ML20233A920

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AN1-2020-03 Draft Outline Comments
ML20233A920
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 06/05/2020
From: Greg Werner
Operations Branch IV
To:
Entergy Operations
References
Download: ML20233A920 (5)


Text

PROPOSED OUTLINE COMMENTS Facility: AN1 First Exam Date: March 30, 2020 Written Exam Outline (Date)

Comment Resolution 1 NRC Generated Please put the two outlines back Done.

together (RO and SRO) into one file. We have to track overlap for the entire exam 2

now per NRR so we need to see all the topics for both exams together to ensure no duplication.

Comment-you removed admin refuel Changed Job task analysis for RO position.

requirements topic from written outlines for RO and stated that it is not 3

applicable but you had an admin JPM on this very topic on the 2005 NRC exam. Explain.

4 5

Administrative JPM Outline (Date)

Comment Resolution For A5-A8 - you cant use all of these Licensee agreed to all comments. Some JPMs because they are all on the items that arent modeled they proposed previous two NRC exams and cant alternate items which was acceptable to the 1

have been selected randomly from a CE.

fully developed bank of JPMs. I will outline the strategy for you to use below For A1- I would like to see a reactivity Licensee agreed to change it.

balance calc performed then have the 2

SRO review it for adequate shutdown margin in A5.

For A2 - I would like to see a time to Licensee agreed to change it.

boil/time to core uncovery calc similar to 3

the 2013 JPM but using different numbers For A3 pick a different piece of Licensee agreed to change it.

4 equipment than the fuel oil transfer pump.

5 For A4 - okay 6 For A5 - see comment 2 above. Licensee agreed to change it. OBDI 202 - IOLE Process Rev 3

For A6 - I would like to see a time to Licensee agreed to change it.

boil/time to core uncovery calc similar to 7

the 2013 SRO JPM but using different numbers For A7 use A3 and apply TS to it for Licensee agreed to change it.

8 SRO only JPM.

For A8 determine max allowable venting Licensee agreed to change it.

9 time of a radioactive tank.

10 A9-okay Control Room / In-Plant System JPM Outline (Date)

Comment Resolution Too much use of previous material so we will need to change some JPMs to 1

give you some new topics and new JPMS 2 For S1-okay For S2- create or find in your bank an Licensee agreed to change it but didnt use 3 inventory change (ie RCS fill) during the mid-loop idea. Ce agreed with their mid-loop as a normal path JPM alternate JPM.

For S3- create or find JPM on Licensee agreed to change it.

4 surveillance of PORV block valve (it fails) so close PORV - alt path For S4- we wont use this JPM or the SF Licensee agreed to change it.

4P on this exam (used same JPM too 5 much). The Initiate Common feed becomes S4, not 4B SF, it is 4S (a typo on outline)

For S5- SF5 will be during LOCA, Licensee agreed to change it.

transfer CS to recirc with cavitation due 6 to sump blockage (alt path, EN, E, L) requires securing at least one pump to stop cavitation For S6- modify this JPM to create a Licensee agreed to change it but didnt use condition where the alt power supply the idea the CE proposed. Ce agreed with 7 breaker doesnt open and must be their alternate topic JPM.

manually opened so the edg o/p bkr will close and power bus 8 For S7-okay For S8- havent done SF9 in forever in Licensee agreed to change it.

simulator-lets try a Control room ventilation alignment change and during 9 that alignment a rad alarm comes in requiring isolation of CR ventilation (recirc) and manual isolation must be triggered-alt path OBDI 202 - IOLE Process Rev 3

10 P1 and P2 are good P3 we need a different SF due to Licensee agreed to change it.

predictability (used too much for RCA 11 JPM). You guys can pick but it needs to be RCA and normal path.

Simulator Scenario Outline Comments (Date)

Comment Resolution General comments - Licensee agreed to change most of the items

1. events that are considered as suggested at least until validation and we normal beans do not become can see how they flow.

CTs merely because if they dont get the actions done it creates an unplanned RPS trip.

That creates a post scenario CT but this is unexpected and cant be planned that way for credit.

2. The NUREG requires that scenarios are varied over core life and core power. You have four of five scenarios that are at full power with no designated time in core life on the D-1 form.

We need to have a low power, a mid power, and a high power scenario, and the low power is most operationally valid at BOL, while the high power should 1 have a BOL and an EOL setup.

