ML22243A221
| ML22243A221 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 08/26/2022 |
| From: | Jim Nance NRC/RGN-III/DRS/OLB |
| To: | Xcel Energy |
| Nance J | |
| Shared Package | |
| ML21188A222 | List: |
| References | |
| Download: ML22243A221 (3) | |
Text
3/24/2022 Outline Comments
- 1. REF: ES-3.1, Page 4 of 5; B.10 - Explain how incorporating facility-specific and industry generic operating experience into the operating test was performed.
Response: OE was incorporated into Scenario and JPM Guides. Now Sat and verified at On-Site Validation (OSV).
- 2. REF: ES-3.1, Page 4 of 5; B.10 & 11 - Explain how incorporating dominant accident sequences and probabilistic risk assessment (PRA) / individual plant examination (IPE) was used to identify risk-important operator actions.
Response: PRA and risk-important operator action are required by the licensees SAT process and were incorporated into Scenario and JPM Guides. Now Sat and verified at OSV.
- 3. Provide a copy of the outlines for the audit exam to verify that there is no overlap when they are available (REF: ES-3.1, Page 3 of 5; B.4 and Form 2.3-1).
Response: Received outlines of the audit exam on May 5, 2022. Sat.
- 4. REF: ES-3.3, Pages 13 Scenario Critical Tasks (CTs) must be developed and documented to show that these criteria are met. Specifically, when addressing the following in the scenario guide (To be reviewed at the Onsite Validation (OV)):
- a. It needs to be explained how they directly lead to restoration of safety functions, how they are EOP-directed verifiable actions essential to an events overall mitigative strategy, and/or how they are tasks with one or more actions that would prevent a challenge to plant safety, such as preventing conditions that result in orange or red path critical safety functions.
- b. CTs must possess each of the following elements:
- i. Initiating Cue: alarm, communication, OR procedure step ii. Performance Feedback: The crew must be able to determine that its action had an impact or that its inaction caused plant conditions to degrade.
iii. Success Path: It must be possible to accomplish the CT during the scenario.
iv. Measurable Performance Standard: The measurable performance standard for a CT must include the expected observable actions and boundary conditions that clearly identify when a CT must be accomplished. Boundary conditions must include the bases for the requirements (For example, PI-CT-13 and PI-CT-18 in Scenario #1 need to explain the bases for the given time limits)
Response: Licensee addressed each concern which were evaluated now Sat and verified during OSV.
3/24/2022
- 5. GENERIC COMMENT ES-3.4.A, General Instructions, Page 1 of 10 and ES-3.4.C, Specific Instructions, Page 3 of 10 - For those events in each scenario which have been significantly modified, please explain how they were modified.
Response: Licensee addressed each item satisfactorily. Now Sat and verified during OSV.
- 6. Several overlaps have been identified, for example:
- a. First stage pressure instrument failing low appears in 2022 Scenarios 1 and 3, although the instruments/channels may be different.
- i. The Tech Specs are the same with the exception that in Scenario 1, it includes TS 3.3.1 Condition R instead of TS 3.3.1 Condition T. TS 3.3.1 Condition A is entered for both scenarios as is TRM 3.3.4 Condition A.
Both SRO-I1 and SRO-I2 will be examined on Scenarios 1 and 3 and therefore 50% the TS calls they make for this exam will be for the same TRM call and for the same TS section, 3.3.1 Condition A, with the only difference being TS 3.3.1 Condition R instead of TS 3.3.1 Condition T.
- b. There appear to be events in the five scenarios that are repeated in the other four scenarios:
- i. Scenario 5 Example
- 1. Scenario 5, Event 7: Main Turbine fails to auto and manually trip and MSIVs fail to close. Crew will direct outplant operator to trip turbine locally
- 2. Scenario 3, Event 6: Main Turbine fails to automatically trip. Crew will manually trip turbine from the control room
- 3. Scenario 4, Event 6: Failure of main turbine to trip automatically or manually on reactor trip, MSIVs will fail to automatically close and the crew will manually close the MSIVs from the control room
- 4. If Scenario 5 is used/needed, it has the potential to overlap both Scenarios 3 and 4, i.e., both days and all crews.
ii. Scenario 3 Example
- 1. Scenario 3, Initial Condition - 12MDAFWP OOS - Event 8: 11 TDAFWP fails to start automatically
- 2. Scenario 2, Initial Condition - 11TDAFWP OOS - Event 7:
12MDAFWP fails to start automatically
- 3. Applicant I-1 will see Scenario 3 in the morning as the SS and then be the BOP responding to the 12MDAFWP failure to start in the afternoon in Scenario 2.
iii. General Comment - There are four scenarios where one piece of equipment is OOS. In three of those scenarios the one piece of equipment OOS is an AFW pump and in each of those scenarios an AFW pump is needed for an event.
- c. Additional overlaps / potential overlaps identified:
3/24/2022
- i. 2022 - Scenario 1, Event 1 - Energize PRZR Backup Heaters and Event 3 - PRZR PORV 1 PCV-431 Leakage
- 1. 2020 - RO/SRO-I JPM C (JPM#RC-25SF) Energize PRZR Back-up Heaters and Respond to PRZR PORV Leakage ii. 2022 - Scenario 1, Event 6 - Small Break LOCA (new)
- 1. 2022 - Written exam questions 9, 35, 63 iii. 2022 - Scenario 4, Event 4 - Reactor vessel o-ring inner seal leakage (new)
- 1. 2018 - Scenario 3, Event 5 - Reactor Vessel O-Ring Leakage iv. 2022 - Scenario 4, Event 7 - SI to chilled water signal actuation failure (new)
- 1. 2020 - Scenario 3, Event 7 - SI to cooling water relay signal failure
- 2. 2018 - Scenario 2, Event 7 - SI to CC Relay Actuation Failure Response: The licensee clarified that many of the instrument failures affected different plant systems and/or controllers. All concerns were addressed satisfactorily and validated at OSV.
- 7. The Form 3.4-1 Events and Evolutions Checklist does not matchup entirely with Scenario 1,2, and 3 Outlines. For example, the positions for R1 and R3 are swapped with positions R2 and R4 on Form 3.4-1 from those stated in Scenario 1 and 3 outlines.
R5 for Scenario 2 shows a Manual Control on Form 3.4-1 which does not appear on Scenario 2 outline for the ATC position (which is R5s position for that scenario)
Response: Transposition and typo errors were fixed. Sat
- 8. Scenario 5 may need to be included on the final Form 3.4-1 if it is not selected to be the spare following onsite validation. Also, identify all TS opportunities in ALL scenarios (NOTE: there are less than 2 opportunities identified for Scenarios 2, 4 and 5, and though these are currently projected to be used with surrogates in the SS position, assignments may change after the OV).
Response: Additional Tech, Spec call added to Scenarios. Sat and verified at OSV
- 9. JPM ADMIN-132 references K/A 2.4.40 Knowledge of SRO responsibilities in emergency plan implementing procedures (SRO Only) which has an importance rating of 4.5. The JPM outline incorrectly shows an importance rating of 4.6.
Response: Typo fixed. Sat