ML040130727

NRC Comments on the Operating Test for the Monticello Initial Examination - Sept 2003

ML040130727
Person / Time
Site:	Monticello
Issue date:	09/23/2003
From:	Lanksbury R NRC/RGN-III/DRS/OLB
To:
References
50-263/03-301 50-263/03-301
Download: ML040130727 (9)

Text

Monticello ADMIN JPMs - Ensure JPM title is not printed on applicant cue sheets LEVEL K/A S/U COMMENTS RO /

SRO A.1.a Perform Core Thermal Limits Monitoring S

U S

Direct conflict with written question 127-B. {see 1021 ES-301 page 8 of 26 item h.}

Resolution: Replaced written question 127-B. Plus added the following enhancements: 1) Perform JPM in plant and require the applicant to acquire a 3D Monicore printout {critical step}. 2) Change exam copy of 3D Monicore printout to properly reflect problem at position 13-32 on core location section of printout.

RO A.1.b Independent Verification S

E S

Enhancements noted during validation: 1) on page 4 / 11 General References update Procedure 0255-06-IA-1 from Rev 61 to Rev 63 2) throughout JPM Standards state applicant observes component in correct position with correct indicating lamp illuminated and remove wording about other indicating lamps. 3) change step 15 to critical with the following standard wording 1. Observes the Flow Controller mode selector switch is positioned to BAL 2. Observes the Flow Controller tape set is at 87%. 4) On JPM step 5, first out of position component, applicant should make a comment in comment section and will not initial this step {may star step & may make comment when of procedure completed}. 5) JPM Step 15, change Flow Controller position from Auto to BAL {out of position} and make the step critical {ensure simulator setup is changed to reflect this new out of position component}

Resolution: All enhancements incorporated satisfactorily.

SRO A.1.b Crew Staffing Determination S

U S

Significant changes required due to deficiencies noted during validation:

1) Need to modify JPM to force critical steps, modify watch stations to cover post with available personnel. 2) Remove Casperson and Voisin from qualified Fire brigade members 3) Step 1, add examiner note that Staffing Report is on applicant turnover sheet.

Resolution: All changes incorporated satisfactorily.

RO /

SRO A.2 Off-Gas Hydrogen Analyzer Checks S

E Enhancements noted during validation: 1) Change Cover Page to reflect JPM performed in Simulator. 2) JPM Step 2, provide an additional Examiner Cue to applicant that SPDS and process not available to obtain hydrogen readings, must use recorders. 3) JPM Step 2, item 2 of Standard change report of rota meter reading to 65 CCM and bypass flow to 2200 CCM. 4) JPM Step 6, ensure Train B Analyzer Y is not rezeroed thus out of spec, make step critical, change step standard and simulator setup. 5) JPM Step 7 becomes critical 6) Step 8, for Train A OOS channel, fail it high. 7) add a step to JPM -

Standard is for applicant to annotate problems encountered in procedure comment section.

Resolution: All enhancements incorporated satisfactorily.

SRO A.3 Authorization for Emergency Exposure Control S

E Neither the Initial Conditions nor the Initiating Cue define the applicants official on-shift position for the event while expecting him to Authorize Emergency Exposure with the TSC not manned and the Shift Manager incapacitated.

Resolution: Add You are the CRS to initiating Cue. Enhancements noted during validation: 1) Add CRD pump room at 20 R/Hr to INITIAL CONDITIONS. 2) Make step 3 critical for part 2 of standard.

Resolution: All enhancements incorporated satisfactorily.

RO A.3 Expected Dose Determination to Inspect Equipment S

E Enhancements noted during validation: 1) Initiating Cue, give annual exposure before stating expectation, add cue obtain required permission to make the inspection. 2) Step 4 Change standard to state Determines maximum total... change 750 to 800 and 2500 to 2550.

Resolution: All enhancements incorporated satisfactorily.

SRO A.4 Authorization for Potassium Iodide use S

U S

Significant changes required due to deficiencies noted during validation:

{JPM unsat due to major re-write because of procedure conflicts and implementation of the required procedures to make the task work.} 1) Provide Control Room surveys in Initial Conditions and state that the site has not been evacuated. Ensure statement info that TSC is not manned is clearly stated. 2)

Change the second bullet of the Initiating Cue to state Determine what additional actions should be taken for the personnel on site.

