ML040160705

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NRC Comments to the Operating Test for the Prairie Island Initial Examination - Sep 2003
ML040160705
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 09/08/2003
From: Cooper P
Nuclear Management Co
To:
NRC/RGN-III
References
50-282/03-301, 50-306/03-301
Download: ML040160705 (10)


Text

Prairie Island Operating Test Comments No. Source Comment Resolution

1. JPM A. VC-12SF-1 Minor editorial errors. Does not indicate Alternate Path on Corrected Emergency Borate Cover sheet. Cue states, Perform step 4 of FRS.1, when it should be FR-S.1. Step S-1, states ...shift runing BA pump to fast.
2. JPM B. SI-11S Page 4, Step 1&2 should be critical steps. Corrected Put a Train of Si in Recirculation Page 7, Step 3 note that the candidate may refer to the Corrected initial conditions instead of asking examiner if the bonnets are vented.

Page 8, Step 4 bold the evaluator note and make it a cue Corrected instead of a note.

3. JPM C. EO-30SF-1 There are no initial conditions established for the Initial Conditions included.

Respond to Stuck candidate.

Open Pzr Valve.

Edit initial conditions - Should read 1 through 5 instead of Corrected 1 through 7 Initiating cues to read perform E-0 starting at step 6. Corrected Put in terminating cue after E-0 step 8. Corrected Add appropriate E-0 steps to JPM. Corrected

Prairie Island Operating Test Comments

4. JPM D. EO-21SF-1 Outline states this is an alternate path JPM, the cover Edited Sat.

RCS Bleed and Feed sheet does not.

During Response To Loss of Secondary No alternate path is required to be taken. Incorrect RCS vents are opened Heat Sink With A which is an alternate path through PORV Failing To The JPM does not say which PORV does not open. I the RNO column.

Open. assume it is CV-31231 do to it not being a critical step.

Edited Sat.

Prairie Island Operating Test Comments

5. JPM E. ARS-1 There are no initial conditions established for the Edited Sat.

Place Standby Air candidate.

Ejector In Service Information in standard is not specific enough, e.g. Edited Sat.

Verifies low vacuum using available indication. Whats available?

The third performance step, standard steps b and c have Edited Sat.

confused the condenser vacuum breakers. The procedure says, verify proper circulating water flow for the power level, the standard states, verify the circulating water pumps running. Theres a difference.

The third performance step states, verify condenser Edited Sat.

crossover valve MV-32005 is open. The procedure says to do this only if a CW pump is lost. Has a pump been lost?

The fourth performance step has the candidate place the Edited Sat.

air ejector in service. This is not indicated as a critical step even though the JPM title is Place Standby Air Ejector In Service. The procedure has the operator place exhaust hood sprays and condenser spray system in service the JPM does not.

The only critical step in the JPM is to Trip the reactor. Putting air ejector in service is now What if the candidate is so slow that the reactor is a critical step.

required to be tripped before the air ejector is placed in service?

Page 8, Step 2, is not a critical step Corrected Page 8, Step 3, is a critical step Corrected Page 8, Step 3, standard shall discuss failure criteria at Corrected 3.5 inches Hg

Prairie Island Operating Test Comments

6. JPM F EO-29SF-1 The JPM had CV-31326 fail to close and the operator was Corrected Response to to take manual action. There was no procedural direction Containment for the operator to manually close CV-31326 upon the Isolation Failure to failure to close. Changed the JPM to have CV-31339 fail Actuate to close for which there is procedural guidance to manually close the valve.
7. JPM G PS-6S There are no initial conditions or initiating cues Corrected Respond to A PZR established for the candidate.

Level Channel Failing High. The licensee included initial conditions but will edit to just Corrected discuss the noun name of the annunciator.

JPM must be edited to include Alarm response procedure Corrected (ARP) C47012-0507 steps.

Page 5, Step 1, edit to read charging flow is raised until Corrected total flow is greater than letdown.

