ML23018A045

CNS-2022-11 Draft Operating Test Comments

ML23018A045
Person / Time
Site:	Cooper
Issue date:	11/22/2022
From:	Heather Gepford NRC/RGN-IV/DORS/OB
To:	Nebraska Public Power District (NPPD)
References
Download: ML23018A045 (1)

Text

Form 2.3-3 Operating Test Review Worksheet (JPMs)

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL Note: All validation comments are included at the end of this file and were incorporated into the operating test. These comments directly below are prior to validation week.

S1 S

N 3

S S2 S

Y 3

S S3 S

N 3

E S

Please add desired band of +10 to +40 inches into task standard because that is what we have to grade them on is restoring level to within this specific band.

Comments resolved and JPM is now Sat.

S4 S

Y 3

S S5 S

Y 3

E S

Please place stuck control rod in the task standard to be clear.

Comments resolved and JPM is now Sat.

S6 S

N 2

E I believe that the KA is incorrect for this JPM. The SDG at Cooper is not the Emergency class Diesel, correct? Is so then system 264000 is not the system being used. The correct system would probably be 262001 (AC DIst Sys) and the most likely KA is A2.12. This would require a change to the outline form and the JPM.

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL S7 S

Y 3

X E

S For step 9.3.2 is it acceptable for applicant to manually realign those components in train A (ie manual start of train A fan, manually open 546A valve, manually close AD-R-1A)? If so need to update JPM step 5 and also the task standard. If not, then we need to word the task standard accordingly.

Also, in the cue it states that another operator will align SBGT so is it possible that they could walk away from JPM at alt path and state that the other operator will align it per the cue? If so we need to fix this issue.

KA is incorrect. This is not cued from one instrument malfunction (A2.16) but an actual high radiation event (dropped fuel). I think you meant to use A2.17.

Comments resolved and JPM is now Sat.

S8 S

N 2

E S

Procedure link is broken in JPM step 1 and needs to be fixed.

Comments resolved and JPM is now Sat.

P1 P

N 2

E S

Wrong Safety Function. REC is system 400000 which you have listed correctly however the SF you have it listed as on the outline and the JPM as SF7 and it is SF8.

Please correct this.

Comments resolved and JPM is now Sat.

P2 P

N 2

E S

There are comments in the JPM right side (track changes is enabled) and someone else provided comments in the right margin.

Can we remove those so they dont go in Adams? Would like to have a before picture of the trip linkage before being reset in the JPM package.

Comments resolved and JPM is now Sat.

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL P3 P

N 2

U S

Step 2, 3, and 4 of JPM should not be critical since you expect B strainer to not be in service at beginning of JPM, correct?

Those would be verify steps that you would expect to be already closed when you got there, correct?

Comments resolved and JPM is now Sat.

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL A1 A

N/A X

U S

No key provided. I sent you back a copy of a key.

1.

First, you fill out the Att 1 for both TC-R-24 and TC-R-25, then you recognize the channel C is reading 250F (it is not displaying red on the screen so I am not sure if they would question it is high off-scale since it has not changed colors-does it flash or something or must they know that 250F is the limit of the scale?

2.

The applicant recognizes channel C is off-scale high on TC-R-24 at 250F and goes to step 3.2

3.

There is no substitute block for using RHR-TR-131 on Att 2 so I assume you just record this value of 90F in the block where it has sum/4 for all of them or at least one of them.

4.

You have the incorrect verbiage for the task standard, in that it states it is the Effluent - it is actually the influent temperature that is used per the procedure.

5.

There are no error bars for this JPM. It is exactly 90F with no error since you read the value straight off the recorder.

Please create a correct A1 key and fix the task standard (effluent vs influent) and eliminate the error bars for this JPM everywhere they are located.

Comments resolved and JPM is now Sat.

A2 A

N/A E

S You have a marginal key-I sent you back what the actual key should look like.

Comments resolved and JPM is now Sat.

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL A3 A

N/A S

A4 A

N/A E

S There are really no error bars in this calculation but they are small and insignificant and dont affect the outcome either way so that is fine. FYI-error bars are used when there is an interpolation required or a rounding issue.

You need a cleaner copy of the RCA map for the applicants. I could barely read the electronic one sent.

Comments resolved and JPM is now Sat.

A5 (SRO)

A N/A S

A6 A

N/A X

E S

The cue needs to state Record your conclusions on Page 3.and record TS requirements/LCO entries, if any.

Comments resolved and JPM is now Sat.

A7 A

N/A E

1.

Procedure links still broken in JPM (JPM steps 1 and 3).

2.

JPM step 2, it is only critical for one valves position, in this case 252, since this is the one we need to change the position on, correct?

3.

Key should state that the valve out of position is 252 and procedure step 0.9 is the tagout procedure on the key. You have it in the task standard but to be clear it should be in the key as well.

4.