Final Sumbital was not acceptable as written - Notification form to be given to applicant contained information that the thyroid dose was >30 rem.

Resolution: All changes incorporated satisfactorily.

RO A.4 Response to a large Diesel Fuel Spill S

E Enhancements noted during validation: 1) JPM to be performed in a classroom setting.

MONTICELLO - Control Room Systems and Facility Walk-Through JPMs - Generic Comments: 1) Ensure JPM title is not printed on applicant cue sheets 2) Place Evaluator Notes

& Cues after Performance Step but before Standard 3) Did not identify if BANK, NEW or MODIFIED K/A S/U COMMENTS B.1.a Inadvertent Control Rod Insertion Alternate Path 201003 A3.01 E

Enhancements noted during validation: 1) on page 3 / 11 under SIMULATOR SETUP add statement to ensure that control rod 30-19 is not selected. 2) on page 4 / 11 General References update Procedure 0074 from Rev 31 to Rev 42 3) page 5 of 10 Add Evaluator Caution Simulator does not respond as the plant for control rod movements, RMCS switch in simulator must be held till insert lamp illuminates before being released.

B.1.b Reject Water from Rx Vessel Using RWCU to Radwaste 204000 A1.07 E

Enhancements: 1) Make step 4 critical 2) Step 9, add evaluator cue that Level control will be turned over to another operator when applicant is ready to monitor RPV level.

3) Change task standard to reflect not monitoring level B.1.c MSIV Exercise Test Alternate Path 239001 A4.01 U

S Same K/A as Audit Exam B.1.c and similar task.

Resolution: Replaced JPM with SRV testing per procedure 0112 Safety Relief Valves Operability Check, 2nd valve tested fails open requiring operator to take actions of procedure C.4-B.03.03A. Success path in C.4-B.03.03A is to bypass the Low-Low Set Logic.

B.1.d Flush No 11 Core Spray Loop 209001 A4.05 E

Enhancements noted during validation: 1) Add statement in Initial Conditions, Steam Line plugs installed. 2) Step 2, include an Examiner Cue to inform applicant that all Precautions, Limitations and Prerequisites are satisfied 3) Step 10 add note that PI 48A is x10.

B.1.e Reset a Group II Isolation 223002 A4.03 E

Enhancements noted during validation: 1) Step 4, add annunciator C04-B-3 clears 2)

Step 6, add action for simulator operator to clear CAM alarm.

B.1.f Restore Bus 15 From Bus 13 262001 A2.07 E

Change Task Standard to include restoration of loads. Enhancements noted during validation: 1) Step 10, Make step critical, have to close ACB 152-509 B.1.g IRM Functional 215003 A4.07 E

Enhancements noted during validation: 1) Change validated time from 20 to 15 minutes. 2) Ensure simulator setup has scrams reset so applicant can take Mode Switch to Startup or Refuel.

K/A S/U COMMENTS B.2.a Depressurize the Scram Air Header Alternate Path 295037 EA1.03 E

Make Step 1, find keys critical {located in work execution office}.

Enhancements noted during validation: 1) Step 3, Add red lamp lit to cue. 2) Step 4, Add lights as seen to cue.

B.2.b Startup the RPS Motor Generators 212000 K1.04 S

B.2.c Manual Initiation of the EFT Emergency High Rad Mode Alternate Path 288000 A2.04 E

Step 2, list annunciator titles. Clarify Steps 8, 9, 10, 11, 12, 13, & 14 that placing HS is critical not the determine portion of step.

Enhancements noted during validation: 1) Step 4, Add 3rd floor HVAC to Admin Bldg in Evaluator Cue 2. 2) Step 10 is not critical, not interlocked with V-AC-11 3) Step 11 add applicant calls control room 4) Steps 12 & 13 only part 2 of standard is critical. 5) Step 14 is not critical due to interlocked 6) Step 15, make this step critical, V-AC-14 would continue to bring in outside air if left running

MONTICELLO - Simulator Scenario 03-01 - Scenario event development was not consistent with the event numbering presented in the outline {Form ES D-1}, events beginning with the Major event were combined. Difficult to follow operator action and sequence progression within the scenario.