The mid-power is most valid at BOL. So at least one scenario should be BOL, one MOL, and one EOL for diversity and to meet NUREG requirements.

3. You need to have a balanced set of beans for each scenario-so at least two for the BOP and two for the ATC, before the major.
4. Please use noun names with the pumps so we know what pump you are talking about (ex. P-4C is the #2 EDG cooling water pump).
5. Critical tasks are normally after the major events that place you in the EOPs because it is usually only then when you are actually starting to challenge safety functions such as core cooling, OBDI 202 - IOLE Process Rev 3

heat removal, or containment There are exceptions such as a stuck open porv at power (this is a clear loss of the rcs barrier).

These are rare though, while at power, and if you put one there for one scenario, you need to look at doing it for the others to keep them consistent.

6. CTs need to be more involved in the EOPs (deeper, more complex) I provided some suggested changes to all five scenarios, which we can discuss when you receive the comments.
7. The reason normal events are allowed to be substituted with malfunctions is to provide more competencies for grading and to allow for demonstration of control when the plant is moving (rx and secondary, via transients). It also raises the LOD of each scenario.

We dont need the normal if you want to remove them. We will see how it all looks during validation for time.

8. To meet SOER 10-02 you need to incorporate bus losses into your scenarios. I have suggested two types in two different scenarios.
9. Two ICW equipment events.

Need to change one to something else. See suggested list in separate file.

10. Inadvertent starts of safety equipment was included on two scenarios (one EFW, and one HPI) because these are OP Experience cases that we want to see how they are handled because industry reported to the commission that they have adequate training and procedures for these events.

ANO had a switchyard event in 2019 where all three trains of EFW started so this is important.

See attached list for suggested changes Yellow-new events, orange are majors (no 2

to scenarios. changes to them) OBDI 202 - IOLE Process Rev 3

ANO1 2020 Scenario changes recommended 99.70% 99.70% 60%?? 99.70% 2-5%

EOL BOL? BOL? MOL? BOL?

Scenario 1 (2020) Scenario 2 (2020) Scenario 3 (2020) Scenario 4 (2020) Scenario 5 (2020)

Shift ICW Pumps, Place P- Place A MFWP in service Align for 2 minute withheld from Adams withheld from Adams 33B in service, Secure P- and secure P-75 Aux FW delithiation because not used because not used 33A Pump non-safety bus trip, lockout Inadvertent start of all 3 Inadvertent start of train A

- has turbine cooling water trains of EFW due to HPI - TS on it switchyard fault-TS P-3A CW pump sheared Degrading Vacuum Reset ARTS (not a CT) shaft - TS LT-1001 Pressurizer Level A' OTSG level inst fails TS Inverter Y11 failure Fails Low (T.S. 3.3.15) low Pressurizer Steam Space Main Steam Header Raise power to 10%

Leak (15 gpm) (T.S. 3.4.13) Pressure bias failure Group 7 Rods do not Generator H2 Temp sequence on resulting in B MFW Pump Trip Controller Setpoint (TIC-no overlap between 4018) failure - not a CT Groups 6 & 7 Pressurizer Steam Space A Main Steam Line break M-(ALL) Loss of Offsite Leak increases to ~800 inside containment Power gpm 2 Stuck Control Rods - ESAS Channels 5 & 6 fail lockout of 2 EDG with TD Emergency Boration to actuate automatically EFW pump failure EFIC Vector Isolation RCPs must be secured failure for one EFW flow EDG 1 fails to auto start within 2 minutes of LOSM path to failed generator CT8: BOP will start the

  1. 1 EDG within 15 CT1: Trip ALL RCPs CT19: Manually actuate minutes of Blackout.

within 2 minutes of Channels 5 & 6 prior to EAL escalation is LOSM (< 30F) following reporting the completion required if the EDG is the reactor trip. of RT-10.

not started within 15 minutes.

CT-16: Manually isolate CT23: Commence all FW flow (MFW and Emergency Boration EFW) to the faulted CT88:ATC will restore within 15 minutes of the steam generator prior to EFW flow with A train reactor trip with two steam generator reaching EFW pump stuck rods. 400 inches (Carry-over into main steam lines) OBDI 202 - IOLE Process Rev 3