Page 5, Step 3 should read TS 3.3.1 Condition A Corrected

Prairie Island Operating Test Comments

8. JPM H RC-15S Performance step? On page 5 says adjust seal injection Corrected High RCS Activity flow to 8gpm and the procedure 1C12.1 5.7.4 B. says 9.5 gpm?

Ensure initial simulator set up has RM read greater than Corrected 10 R/hr Initial conditions should have 2 CCPs running Corrected Change Initiating Cues to read, You are the lead respond Corrected to any alarms that may come in.

Page 4, Step 1, edit to show that annunciator 47077:0108 Corrected is the initiating event.

Page 5, add note that C12.1AOP4 will be looked @ by Corrected another operator.

Prairie Island Operating Test Comments

9. JPM I Instead of stopping the JPM where you suggested just The licensee included more than Immediate Actions make the cues state that the 22DCLP is running and that one JPM to make the exam easier for control room the pressure at PI-11082 is greater than 90 psig. This will to administer. The examiner evacuation shorten the JPM and allow for completion of the disagreed with this plan and only procedure. Why are there more than one JPM included one JPM was selected (F5-9 Unit 1 here? Reactor Operator Actions when evacuating the Control Room).

Page 4, Step 1 need cue for turbine verification Corrected Page 5, Step 2, add that the knife switch is inside cabinet Corrected Page 6, Step 1, put 1190 rpm instead of full speed Corrected Page 7, Step 2, use 1190 rpm instead of running Corrected Page 8, Step 1, note to examiner that valve has no epn Corrected tag

Prairie Island Operating Test Comments

10. JPM J EG-11F Editorial, third performance step on page 6 should include Corrected Local Start of DG the epns of equipment used to control voltage and frequency.

Editorial, first performance step on page 7, what is it the Edited Sat.

candidate is looking for?

How will he/she know if the parameters are normal if the Edited Sat.

examiner is not there to tell them?

Page 5, Step 3, need a note to tell examiner how the Corrected valve is to unlocked and opened.

Page 6, Step 2, add cues for field and output voltage. Corrected Move cue for voltage and frequency from next step.

Page 6, Step 3, make adjusting voltage and frequency 2 Corrected separate steps

11. JPM K MS-4 Very simple one step procedure. Only manipulated one Licensee replaced this JPM Locally open 12 S/G valve. because it was too simple. The PORV licensee replaced this with another JPM, however, during validation it REPLACED was determined that one of the valves needed to perform the JPM VC-16 No comments. was within a contaminated area Borate the RCS due to an event that recently From Outside The occurred. With 17 prospective Control Room candidates this would be too difficult to administer so the licensee replaced the JPM again.

The new JPM was sat as provided.

12. SRO Admin Editorial, equations in JPM are not the same as those in Edited JPM SAT. Minor editorial Determine Max RCS procedure. change required. Corrected.

Venting Time

Prairie Island Operating Test Comments

13. RO Admin Must this be done in the CR? Will add significant time to This JPM was removed because it Remove An the day. There are several examiner cues in the JPM required a portion to be performed Annunciator from which are not indicated as such. Several performance in the control room. For ease of Service steps refer to procedure step 5.2.2.B when it should read exam administration the licensee 5.2.2.C. replaced it with a JPM that REPLACED removed a radiation monitor from Procedure step 5.2.2.C.3 states, Momentarily place the service. However, the examiners Prepare a keyswitch in the Enable/Disable position. What does identified that this activity was part Temporary momentarily mean? of a simulator set. The JPM was Procedure Change replaced again with a new JPM to What are the additional compensatory actions required for perform a temporary procedure removing this annunciator from service discussed in C47 change. The new TPC JPM was step 3.3.5? Why arent they required to be identified as Sat as provided.

part of this JPM?

