ML14155A497

From kanterella
Jump to navigation Jump to search
2014-02-Draft Outline Comments
ML14155A497
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 02/27/2014
From: Vincent Gaddy
Operations Branch IV
To:
Entergy Operations
laura hurley
References
50-313/14-02, 50-368/14-02 50-313/OL-14, 50-368/OL-14
Download: ML14155A497 (7)


Text

Comments - Rev 1 DRAFT OUTLINE COMMENTS Facility: ANO Unit 2 First Exam Date: February 7, 2014 Written Exam Outline (11/26/2013)

Comment Resolution The outline generated by NRC and Draft Outline updated to Revision 1 provided to you was Revision 0. The 1 outline you sent with the Draft Outline submittal should be Revision 1. Update your version as Rev 1.

Descriptions in K/A Topic(s) column - Re-ran program. QID 31/32 wording added does your program only list the first K/A 2

for systems that have more than 1 K/A selected? (Example: QID - 31/32)

ES-401-4, Record of Rejected K/As N/A reviewed - no issues. Oversampling 3

concerns were identified and discussed prior to outline submittal.

What program was used to create N/A - Outline provided by NRC 4

outline?

Describe methodology used (or program N/A - Outline provided by NRC 5

specs).

How were K/As with < 2.5 IR handled? N/A - Outline provided by NRC Were they removed from the sample prior to random selection? If yes, were 6

all K/As with < 2.5 IR reviewed to determine that none had a site-specific reason to raise their IR? OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Generic Operating Test Comments

1. How did you comply with ES-301, D.1.f? Identify PRA, industry OE events, site-specific events, time critical operator actions, etc. This is applicable for JPMs and scenarios.
2. Ensure all reference materials are included with Draft Op Test submittal - see ES-201, . There are a lot of them so plan accordingly.
3. Since the examiners arent familiar with ANO Unit 2, include noun names with equipment identifiers. Example: 2P-7B will be written 2P-7B, EFW pump
4. Similarly, procedures shall include titles (at least the first time they are used in a paragraph or Event or JPM step). Example: OP 2203.003 will be written OP 2203.003, CEA Malfunctions.

Administrative JPM Outline (11/26/2013)

Comment Resolution A2 and A7: Make sure you incorporate Comments will be reviewed and incorporated.

1 all comments / lessons learned from previous NRC exam (2012).

A4 and A7: Ensure JPM tests the issues A4 and A7 will test the weakness identified (weaknesses) identified in ANO-2012- during the previous NRC exam.

2 633. Scenario 1 will test weakness with CEAC/CEA position.

A9: Replace this JPM. EAL classification Will work with Examiner to determine a viable has been performed on at least last 2 alternative.

3 NRC exams. Consider JPM for toxic gas Some potential replacements have been or other Emer Plan activity. identified.

A3: Evaluate Containment Atmosphere Yes. Daily (performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) 4 conditions - is this a surveillance? OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Control Room / In-Plant System JPM Outline (11/26/2013)

Comment Resolution Ensure no overlap between CR-IP JPMs We have verified no overlap. Will continue to 1

and simulator scenarios. check with each revision.

P2: replace with P1 (non Alt Path) from P2 replaced as requested.

2012 NRC exam. The SDBCS has been 2

tested on last 2 NRC exams and is included in Scenario 3 as Event 7.

Make SRO-U JPMs S1, S4 and P1-3. Modified SRO-U selections for JPMs.

For Safety Function consideration, 3

replace P3 with Safety Function 8 JPM Systems in Safety Function 8 are limited in that is A/N/R. RCA. Recommend leaving as is.

SRO-I: what was basis for them not No special basis.

4 doing this JPM? OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Generic Simulator Scenario Comments

1. Alternate events between ATC and BOP (unless good reason not to).
2. Scenario D-1s, dont repeat information from Initial Conditions to the Turnover block.

Turnover information is generally short - it only applies to activities that the applicant would get for their specific watch. Example - the evolution planned.