Question, if a valve is a throttle valve, what does out of position actually mean here? Could the applicant challenge this?

Facility: CNS Exam Date: Nov 14, 2022 1

JPM # or title 2

Type (S/P/A) 3 ALT (Y/N) 4 LOD (1-5) 5 JPM Errors 6

U/E/S 7

Explanation LOD REF IC TSK CUE CS TL A8 A

N/A X

E S

You need to make it clear on the answer key that logging is critical step. You state on your key that if examinee (should be applicant by the way) lists KI in the log entry section of Att 2 and this is a critical step.

Really the key is Auth KI for EMT (critical)

Auth KI for RP (non-critical)

Log it (critical)

Need to update task standard for this as well.

Comments resolved and JPM is now Sat.

A9 A

N/A S

Form 2.3-3 Instructions for Completing the JPM Table

1. Enter the JPM number and/or title.

2. Enter the type of JPM(S)imulator, (P)lant, or (A)dministrative.

3. Enter (Y)es or (N)o for an Alternate Path JPM.

4. Rate the level of difficulty (LOD) of each JPM using a scale of 1-5 (easy-difficult). A JPM containing less than two critical steps, a JPM that tests solely for recall or memorization, or a JPM that involves directly looking up a single correct answer is likely LOD = 1 (too easy). Conversely, a JPM with over 30 steps or a JPM that takes more than 45 minutes to complete is likely LOD = 5 (too difficult).

5. Check the appropriate block for each JPM error type, using the following criteria:

LOD = 1 or 5 is unsatisfactory (U).

REF: The JPM lacks required references, tools, or procedures (U).

IC: The JPM initial conditions are missing or the JPM lacks an adequate initial cue (U).

CUE: The JPM lacks adequate evaluator cues to allow the applicant to complete the task, or the evaluator cues are subjective or leading (U).

TSK: The JPM lacks a task standard or lacks completion criteria for a task standard (U).

CS: The JPM contains errors in designating critical steps, or the JPM lacks an adequate performance standard for a critical step (U).

TL: The JPM validation times are unreasonable, or a time-critical JPM lacks a completion time (U).

6. Mark the JPM as unsatisfactory (U), satisfactory (S), or needs enhancements (E). A JPM is (U) if it has one or more (U) errors as determined in step 5. Examples of enhancements include formatting, spelling, or other minor changes.

7. Briefly describe any JPM determined to be unsatisfactory (U) or needing enhancement (E). Save initial review comments and detail subsequent comment resolution so that each exam-bound JPM is marked by a satisfactory (S) resolution on this form.

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility: CNS Scenario: 1 (100% EOL)

Exam Date: Nov 14, 2022 1

Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

Removed Scenario 1 from the scenario set since it was not needed due to class size.

2 3

4 5

6 7

8 9

10

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility:

Scenario: 2 (7.5% BOL)

Exam Date:

1 Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

S 2

X E

S You have action to bypass IRM A on page 22 but it is actually bypass C, correct?

Comments resolved and scenario is Sat.

3 S

4 S

5 S

6 S

7 S

8 S

9 S

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility:

Scenario: 3 (75% BOL)

Exam Date:

1 Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

S Comments removed since this is the spare scenario.

2 S

3 S

4 S

5 S

6 S

7 S

Form 2.3-3 Operating Test Review Worksheet (Scenarios)

Facility:

Scenario: 4 (100% BOL)

Exam Date:

1 Scenario Event ID/Name:

2 Scenario event errors 3

U/E/S 4

Explanation Realism/

Credibility Performance Standards Verifiable Actions Critical Task TS 1

S 2

S 3

S 4

S 5

S 6

S 7

S

Form 2.3-3 Instructions for Completing the Scenario Table

1. For each scenario, enter the scenario event names and descriptions.

2. Review the individual events contained in each scenario, and identify and mark event errors:

The scenario guide event description is not realistic/credibleunsatisfactory (U).

The scenario guide event description lacks adequate crew/operator performance standardsneeds enhancement (E).

The scenario guide event description lacks verifiable actions for a credited normal event, reactivity event instrument/component malfunction, or technical specification (TS) event (or a combination of these) (U).

The scenario guide event description incorrectly designates an event as a critical task (i.e., a noncritical task labeled as critical or a critical task labeled as noncritical). This includes critical tasks that do not meet the critical task criteria (i.e., the critical task does not have a measurable performance standard) (U).

The scenario guide event description incorrectly designates entry into TS actions when not required or does not designate entry into TS actions when required (U).

3. Based on the outcome in step 2, mark the scenario event as unsatisfactory (U), satisfactory (S), or needs enhancements (E). An event is (U) if it has one or more (U) errors as determined in step 2. Examples of enhancements include formatting, spelling, or other minor changes.

4. Briefly describe any scenario event determined to be unsatisfactory (U) or needing enhancement (E). Save initial review comments and detail subsequent comment resolution so that each exam-bound scenario event is marked by a satisfactory (S) resolution on this form.