Initial Conditions: Rx S/U in-progress at approx. 13% power, raise power then prepare to & roll turbine. Equipment Out of Service: B RWCU Pump & APRM Channel #5 Event #

Type Comments 1

RO (R)

U S

Event requires rod withdrawal to achieve 11/2 Bypass Valves, applicant monitors RMCS lights during withdrawal, see written question 002-B.

Resolution - Replacing question 002-B for other reasons. Enhancements: 1) add information to scenario on location of instrumentation to verify 11/2 Bypass Valves 2) Pull an additional rod prior to crew assuming watch.

2 RO (I)

U S

RWM Equipment Failure - Appears to be one button event, may not provide minimum operator performance observation to base license decision. During validation this event did not run as originally written, as written required giving the crew a completed Form 2169 which removed significant operator actions, analysis and diagnostics.

Resolution - Scenario Changes: 1) Trigger Event #2 when operator selects second rod to be withdrawn. 2) Delete Phone Talker/NE statement to direct crew to bypass RWM. 3) Do not provide the crew with a completed Form 2169. 4) Add bullets under SRO and RO actions {as appropriate}

for TS 3.3.B.3.b specific criteria and Form 2169 required actions. 5) Provide required action bullets for performance of procedure B.05.02-05.G.2 6) Provide a note to explain RWM error message and prompt to phone talker to not make decision for crew if confused by this error message, also include bullet to cover crew actions if they decide a procedure change is required to continue {due to the error message}. Crew should follow through as directed by procedure 3

BOP (N)

S Roll Turbine. Enhancements: 1) Delete references to actions that would occur at >200 rpm 4

BOP (C)

U S

Press Reg Oscillations (MPR), malf inserted on roll-up at 500 rpm. Receive 2 computer alarms, visual = lights cycling, plus parameter oscillations and BPVs cycling, appears to be 2 manipulations to take control. May not provide minimum operator performance observation to base license decision.

Resolution - Validation provide insight to additional operator actions. Enhancements: 1) insert event #4 when turbine at 200 rpm while operator taking action to secure turning gear.

5 RO (C)

E S

1. 11 RBCCW Pump trip. One button event {start standby pump}, may not provide minimum operator performance observation to base license decision.

Resolution - acceptable if initiated while BOP operator engaged with responding to Event #4 such that RO has to respond. Scenario Changes: 1) insert event #5 while BOP operator engaged with responding to Event #4 such that RO has to respond. 2) add additional information on RWCU isolation {high potential} such as alarms, actions and limitations. 3) add information on RR alarms.

4) add information from procedure C.4-B.02.05.A on operator actions include criteria and potential to trip both RR pumps.

6 M BOP (C)

U E

IA Hdr failure. {This is part of the Major not a BOP (C), per 1021 - ES-301 4.d 3rd Par on page 16, adjust ES-301-6}

Resolution - Not counted as a BOP (C)

Enhancements: 1) break out events 6 - 9. 2) Add steps from C.4.K to SRO expected actions 3) delete SRO direction to run RR to min &/or note RR already at min. 4) add information for SRO to direct local control of low flow FRVs, include phone talker responses and RO/BOP procedural actions {as observed during validation}. 5) Add procedure titles to all references to EOPs 6) on page 3 of 6, during validation, SRO directed RO to maintain RPV level using RCIC not Cond/FW

{prescribed method in as submitted scenario}, add details to scenario for alternate methods allowed by procedure.

7 M

S Failure to Scram 61 west side rods suck. Success is for rods to insert following rupture of West Side SDV.

8 M

E Rupture of West Side SDV Enhancements ( for events 7, 8, & 9): 1) the scenario has operators dispatched to the reactor bldg to manually open SDV vent and drains, also has a rupture on the West Side SDV. Need to include additional information in scenario on rad conditions, phone talker responses, and expected crew responses {by position} to these conditions.

9 RO (C)

E 1 ADS fails to open on ED. Enhancement: 1) on page 2 of 3 {event 7} state RO opens a third SRV, restate as Opens an additional SRV

MONTICELLO - Simulator Scenario 03-02 - Scenario event development was not consistent with the event numbering presented in the outline {Form ES D-1}, events beginning with the Major event were combined. Difficult to follow operator action and sequence progression within the scenario.

