ML15126A466
| ML15126A466 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/19/2014 |
| From: | Bielby M NRC/RGN-III/DRS/OLB |
| To: | Northern States Power Co |
| Shared Package | |
| ML13093A444 | List: |
| References | |
| Download: ML15126A466 (6) | |
Text
NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response Outline Submittal Comments Written Exam Duplicate generic KAs between Tier 3 and other two Lic: Missed the two on SRO, but were aware of the Outline Tiers: 2.2.44, two on SRO exam; 2.2.38, once on RO, requirement.
once on SRO. NRC: Once on each of the exams (ie, RO and SRO) ok. Will accept the two on SRO also.
Written Exam RO Exam Outline, page 2, SGTR evolution comment Lic: Will revise comment to reflect why we feel KA Outline for justification of making Rating 2.2* acceptable. Need Importance Rating less than 2.5 is acceptable and more explanation of what makes question unique to unique for PRA.
PRA. NRC: Accepted rationale for use of this KA on exam.
Written Exam Need more information / justification for rejection of Lic: Will add more information/justification of why Rejected KAs SRO KAs (2nd, 3rd, and 4th). KAs rejected for SRO outline. (2nd, 3rd, 4th)
NRC: Additional information/justification adequate to support KA rejection.
JPMs-Admin 2012 contained a Tag-Out, this year there is a Lic: Did not intentionally make them the same, but Clearance Order. Arent these the same? did look at them. Will review again and change if necessary.
NRC: The JPMs demonstrate different objectives; therefore JPM is not repeated from previous exam.
JPMs-Admin SRO Emergency Procedure for Notification. This is a Lic: Good idea. Will consider.
bank JPM used in the past; perhaps modify (in the NRC: This JPM was replaced with a new JPM to future?) to test the newer HAB procedure that requires demonstrate the applicant ability to implement site SROs to do additional notifications. security procedure actions for a HAB event.
JPMs-System Make sure mitigating actions for SWS JPMs j. and d. Lic: Will review again and revise if necessary.
involve different evolutions. NRC: JPM j was replaced with a JPM from a different safety function area.
JPMs ES 301-1 ES 301-1 would be more helpful if included K/A, brief Lic: Although not required, will add more task description of task, and what makes JPM SRO vice RO. information, KA, and what makes a JPM SRO vice RO as appropriate.
NRC: Additional information provided.
JPMs ES 301-2 SRO-U requires all system JPMs have different safety Lic: Our review missed that requirement, will revise.
function areas. NRC: Replacing JPM j corrected the issue JPMs ES 301-2 Requires at least one in-plant JPM to implement actions Lic: Did not recognize that requirement, will revise.
required during Emergency/Abnormal conditions NRC: Replacing JPM j corrected concern.
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NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response and another that requires entry into the RCA. Currently have only one in-plant JPM with Emergency/Abnormal conditions that also enters the RCA.
Scenario ES-D-1 Scenario 2, Event 7; Scenario 4, Event 5: Both events Lic: They are same malfunction, but the malfunction are Main Turbine Fails to Auto Trip. Are they different occurs under different circumstances in the scenarios events? What makes them different? (before the major event in one scenario and after the major in the other scenario), and both scenarios are never administered to the same crew (applicants),
total of 5 scenarios are being administered.
NRC: No revisions required for this comment.
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NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response Operating Test Submittal Comments RO/SRO Admin JPMs Comments RO Admin 1 1. Verify that 5% (allowed error) is 1/2 of one Lic: The 5% is equal to 1/2 of one division on Fig. 1, division on the nomograph (Figure 1) or and when the correct values are entered into the consider adjusting the allowed error accordingly. formula, the answer is correct.
- 2. Why is 5% error appropriate if the applicant NRC: Concur, JPM is satisfactory as written, no uses the equation? changes required.
- 3. Check the equation given in the note for step 1C12.5 Figure 1(3.); I calculated 3.4 % vs. 34%.
RO Admin 2 1. It seems way too basic to just check procedure Lic: The site procedures require the verification be revisions, especially since were cueing them performed by one of two methods, and this is what that they have an unverified revision of the JPM is demonstrating. The specific actions something else! required are not referenced in the CUE.
- 2. Suggest including this as a part of another NRC: Concur, JPM is satisfactory as written, no critical RO admin task - calculate/verify changes required.
something meaningful and verify they check revisions (that have important differences so it is a critical task) without cueing.
RO Admin 3 1. BKR 112J-1 does not even exist on the Lic: The applicant is required to identify the two document provided to the applicant; is the errors and clarify why the identified issues are in critical step to simply find the typo? It would be error and if the final boundary isolation is adequate.
more discriminating to find the needed NRC: Concur, JPM is satisfactory.
references or determine which of several possible boundaries on a given reference apply.
- 2. The task is to review the clearance order, not simply find the errors. It is important to document the review properly as well as determine all correct boundaries are proper and complete.
RO Admin 4 1. While this is an RO task, it would be far more Lic: The JPM was modified to include the task of discriminating if the applicant was required to completing the Out-of-Service tag and appropriately make decisions or find some of the required apply the tag to the equipment removed from service.