NRC Prep Week Notes (Revised) 8-1-2022 Simulator JPMs S1 - no comments. The applicant would be allowed to review paperwork ahead of time.

S2 - Make step 3 a critical step. Override the turbine test switch. No review ahead of time due to using hard card.

S3 - line out flow on Step 5. Remove procedure steps 10.1 thru 10.3 and mark up procedure. Stop at step 10 and removed remaining steps. Change task standard and cue sheet. Applicant allowed to review ahead of time.

S4 - Ensure hard card is marked up. Update task standard. Add statement for needing keys for the RHR-MO-26A/B. Update validation time to 10 minutes. Add note on page 9 for DWSIL being met. Applicant would not review paperwork ahead of time.

S5 - Make each switch manipulation a critical step. Add pull sheet with control rod 10-11 on it. Change standard to only 1 attempt on each and then move to the next one to shorten time. Applicant would review paperwork ahead of time.

S6 - No comments. Applicant would review paperwork ahead of time.

S7 - Add examiner note to step 12 to stop JPM after SGT A is started. Applicant would review ahead of time.

S8 - No comments. Applicant would not review paperwork ahead of time.

Admin JPMs A2 - Get rid of check mark for answering yes for the 10.1 A3 - Make 11x 17 copies of each print and give as handouts instead of using electronic copies.

A4 - Change transition dose to 0mrem. Update cue sheet, calculations, and answer key.

A6 - Change flows on attachment 3 so they are in the curves. Update answer key with correct flows. Add condition B to LCO. Change key to N/A to verify RR pump running on page 2 of attachment 3.

A7 - If valves not listed have a second cue sheet asking which valves would be tagged out of normal configuration. Make this sheet green. Run the A7 last. Update schedule to reflect running last.

In Plant JPMs P1 - Stop JPM at step 14. Remove remaining steps.

P2 - No comments P3 - Typo on second step 4. Should be step 5.

Scenarios SC2 - Have a copy of 2.1.1 marked up and included in the handouts.

On page 24, added alarm tiles R-2/C-4 and R-2/D-4 with alarm R-2/E-4 On page 38, added steps from alarm 9-4-1/B-1 to restart RCIC On pages 47 and 49, added examiner note that specifies the SPDS screens that are used to display corrected fuel zone(CFZ) RPV level On page 46, added Critical Task SATISFACTORY criteria actions; deleted text defining why the task is critical (Safety significance). This information is found on pages 6 and 51.

On page 49, added Critical Task SATISFACTORY criteria actions; deleted text defining why the task is critical (Safety significance). This information is found on pages 8 and 51.

SC3 On page 23, add note to add LCO 3.6.4.1 condition A entry and exit.

On page 24, added box under CRS for entry into 5.1RAD and EOP-5A for alarm 9-3-1/A-9, Reactor Building High Rad.

On Page 25, added step for resetting HPCI Rad Monitor on Panel 9-11.

Change CT#1 to add crew manually closes EG2 or directs NLO to close EG2 locally. Ensure this is updated on all affected pages.

On page 28, add booth action to insert Remote Function DG09, if directed to closed EG2 locally.

On page 33, make trigger 7 an automatic trigger. This should happen 15 minutes after trigger 6 is put in.

Change description under booth action to reflect this and change schedule file.

On page 37, update CT#2 with the correct secondary temperature areas. 1st area to exceed MSOT is 903,931 TS-126A & C. 2nd area to exceed MSOT is SW quad with TS-99G/TS-105B. 3rd area to exceed MSOT is the NW quad with TS-99C.

SC4 On page 3, added information concerning new CT#2.

On page 22, added step for CRS entering EOP-3A for high torus water level.

On page 23, added examiner note to move on to event 4 five minutes after fuses are pulled for SRV-71D.

Add role play as NLO: If directed to check FW heaters, wait 3 minutes and report you see nothing wrong with FW controllers. Add role play as NLO: If sent to OWC, insert OW1 to acknowledge alarm.

On page 23, added Critical Task SATISFACTORY criteria actions; deleted text defining why the task is critical (Safety significance). This information is found on pages 7 and 40.

On page 27, added role play as NLO: If sent to OWC, insert OW1 to acknowledge alarm.

On page 28, added annunciator A-3/C-4 as third box under CREW at top of page.

On page 29, added MSIV closure/Group 1 on low condenser vacuum under CRS box at bottom of page.

On page 30, added Critical Task SATISFACTORY criteria actions; deleted text defining why the task is critical (Safety significance). This information is found on pages 8 and 40.

On page 34 added booth action: When directed to manually open RHR-MO-26A/B, insert remote function RH19A/RH20A to de-energize.

On page 36, added Critical Task SATISFACTORY criteria actions; deleted text defining why the task is critical (Safety significance). This information is found on pages 9 and 40.