ML15148A375

2015-04 Draft Operating Test Comments

ML15148A375
Person / Time
Site:	Palo Verde
Issue date:	04/13/2015
From:	Vincent Gaddy Operations Branch IV
To:	Arizona Public Service Co
References
50-528/15-04, 50-529/15-04, 50-530/15-04
Download: ML15148A375 (6)

Text

{{#Wiki_filter:Attachment 10 Page 1 of 6 OBDI 202 - IOLE Process PV - 2015 - 04 DRAFT OPERATING TEST COMMENTS ADMIN JPMS JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia RO (A1) S 2 E

S This appears to have three critical steps vice two. Also, to preclude answering anything other than a 'Yes' answer on "Are you current in Training?", I would add "as of today" and give the date. I don't want two possible answers. Same thing on number 3.

Fixed RO (A2) S 4 S Editorial: Please provide an ANSWER KEY to show how the calculation is accomplished. This will help with any necessary follow-up questions.

Will add answer key.

Fixed. RO (A3) S 3 S Editorial: Please provide the system diagrams with appropriate break ers/valves high-lighted as an answer key.

Will add and highlight.

Fixed. RO (A4) S 2 S SRO (A5) S 3 S SRO (A6) S 3 S Editorial: Line C9 in the procedure indicates 30.5 not 31.3 as given in the ANSWER KEY. Please provide ANSWER KEY that is the correct version for Appendix C. Fixed SRO (A7) S 3 E

S Task Standard states that "four errors" should be found. Error #3 is marked as non-critical. So either Error #3 should be critical or Task Standard should be reduced to "three errors". Let's discuss why Error #3 is not critical.

Error 3 is critical. Will look at rewording the Task Standard about Not meeting Acceptance Criteria. Will ask Ops if not catching redundant train error on page is important. It is not necessary to determine acceptance criteria.

Fixed SRO (A8) S 3 S SRO (A9) S 3 S Editorial: This is a Time Critical JPM but is marked "No" under "JPM Type" on the cover sheet. Please correct and give the time allowed as 15 minutes.

Fixed 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 Attachment 10 Page 2 of 6 OBDI 202 - IOLE Process reviewing operating tests. Additional information on these areas may be found in Exam ination 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 reconf iguration 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 fo r 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 c ues 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 wr itten examination. 4. Check the appropriate box when a job content error is identified: Topics not linked to job content (e.g., di sguised 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)na cceptable (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. Attachment 10 Page 3 of 6 OBDI 202 - IOLE Process PV - 2015 - 04 DRAFT OPERATING TEST COMMENTS CONTROL ROOM/IN-PLANT SYSTEMS JPMS JPM# 1. Dyn (D/S) 2. LOD (1-5) 3. Attributes

4. Job Content Errors 5. U/E/S 6. Explanation (See below for instructions)

IC Focus Cues Critical Steps Scope (N/B) Over- lap Job-Link Minutia S1 D 2 S S2 D 3 S S3 D 3 S S4 D 3 E

S Step 1 appears to be critical. Unlock breaker PHA-M3516. Step 3 appears to be critical. Unlock breaker PHA-M3517.

Step 5 appears to be critical. Unlock breaker PHB-M3622.

Step 7 appears to be critical. Unlock breaker PHB-M3623. (The above steps would be critical since you could not complete the Task Standard without someone unlocking the breakers.)

Step 9 would NOT be critical if CPN-HY-006A(B) already open. This is correct per facility. Steps 1, 3, 5 and 7 ARE critical.

Fixed S5 D 3 S S6 D 3 S S7 D 2 S S8 D 3 E

S How long does it take for the BAM alarm to co me in on Step 20 after the completion of Step 19? Five minutes?

Is it necessary to wait five minutes on Step 22?

No, but there is a delay. Will see how it validates. JPM Replaced - JPM ends on Step 7 with tripping the reactor. Why does the JPM continue to step 19?

Fixed. Now Sat S9 D 3 S P1 S 4 S P2 S 3 S P3 S 4 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 Exam ination Good Practices Appendix D. Check or mark any item(s) requiring comment and explain the issue in the space provided. Attachment 10 Page 4 of 6 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 reconf iguration 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 fo r 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 c ues 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 wr itten examination. 4. Check the appropriate box when a job content error is identified: Topics not linked to job content (e.g., di sguised 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)na cceptable (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. Attachment 10 Page 5 of 6 OBDI 202 - IOLE Process PV - 2015 - 04 DRAFT OPERATING TEST COMMENTS SCENARIOS Scenario Set 1. ES 2. TS 3. Crit 4. IC 5. Pred 6. TL 7. L/C 8. Eff 9. U/E/S 10. Explanation (See below for instructions) 1 E

S E9 - The CT is to establish feed to at least one S/G prior to "dryout". Is this the 0% WR level? Please define.

Will come up with good definition.

This scenario contains FR.

100% power

Generic comment for all D-1s: Please put procedure number and title into each event.

Question - Greyed out areas of D-2 are acti ons that are N/A or are expected to not occur? Yes. Fixed 2 E

S Attributes Table: Appears there ar e 6 total malfunctions and not 7.

Event 6 has two failures.

Examiners will need clarific ation on determining if A ppendix 2 limits have been exceeded for the CT involving Aux Feed.

Will give definition/parameters for this CT.

100% power

Fixed 3 E

S 100% power Comment 65 and 66 says "potentially" for LCO 3.4.9 - Please confirm that we will ABSOLUTELY be in this LCO or this scenario would be unsat.

Event that was previously deleted during validation has been reinstated. Two guaranteed TS calls with potential for third. Scenario is now Sat. 4 S 50% power

Blackout scenario 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 Ex amination Good Practices Appendix D. Check or mark any item(s) requiring Attachment 10 Page 6 of 6 OBDI 202 - IOLE Process PV - 2015 - 04 DRAFT OPERATING TEST COMMENTS SCENARIOS comment and explain the iss ue 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 scen ario events and actions. 5. Pred: Scenario sequence and other factors avoid predictability issues. 6. TL: Time line constructed, including ev ent and process triggered conditions, such t hat scenario can run without routine exam iner 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 sim ilar 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 interact ions. 9. Based on the reviewer

=s judgment, rate the scenario set as (U)nacceptable (requiring r epair 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.}}