ML11262A186

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AN1-2011-08 Draft Operating Test Comments
ML11262A186
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 08/26/2011
From:
NRC Region 4
To:
Entergy Operations
References
50-313/11-008
Download: ML11262A186 (7)
v • d • e


Text

AN1-2011-08 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 3 E During validation, need to discuss how examiner cues are given to applicant without S distracting/cueing the others.

Modify the task standard to state that the task is completed per procedure XXXX.

Made changes to the cues. Procedure reference added. Satisfactory.

RO (A2) S 1 U Same comment about referencing the controlling procedure in the task standard.

S Reviewing the referenced procedure (1105.010), it is assumed that these actions are covered in Step 7.6, because this is the closest to describing what the applicant is doing.

The statements in the procedure dont match with the steps stated in the JPM. This needs to be reviewed/resolved.

During validation, it was verified that there was no procedure reference for this JPM task.

It was replaced with a new JPM, and it was validated as satisfactory.

RO (A3) S 2 X U By cueing the applicant that there are 2 errors, you are giving him/her the completion S criteria for the JPM. Change to say identify any errors with the tagout.

The standard for correctness of tagouts is 100% correct. Is the expectation that an RO assigned to do the review of a tagout before hanging the tag picks up and corrects only 50% of the errors? Implementing tagouts with 50% correctness, can get people hurt/killed.

The JPM needs to be written so that the applicant has to identify all errors with the tagout to satisfactorily meet the task standard.

Changes were made to require all critical steps identified to be completed. JPM is satisfactory.

Also, the tagout says that it is in on a high energy system with single valve isolation. Per procedure, are there any compensatory measures that have to be approved to do this?

This is addressed in the Hazards section of the tagout IAW their procedure, per their review. No change needed based on this comment.

RO (A4) S 3 X S SRO (A5) S 2 X X U (SRO A1)

S For a procedure deviation, it is not expected that the deviation review form annotates which step(s) are being deviated from? It shows that procedure 1102.002 is being deviated from. In its entirety?

Based on the deviation form provided for the applicant, it should not be initialed as approved. Section B, Question 3 has not been answered. 0 Page 1 of 7 OBDI 202 - IOLE Process

AN1-2011-08 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 There is no required note at Step 17.11.3 in the procedure to denote that it was deviated from?

As it is written, it shouldnt be signed for approval. If this is written so that all the applicant needs to do is sign the form, it has very little discriminatory value. This needs to be revised.

The licensee changed the draft during development in between a task to review the deviation form versus preparing it. Therefore, the JPM submitted was in error. Revised to require applicant to perform the procedure steps and fill in the form. Satisfactory.

UPDATE: During exam administration, it was communicated to the exam team that a recent corporate procedure change invalidated the content of this JPM. The JPM was taken out of the exam; a new one was developed, validated with an SRO, and revised to address comments provided by the chief examiner. The new JPM was administered to the SRO applicants. The outlines and final operating test content will reflect this change.

SRO (A6) S 3 X U To have a critical step that says provide what corrective action that should be taken with S a list of possible answers that is not all inclusive does not provide clear grading criteria to establish if he/she satisfies this step. There needs to be clear grading criteria based on what the sites expectation is for the operators. There should be a minimum set of corrective actions that you expect them to take.

The applicant needs to document what corrective actions he/she would recommend.

Providing verbal responses is not conducive to the exam grading process.

The abnormal trend in pump differential pressure is based on surveillance data on 7/7/10, 1/25/11, and 7/5/11. In the other provided graphs (various bearing vibration data, etc.),

there are no data points for the 7/05/11 surveillance. This would be a comment that the test data is incomplete for review. All of the data needs to be provided.

The expectations are being defined based on review with operations staff. The incomplete testing data was added in, so as to not add an additional task that the SRO would be expected to address in the JPM. The expectations for the critical steps were determined and added in. Satisfactory.

SRO (A7) S 2 X U Same comments as in A3 above.

S Revised similar to A3 above. Satisfactory.

SRO (A8) S 3 S SRO (A9) S 3 E The initiating conditions state that the applicant is the Emergency Director (i.e., Shift S Manager with no one relieving him/her yet). Prior to the EOF staff taking Emergency Director responsibility, there is typically a turnover of that role to the TSC Director. This should be addressed somehow in the initial conditions. 0 Page 2 of 7 OBDI 202 - IOLE Process

AN1-2011-08 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 Has the minimum GE PAR been made, per the Discussion section in Attachment 6?

When the GE is declared, there is a minimum PAR that is made prior to follow on PARs developed based on dose assessment. If the desire is to have the applicant exercise the use of the flow chart to determine affected EPZ areas that have specific PARs, then this topic should be addressed in the initial conditions.

Changes made to address comments. Satisfactory.

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 3 of 7 OBDI 202 - IOLE Process

AN1-2011-08 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 E If the task standard is that the applicant completes the steps of the AOP attachment, as S stated, then all of the steps have to be critical steps.

Revised, JPM satisfactory.