3. All Tech Specs need to identify the LCO Condition(s) that applies. D-2s must identify which Tech Spec calls are shall be verses those that may be identified.
4. All evolutions will require a procedure copy that has been place-kept up to the point where the crew will commence the evolution.
5. What are the Critical Tasks for each scenario? Ensure each Critical Task has clearly defined success (and therefore - failure) criteria identified. May need to get an Operations representative on the Exam Security Agreement for input (Assistant Ops Mgr or above).
6. Does each scenario have a clearly defined end point?
7. Attach the table of Target Quantitative Attributes (found at the bottom of ES-301-4, Simulator Scenario Quality Checklist) to the bottom of each D-1 or on the next page. Ive included an Adobe (.pdf) example for your reference. (I dont necessarily agree with the format or level of detail contained in this example - its just for demonstrating use of the Target Quantitative Attributes table in the D-1.)
8. It should be possible to determine whether each Event is ACA or AOP or EOP driven.

Either identify in the Event Description or in the narrative summary.

9. In general, Events should alternate between ATC and BOP. This allows the Lead Examiner the opportunity to run two events in parallel (or at least start the next Event without having to wait for the applicant to completely finish).
10. Initial Conditions - dont need to state All ESF systems in standby or other similar statements. Only need to identify conditions or lineups that are out of normal.
11. Event Descriptions on D-1: should be succinct. Details are put in Narrative Summary. OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Simulator Scenario # 1 Outline Comments (11/26/2013)

Comment Resolution Re-order Events 1 2 - 4 (see #9 Changed as requested.

1 above).

Event 3: Event Description - what is Instrument Number has been added.

2 instrument name/number?

Event 5: Ensure rate of oil leak is small Oil leak size is of an adequate size to allow 3 enough that crew can step through the procedure to be implemented.

procedure.

Event 6: Fail CSAS to auto actuate Will add CSAS fails to complicate post trip.

After discussion I am still concerned that this 4

will cause an additional critical task. May want to fail only one train.

Event 7: Is loss of both EFW pumps Discussed and No changes required.

reasonable without a preceding 5

incident? Should one pump be tagged out? Loss of a power supply bus?

Event 7: Delay LOAF until SRO Discussed and this would impact the 6 completes diagnosis of ESD and makes contingency procedure use. Leave as is.

procedure transition.

Add Event 8 for ATC - running CCP trips Discussed and this malfunction will not work 7 and loss of Aux Spray. as desired. Will attempt to add an ATC malfunction after the major. OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Simulator Scenario # 2 Outline Comments (11/26/2013)

Comment Resolution Narrative says scenario begins at 100% Updated typo.

1 power - should be 40%

Initial Conditions - will need a power Power band has been added.

2 band for crew to maintain (not approx.

40%)

Event 2: How is this affected by C This will cause points in the B channel Excore 3

already in Bypass? to be tripped instead of bypassed.

Prior to Major Transient - BOP has 4 After discussion will attempt to change normal 4 beans, ATC has 2. Change Event 4 to to ATC to even out distribution.

an ATC bean.

Re-order all events to alternate between Events have been reordered.

5 ATC and BOP.

Event 3: BOP can be given credit due to Updated for BOP credit.

6 verifiable actions with SDBCS.

Event 4: How long does crew have to 10 min. Not a critical task.

7 restore CCW to RCPs? Is this a Critical Task?

Event 4: Is 2P-33A not already running No. 2P-33A will not be running and receives 8 when 33B trips? Narrative states and no auto start signals.

start 33A Event 5: We will need shutdown specs Added reactivity plan data for the first 15 min.

(amount boration needed, CEAs) so we can compare what applicants 9

determined with what should have been identified. Also need to identify actual leak rate in the D-2s) OBDI 202 - IOLE Process Form - Rev 1

Comments - Rev 1 Simulator Scenario # 3 Outline Comments (11/26/2013)

Comment Resolution Initial Conditions - Dont need to state Removed.

1 All ESF systems in standby.

2 Alternate events between ATC and BOP. Events 2 and 3 have been swapped.

Event 2: Is this an AOP event? No it is an annunciator corrective action 3

response.

Event 6: Crew waits for NLO report to IAW our transient response conduct of ops 4 start HPSI pump? What about the LPSI both 4160 volt loads will check prior to pump? starting. Will provide a copy of COPD-32.

Event 6: RED Train maintenance week - No.

5 any impact on this event?

Event 6: What is failure mode? Would Green train SIAS, all components: Auto manual actuation be successful? Should actuation will fail, Manual actuation with the they attempt a manual actuation? push buttons will fail, but components can be 6

manipulated using handswitches.

Red train component on event 6 will not function at all.

Event 7: ATC selects another steam Yes.

7 dump bypass valve to re-initiate the cooldown? OBDI 202 - IOLE Process Form - Rev 1