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NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response information to perform the task (rather than just NRC: Concur with the modification of the JPM; the copying information provided by the JPM JPM is satisfactory as modified.
handouts or the examiner).
SRO Admin 1 1. Change cue to just SWI O-2, Shift Organization, Lic: The JPM was modified to state that the STA Operation & Turnover, to avoid leading directly to must leave the site, and the reference to Table 1 was the answer (omit the Table 1 reference). removed from the initiating cue.
- 2. Based on the note referred to in SWI O-2, would NRC: Concur with the modification of the JPM; the the off-going Unit 1 Shift Supervisor have to stay JPM is satisfactory as modified.
until his relief arrived? (Also, SEE BELOW)
- 3. When does This SHALL NOT be used for convenience apply? (If an applicant were to answer that it applies in this case, would they be incorrect? (Both ways cannot be right)
SRO Admin 2 1. Per H24.1, App. A, step 6.6.2.C, how does one Lic: Unless stated in the initial conditions, the know if updating the environmental variables for applicant should not change the variables, and if adverse weather conditions, system conditions applicant asks normal condition indications will be or switchyard maintenance is required? Rather provided. The IT personnel will provide the current than just cueing that it isnt, how can this be revision of the in-service equipment line-up for the determined by the applicant? applicant to verify.
- 2. What is needed to Verify the correct in-service NRC: Concur, JPM is satisfactory.
equipment alignment is input in EOOS, rather than just cueing that it was verified?
SRO Admin 3 1. Specify how the verification of section 6.3.6 was Lic: The applicant will require all sections of the form determined to be complete in the standard. properly filled out prior to approval. The locations of
- 2. Specify where the Bypass Index and Bypass the Bypass Index and Bypass Locker are briefed for Locker are in the standard so the examiner can the examiner prior to administering the JPM.
evaluate the applicants knowledge prior to NRC: Concur, JPM is satisfactory.
providing the cues for the critical step.
SRO Admin 4 1. Are there any records that would be available Lic: The information must be provided by RP, and that the applicant can review to determine if the the critical portion of the step is for the applicant to volunteers have had emergency exposures request to be informed of any prior emer exposures.
(versus being told)? This is a critical step. NRC: Concur, JPM is satisfactory.
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NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response SRO Admin 5 1. Simply answering the phone does not seem like Lic: The JPM was modified to make the proper an evaluative critical step, especially since it just authentication of the call the critical step, and critical reflects turnover information. steps were added to implement the Security
NRC: Concur with the modification of the JPM; the JPM is satisfactory as modified.
RO/SRO CR/IP System JPMs Comments SIM JPM a 1. Though there is a unique malfunction to contend Lic: This is an ALT PATH JPM which requires the with, most of the critical steps are performed in applicant to expressly determine why the rod motion each scenario. I suggest adding additional occurred and takes positive action to stop the rod issues to be recognized to further differentiate it motion.
from the scenarios. NRC: Concur, this JPM is satisfactory.
SIM JPM b 1. Attachment L is verified in nearly all of the Lic: This JPM specifically addresses a Containment scenarios, so there is low LOD and little Isolation Failure which is not included in any of the discriminatory value to this JPM. I recommend scenarios.
replacing it. NRC: Concur, JPM is satisfactory.
SIM JPM c No comments.
SIM JPM d No comments.
SIM JPM e No comments.
SIM JPM f 1. Recommend adding conditions/actions to the Lic: By continuing the JPM another step, the end of the JPM to require operator action to applicant is required to verify that the DG actually have the DG pick up some load. picks up ~ 150 KW of real load.
NRC: Concur, JPM is satisfactory.
SIM JPM g 1. Unlocking a potentiometer, although needed to Lic: The JPM was modified by changing the initial adjust the gain, does not seem like a highly recorded data to require the applicant to verify which discriminating critical task. Since there are only Nis are required to be adjusted, when the 2 critical tasks for this JPM, perhaps a situation subsequent calculations in the surveillance are that required a decision could be added. completed. This JPM was not modified to be ALT
- 2. Possibly make this an alternate path JPM. PATH.
NRC: Concur with the modification of the JPM; the JPM is satisfactory as modified.
SIM JPM h No comments.
IP JPM i No comments.
IP JPM j No comments.
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NRC ILE Outline and Operating Test Submittal Comments 2014 Prairie Island Nuclear Generating Plant Chief Examiner Comment Facility Action/Response IP JPM k No comments.
Scenario D-1 Comments Scenario 1 1. Add another malfunction (there are currently 4, Lic: The scenario is adequately challenging as (1401S) need 5 to 8 per Form ES-301-4). Spare? written and will only be used as the 3rd scenario on one of the crews. Adequate malfunctions already.
NRC: Concur, scenario is satisfactory as written.
Scenario 2 1. The same PZR pressure channel failure occurs Lic: None of the crews will see both 1401S & 1402S, (1402S) here as in 1401S, albeit HIGH versus LOW. so there will not be any overlap between applicants.
There is overlap on TS (LCO 3.3.1). Choose NRC: Concur, scenario is satisfactory as written.
another instrument failure.
Scenario 3 No comments.
(1403S)
Scenario 4 No comments.
(1404S)
Scenario 5 No comments.
(1405S) 6 of 6