Initial Conditions: Rx at 50% power following maintenance on #11 RFP. Place RFP I/S & return to 100% power. Equipment Out of Service: B RWCU Pump & APRM Channel #5 Event #

Type Comments 1

BOP (N)

E Place #11 RFP I/S. Enhancements: 1) page 3 of 3 warming valves should be 69-1 & 70-1 vs 69-2

& 70-2 2) computer points CFW524 & CFW525 do not work in simulator, need someone staged at to provide correct information, also will need a simulator problem report on performance of procedure B.06.05-05.D.7 on the simulator due to computer points CFW524 & CFW525 {write after administration of scenarios}. 3) Provide Phone Talker info from page 1 to crew during turnover.

2 RO (R)

E Raise reactor power with reactor recirc. flow. Scenario states SRO directs RO to raise power to 60%, however under RO expected actions scenario states raises power to 90%. Enhancements:

1) provided details of SRO review of B.06.01-06 Figure 13 and provide the expected rate change order {i.e. 5 MWe/min}.

3 RO (C)

E S

RR A speed control signal failure occuring as the RO adjusts RR speed. 1) RO observes change.

2) Depress SCOOP TUBE LOCK pushbutton. 3) SRO TS call. 1 button event, may not provide minimum operator performance observation to base license decision.

Resolution - during validation provided changes that resulted in sufficient observation of operator performance to base license decision. Scenario Changes: 1) Change order of scenario sequence such that this becomes event #4 and the RCIC event becomes #3. 2) Change event such that malfunction inserted after RCIC event and RO focused on other plant parameters. 3) Change NE phone talker response, NE can only solicit action from the SRO/crew and concur. 4) Add bullets in SRO actions on TS 3/4.6.G 4

BOP (C)

U E

RCIC Auto Initiation. One button event {trip RCIC}, may not provide minimum operator performance observation to base license decision.

Resolution - during validation provided scenario changes that resulted in sufficient observation of operator performance to base license decision. Scenario Changes: 1) prevent RCIC trip. 2) add crew actions to recognize, diagnose and correct. 3) add step(s) to CLOSE MO-2070, RCIC Turbine Steam Supply valve or MO-2080, RCIC Turbine Trip 4) make this event #3 5

BOP (C)

S Stator Cool pump trip w/ SB fail to start.

6 RO (I)

S RPV FWLC setpoint failure. During validation RO only placed 1 FW Reg valve in manual.

Enhancements: 1) revise scenario to reflect procedure direction and validated actions.

7 M

S LOOP - Scram - RPV Control - will ED due to RPV low level & no HP Injection.

E EDG 12 fail to start. Per scenario, all BOP does is call System Engineer to investigate and place CS in PTL. BOP does not inform SRO of EDG 12 status per scenario and SRO takes no action on EDG 12. Resolution - Response to failure of EDG 12 to start, 1) BOP/Crew dispatches a plant operator to evaluate the status of EDG 12 2) NLO will report back that there are no indications of problems and the diesel appears to be in a proper standby condition ready to start.

Enhancements: 1) Change page 8 of 11, expect operator to dispatch plant operator to investigate the status of EDG 12, operator will report back - are no indications of problems and the diesel appears to be in a proper standby condition ready to start. 2) Expected BOP attempt to start EDG 12 after receiving field report. 3) add for EDG 12 to trip after it ties to bus. 4) During validation crew could not restore CRD due to lack of cooling, ensure scenario covers this contingency and defines what was missed etc. 4) During validation crew determined they could not line up Demin water to SBLC, add explanation to scenario and indicate what was missed to cause this situation.

8 M

E HPCI SL Break in DW {uses small RR line break instead}. Break initiated when HPCI initiated for RPV level control. Enhancements: 1) After BOP completes electrical checklist for LOOP or at discretion of Chief ramp leak to 55% over 5 minutes, to speed up arrival at TAF for ED.

9 BOP (C)

E RCIC Trip As submitted scenario had RCIC trip on overspeed however during validation RCIC tripped on high exhaust pressure. Enhancements: 1) SRO should call for RCIC realignment and return to service. RO/BOP realign & start RCIC. After RCIC inject,s trip on high exhaust pressure.