14. SRO Admin Would like to see a completed PINGP 577 as an answer PINGP 577 provided as answer Reclassify Event and key and the previously completed PINGP 577 as part of key. Answer key needed to be Issue PAGs the initial conditions. changed because the licensee identified that initial condition could result in two possible correct answers. Corrected.
15. SRO Admin The JPM needs to be clarified on page 4 that the Corrected.

Surveillance Test candidate shall identify that stroke time was not Review performed in August in steps 6.1, 7.8, 7.9 of SP1111A to be SAT.

16. SRO Admin Form provided with JPM was Met data, the procedure Corrected.

Authorize Rad waste requires an OPWIND display.

release Initials on step 7.3.8 of C21.3-10.12 provided to the Corrected.

candidate need to be changed so that they are acceptable.

Prairie Island Operating Test Comments

17. SRO Admin Need more detail added to the JPM so that the examiner Changed to include the wrong obtain a current can follow the candidates actions. revision of a procedure to copy of an SP determine if the candidate knows how to use the system. Corrected.
18. RO Admin Minor editorial changes necessary. JPM was changed to include a Prep for Emergency choice of meters from which the Survey candidate needed to choose, and the beta window was to be closed to determine if the candidate knew how to perform a source check.

Corrected

19. RO Admin Drop the word dilution from cue and put boron This JPM was dropped because Prep reactivity Plan concentration change the licensee had no procedural actions from which a standard of REPLACED Editorial = should be + acceptance could be derived. This JPM was replaced with a JPM to perform NIS checks and determine that Channel N43 gains needed to be adjusted.

Perform NIS Checks An answer key needs to be provided. Corrected.

Standard for what is an acceptable value needs to agree Corrected.

with procedure provided. (Page 6, Step 3)

Need note for examiner as to what ERCS value should be Corrected.

on Page 6, Step 1 Need note that tells examiner that Channel N43 needs Corrected.

adjusting on Page 6, Step 2.

Prairie Island Operating Test Comments

20. RO Admin Drop trainee completed logs and identify ALL Corrected.

Review Control discrepancies.

Room Log Candidate should be given a full set of logs. Full set of logs provided.

21. Scenario A Event 1, add required charging flow and seal injection flow Done Sat.

amounts

22. Scenario A Event 2, Reactor Vessel O-Ring Leak, is the same as Will change audit exam. Done.

audit exam JPM.

24 Scenario A Please add definition of adverse containment to note at Will edit. Done page 6.

beginning of scenario.

25. Scenario A There are no abnormal events in Scenario A as defined in Changed initial conditions such that Appendix D, C.2.d page 9-41. when charging pump trips in event 1 the crew should go to 1C12.1 AOP1.
26. Scenario A Can only assume that closing the MSIVs isolates the Will edit. Done Sat.

steam leak?

Scenario A Add note to have lead called away prior to Event 2 so that Corrected.

RO can perform event 2.

Scenario A Need to mark up initial conditions to indicate that the crew Corrected.

is about to swap charging pumps when taking the shift.

11CCP running, 12 unavailable, and 13 in PTL.

Scenario A Event 1, include steps of 1C12.1 AOP1 that are Corrected.

applicable.

Scenario A Ensure that EPNs in addition to noun names are added to Corrected.

JPM where applicable.

Scenario A Event 3, reference procedure C11, Step 5.4 for turning off Corrected.

RM11/12. Reference T/S 3.4.16 B.1.1 & B.2 SR 3.4.14.1

Prairie Island Operating Test Comments Scenario A Event 4 add trip set points for TDAFW as an evaluator Corrected.

note.

27. Scenario B Event 1, what is the TS applicability? Will edit. Done Sat.

Event 2, TS applicability says if leak is stopped. Will the Scenario did not include action to leak be stopped? delete malfunction. Therefore no TS applicability.

28. Scenario B Why not put S/G tube leak then rupture before loss of all Will review for edit. Not done tube AC. This gives another abnormal event. leak was in audit exam.
29. Scenario B Scenario does not discuss the requirement to close the Valves close automatically.

ruptured S/G blowdown valves as desribed in 1E-3 step 3.d.

