ML103400349

PV-2010-11-Draft Operating Test Comments

ML103400349
Person / Time
Site:	Palo Verde
Issue date:	11/05/2010
From:	Brian Larson Operations Branch IV
To:	Arizona Public Service Co
References
Download: ML103400349 (4)

Text

Attachment 10 Page 1 of 4 OBDI 202 - IOLE Process PV - 2010 - 11 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 4 E Step 8.2.1 is marked as Critical but does not appear to be so. Applicant is not required to actually calculate anything in this step. Applicant must determine that this is initial Shutdown Margin, but could make this assumption and successfully complete the task standard.

Fixed RO (A2) S 3 E Step 1 determines Regulating Group time which is necessary in the Step 2 calculation. Step 1 should be marked as Critical.

Fixed Step 4 determines the EFPD for Full Strength CEAs and is required information on the data sheet.

Step should be marked Critical.

Fixed Step 9 determines the EFPD for Part Strength CEAs and is required information on the data sheet.

Step should be marked Critical. Fixed RO (A3) S 3 S RO (A4) S 2 E Initiating Cue as given to the Applicant - Replace "You have been tasked with entering-" to "The CRS directs you to enter-" Fixed SRO (A5) S 2 E Cue Sheet indicates total number of errors in the Shutdown Margin Calculation that the Applicant must find. This is contrary to the actual Control Room setting where the SRO will have to review information without knowledge of errors or number of errors.

Remove total error count from Cue Sheet and also change Applicant Handout so that the number of erro rs is not indicated by spaces available. Fixed SRO (A6) S 3 E Step 1 - Evaluate Technical Specifications for all Units. This step is Critical for this JPM and should be noted as such. Fixed SRO (A7) S 3 E Cue Sheet has small table to enter required LCOs and Limits. Replace table format with something else that does not indicate to the Applicant the possible number of correct answers. Fixed SRO (A8) S 2 S SRO (A9) S 3 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.

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.

Attachment 10 Page 2 of 4 OBDI 202 - IOLE Process 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 4 OBDI 202 - IOLE Process SITE - YEAR - MONTH 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 (Bank)(Alt-Path) JPM step 6 is not critical. Fixed S3 D 3 S (New)(Alt-Path)

S4 D 3 S (Bank) S5 D 3 S (Bank)(Previous)(Alt-Path)

S6 D 2 S (Bank) S7 D 3 S (New) S8 D 3 S (Bank)(Previous)

P1 D 3 S (Modified)(Alt-Path)

P2 D 3 S (New) P3 D 2 S (New)(Alt-Path?) Outline shows this JPM being alt-path, however the JPM is not written as alt-path. 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 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 4 of 4 OBDI 202 - IOLE Process SITE - YEAR - MONTH 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 "CO addresses the alarm response procedure for window 13 B-" - provide procedure number for this. (page 2) Fixed 2 E Event 1 (CH-UV-560 fails to close) does not count as malfuncti on as there is no required operator action to correct by the RO. Fixed 3 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 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 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.