On page 11/11 the critical step is to open 3 SRVs not verify

MONTICELLO - Combined parts of Scenarios 3 and 4 to produce one good scenario and an acceptable spare.

Scenario event development was not consistent with the event numbering presented in the outline {Form ES D-1}, events beginning with the Major event were combined. Difficult to follow operator action and sequence progression within the scenario.

Simulator Scenario 03 AS SUBMITTED - Rx at 14% power S/U I/P, Sync Gen to grid and continue power increase. Equipment Out of Service: B RWCU Pump & APRM Channel #5 Event #

Type Comments 1

BOP (N)

Sync Main Generator to Grid.

2 RO (R)

Increase power with rods.

3 BOP (C)

U

1. 11 Service Water Pump Trip. 1 button event, min operator performance to base license decision.

4 RO (C)

U Hotwell Lo Level. One button event, min operator performance to base license decision.

5 BOP (C)

SPE Blower Motor Hi Temp. Start K-3B, adjust outlet valve, stop K-3A & close outlet valve.

6 RO (I)

APRM #4 Upscale with failure of 1/2 of B channel RPS to trip.

7/8 M

Design Basis Earthquake.

BOP (C)

U Loss of Bus 13. BOP locks out breaker C/Ss but no impact or consequences if he doesnt do it.

Does not appear to provide the minimum operator performance to base license decision.

9 M

NB Reference Line Break - Loss of All Level Indication - OK {What if this event occurs prior to man scram, ie between Earthquake and Design Basis Earthquake} 1) Event 9 page 1/6 says SRO Enter EOP C.5-2006 - RPV Flooding at step 24" what is step 24? 2) Who verifies RPV >50#

during flooding & how determine flooded long enough. Termination criteria says check injecting with RPV press >50# above DW.

MONTICELLO - Simulator Scenario 03 AS VALIDATED, SPARE SCENARIO Rx at 14% power S/U I/P, Sync Gen to grid and continue power increase. Equipment Out of Service: B RWCU Pump & APRM Channel #5 Event #

Type Comments 1

BOP (N)

E Sync Main Generator to Grid. Enhancements: 1) Clarify note on page 2 of 5 about allowing more than one attempt to close generator breaker, if breaker does not close on second attempt applicant(s) should stop and investigate. Chief examiner will determine course of action. 2) During validation received annunciator on Generator Phase which was not expected, explain alarm and add response details to scenario 3) During validation received annunciator Generator Reactive Load when sync to grid add details for alarm response. 4) Why is MVAR adjusted after sync while loading rather than adjusting voltage before sync before.

2 RO (R)

Increase power with rods.

3 RO (C)

U S

1. 11 CRD Pump Trip One button event {start #12 CRD pump}, min operator performance to base license decision.

Resolution - during validation provided changes that resulted in sufficient observation of operator performance to base license decision. Scenario Changes: 1) Change malfunction from pump trip to oscillation of discharge/charging water pressure requiring diagnoses of conditions and decision to secure running pump and placing standby in service. 2) During validation, following the CRD pump trip and starting the standby, several CRD drift alarms were received resulting in the crew scramming the reactor. Validate the simulator response to the CRD pressure transients expected during this event and ensure the scenario documents the appropriate operator responses.

4 BOP (C)

SPE Blower Motor Hi Temp. Operator start K-3B, adjust outlet valve, stop K-3A & close outlet valve.

5/6 M

Design Basis Earthquake.

BOP (C)

S Loss of Bus 13.

7 M

U E

NB Reference Line Break - Loss of All Level Indication - Because this event required several enhancements to rectify difference between the as submitted and as validated versions, the as submitted event was judged as unsat. 1) Event 9 page 1/6 says SRO Enter EOP C.5-2006 - RPV Flooding at step 24" what is step 24? 2) Who verifies RPV >50# during flooding & how determine flooded long enough.