30. Scenario B Why isnt the RCS depressurized using spray valves per RCPs are gone because of the loss step 17 of 1E-3? of all AC.
31. Scenario B Scenario description for Event 7 critical task is too cryptic. Edit for content. Done Sat.

32 Scenario B Event 1, Steps from ARP 47011:0405 need to be added. Corrected.

33 Scenario B Event 2, add EPNs and/or noun names for valves and Corrected.

switches 34 Scenario B Event 2, edit to remove system engineer Corrected.

recommendation.

35 Scenario B Event 2, TS applicability should be TS 3.4.14 and 3.5.1 Corrected.

36 Scenario B Event 3, add S/G level trip setpoint. Corrected.

37 Scenario B Event 3, edit out 2% criteria in critical task. The Corrected.

termination cue should read S/G levels stable or reactor is tripped.

38 Scenario B Event 4, add steps from ECA 0.0 Corrected.

39 Scenario B Event 4, change so that both diesels start but dont load Corrected.

on.

Prairie Island Operating Test Comments 40 Scenario B Event 5, add isolation of AFW to critical step Corrected.

41 Scenario B Event 5, add appropriate steps from E-0 Corrected.

42 Scenario B A PDP will go away on low VCT level need steps for Corrected.

charging pump recovery added.

43 Scenario B Event 5 add an evaluator note that a followup question on Corrected.

whether or not the crew recognized a release was in progress when the S/G Porv lifted during the tube rupture.

44 Intentionally blank 45 A/B Quality check list Scenarios A and B, dont list symptoms/cues visible to the Edit. Done Sat.

crew. Scenario A major doesnt show what the indications of the steam line rupture are. Scenario B doesnt have symptoms/cues visible for S/G tube rupture.

Events dont have termination criteria. Edit. Done Sat Also, NUREG 1021, Appendix D page 3, states that Corrected.

every required operator action should be on the form ES-D-2. Many procedure actions are not indicated on ES-D-2.

Is A or B or Both new scenarios? All new scenarios.

46 Scenario C Event 2, Places excess letdown in service, is not specific Will edit. Done Sat.

enough.

47 Scenario C Verification of auto rod insertion cannot be a critical task. Rods will stop during auto insertion If the rods auto insert and the operator fails to verify manual insertion is critical.

whats the impact on the plant?

48 Scenario C Isolates B steam generator is not specific enough. Will edit. Done Sat.

Specifically what valves need to be manipulated.

Prairie Island Operating Test Comments 49 Scenario C Event 4, Critical task to start CC pump. Why has CC The CC pump doesnt actually trip.

pump gone away? CC12 has already tripped in previous The bus strips and the pump event. What in attachment L causes the operator to start doesnt come back. Step 7 of CC pump? Attachment L has the operator restart the CC pump.

50 Scenario C Event 7, is there a TS associated with this event? TS TS not applicable.

3.3.1 F1?

51 Scenario C There are no abnormal events in Scenario C as defined in Added RCS leak to implement 1C4 Appendix D, C.2.d page 9-41. AOP1 52 Scenario C Event 1, Alarm 47020:0103 need appropriate steps added Corrected.

to JPM 53 Scenario C Event 2, add note that minimizing charging includes Corrected.

securing a charging pump 54 Scenario C Event 2, add a reference to AOP for Loss of Letdown Corrected.

55 Scenario C Event 3, ARP 47020:0102 references TS 3.7.7 so it is Corrected.

also applicable and should be referenced in the JPM.

56 Scenario C Event 3, add steps on how RO is to restore PZR heaters. Corrected.

57 Scenario C Event 4, RO should recognize entry into TS for DNB Corrected.

below 2200 psig. Need evaluator note.

58 Scenario C Event 5, add note that RO attempts to scram reactor by Corrected.

operating 2 trip switches and the AMSAC/DSS switch