S2 D 1 X N U The only action that the applicant really takes for evaluation is whether he/she depresses S the test switch to Reset the system. This is a simple one-step JPM, which is not appropriate. This is more of an issue when you consider using this as one of the JPMs to evaluate where licensed ROs can get SRO licenses. The JPM should have meaningful performance requirements that will provide a legitimate basis for evaluating the examinees ability to safely operate the system or the plant. See NUREG-1021, Appendix C, Section B.3.

JPM replaced and new JPM validated. Satisfactory.

S3 D 3 X U The alternate path actions described in the JPM are not denoted in the plant procedure.

S There is no mention of the critical parameter of decrease in Makeup Tank level by 5 inches in the procedure. What is the basis for this being a critical step?

The plants expectation for how to address abnormal operations in this situation need to be proceduralized. Because they arent, how can we be sure that the critical steps as stated are the correct actions?

JPM replaced and new JPM validated. Satisfactory.

S4 D 2 X E The specifics of how to transfer D11 to its emergency power supply are not spelled out in S procedure 1003.036, Step 3.1. There is more detail on the switch name and needed switch position in the JPM than in the procedure.

Actions addressed in procedure 1203.036. JPM satisfactory.

S5 D 3 E Put in a cue for Step 6 that 5 minutes has elapsed at 20 kW.

S Is it acceptable to interpolate a curve for 92F on Attachment B, or is it site expectation that the applicant uses the given 90F curve?

The 5 minute cue will be added to the exam. Use of Attachment B curves discussed, no issue.

S6 D 3 X E Recommend cueing the applicant to respond to any alarms, vice telling them which alarm S is in and where to focus.

Is there a reason why initial power is not greater than 40%? It would require additional action demonstrating abilities with ICS controls.

Revisions made. Satisfactory.

S7 D 3 E Step 67.F in the procedure does not state the EFW valves operated to complete that step.

S Other steps in the procedure state the valve ID numbers.

Noted as a procedure improvement. Content of JPM - leave as is. 0 Page 4 of 7 OBDI 202 - IOLE Process

AN1-2011-08 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 S8 D 3 S P1 D 1 N U The only action taken by the operator is to demonstrate closing and opening the same S valve. This is not a discriminating task. The JPM should have meaningful performance requirements that will provide a legitimate basis for evaluating the examinees ability to safely operate the system or the plant. See NUREG-1021, Appendix C, Section B.3.

Altered the scope of the JPM. Validated JPM is satisfactory.

P2 D 3 S P3 D 1 X X U The JPM involves no actual tasks performed. All steps are verification of equipment in its S correct position and the examiner telling the applicant that a tag is missing. This isnt even a simple one-step JPM, which is inappropriate in itself. The JPM should have meaningful performance requirements that will provide a legitimate basis for evaluating the examinees ability to safely operate the system or the plant. See NUREG-1021, Appendix C, Section B.3.

A new JPM was written with multiple manipulations in different plant locations. Validated, JPM is satisfactory.

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 5 of 7 OBDI 202 - IOLE Process

AN1-2011-08 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 E The Tech Spec Action Statements that are required for entry are not stated/explained in S the D-1/2.

The Critical Tasks are not explained, why they are critical, what key parameters are measured to determine if the Critical Tasks are met or not.

In Event 7, it says that they meet HPI throttling criteria. According to RT-10, RCS pressure has to be greater than 600 psig, and this isnt stated.

Changes made. Scenario is satisfactory.

2 X X E 1) Event 3 is the same subject matter as SRO Admin JPM A1 (A1JPM-SRO-S PROC2).

2) The Tech Specs for Events 7 and 8 are not stated in the D-2. Also, the first Tech Spec call is in Event 4, but theD-1 says Event 5.
3) Similar to scenario 1, there is no explanation of the evaluation criteria for the critical tasks - what tasks are critical - when they have to be completed by based on plant parameters to be satisfactory?

Will coordinate schedule to have Admin JPM A1 completed same day as scenario.

Changes to content made. Scenario is satisfactory.

3 X E 1) Event 2/3: If the Heater Drain Pump trips before the downpower to 70%, what S will be the effect on the rest of the scenario?

2) Same comment on definition of Critical Tasks.
3) Tech Specs, denoted as being in Events 5 and 7 in the D-1, are not mentioned in the D-2.

Changes made. Scenario is satisfactory.

(Overall comment) There are no indicated tasks in the exam which are time critical (except 2 minute RCP trip on loss of SCM) or obviously tied to plant operating experience. It is expected that an evaluation of dominant accident sequences in the plants PRA will be used to find risk-important operator actions for the exam material.

See NUREG-1021, ES-301, Section D.1.f.

Changes resulted in an Admin JPM being added dealing with reset of CET alarm setpoints, which has been an issue onsite.

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. 0 Page 6 of 7 OBDI 202 - IOLE Process

AN1-2011-08 DRAFT OPERATING TEST COMMENTS SCENARIOS

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. 0 Page 7 of 7 OBDI 202 - IOLE Process
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