Scenario Changes: 1) page 21 of 26 and 23 of 26, add HPCI SL valves to be closed 2) page 21 of 26 where SRO orders to inject into RPV, during validation the crew overrode the RPV high level and used feedwater as a source, verify these actions with the procedure and ensure scenario contains the expected operator actions. 3) page 21 of 26 did not reach 2# in DW EOP entry on torus temp >90 F Re-verify simulator response to the event and ensure scenario documents the correct plant response and operator actions 4) page 23 of 26, can not have a verify step as a critical step change to RO/BOP reports injection. 5) On page 15 of 26, the RO is expected to place CV-6-13 {feedwater low flow valve} in auto, during validation this could not be achieved due to the reference leg failures, re-validate and ensure scenario documents the correct plant response and operator actions.

MONTICELLO - Combined parts of Scenarios 3 and 4 to produce one good scenario and an acceptable spare.

Simulator Scenario 03 AS SUBMITTED - Rx at 100% power. Equipment Out of Service: B RWCU Pump, APRM Channel #5, & HPCI is inop for performance of 0255-06-IA-1.

Event #

Type Comments 1

BOP(N)

Secure B RHR from Torus Cooling 2

RO (C)

U

1. 11 CRD Pump Trip One button event {start #12 CRD pump}.

3 RO (I)

U RBM Channel 8 Fail Upscale One button event {bypass #8 RBM}; min operator performance to base license decision.

4 BOP (C)

U

1. 12 Circ Water Pump Trip - Only action BOP takes is place #12 C/S in shutdown, what is consequence if BOP fails to do any of his actions. Less than one button event; min operator performance to base license decision.

5 RO (R)

Rapid Power Reduction give credit if RO take action per procedure to reduce power 6

BOP (C)

U Loss of Turb Brg Oil Press. BOP takes no action as a result of this malfunction, therefore no credit given for component failure.

7/8 M

Failure to scram & Failure of SLC. Scenario outline implies both trains SLC fail to start, however event description in scenario and critical steps show second train of SLC starting

MONTICELLO - Simulator Scenario 03 AS VALIDATED, EXAM SCENARIO - Scenario event development was not consistent with the event numbering presented in the outline {Form ES D-1},

events beginning with the Major event were combined. Difficult to follow operator action and sequence progression within the scenario.

Rx at 100% power. Equipment Out of Service: B RWCU Pump, APRM Channel #5, & HPCI is inop for performance of 0255-06-IA-1.

Event #

Type Comments 1

BOP(N)

S Secure B RHR from Torus Cooling 2

BOP (C)

U E

1. 11 Service Water Pump Trip.

Resolution - Validation provided insight to additional operator actions/diagnoses. Recognize fail to auto start & start #12 Service Water pump have to diagnose failure to auto start.

Enhancement: Add contingency for RO to perform RPR due to RR alarms on loss of Service Water {found during validation}, include crew ques {alarms} and expected actions per procedure for each position.

3 RO (I)

U S

APRM #4 Upscale with failure of 1/2 of B channel RPS to trip.

Resolution - Validation provided insight to additional operator actions/diagnoses. When used in Scenario #4 with APRM #5 already out of service and bypassed additional diagnostics and TS analysis required. Enhancement: Added specific TS details for inop APRMS {Scram & Rod Block} and include required actions.

4/5 U

S

1. 12 Circ Water Pump Trip - Only action BOP takes is place #12 C/S in shutdown, therefore no credit given for component failure. Less than one button event; min operator performance to base license decision.

Resolution - Will not count as BOP (C) direct lead into major without BOP action.

4/5 RO (R)

S Rapid Power Reduction {RPR} give credit if RO take action per procedure to reduce power 6

RO (C)

U S

Hotwell Lo Level. One button event {place LC-1093 Hotwell Reject Controller to man & control HW level}; min operator performance to base license decision.

Resolution - When changed to Scenario #4 at a higher power level plant and subsequent operatort action provided additional operator actions/diagnoses. Enhancement: Added contingency for RO to perform RPR due to RR alarms on loss of Service Water {found during validation}, include crew cues {alarms} and expected actions per procedure for each position.

7 U

S Loss of Turb Brg Oil Press. BOP (C), BOP takes no action as a result of this malfunction, therefore no credit given for component failure.

Resolution - Validation provided insight to additional operator actions/diagnoses sufficient to meet the standard.

8/9 M