completing Matrix 0 Page 6 of 7 OBDI 202 - IOLE Process

RB-2014-12 DRAFT OPERATING TEST COMMENTS SCENARIOS 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.

Based on all four scenarios being Unsat and 4 JPMs Unsat the overall Op test submittal was Unsat per ES-501 page 9 of NUREG-1021. 0 Page 7 of 7 OBDI 202 - IOLE Process

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