ML20265A259

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Ile Operating Test Outline Comments
ML20265A259
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 12/11/2018
From: Chuck Zoia
Operations Branch III
To:
Exelon Generation Co, NRC/RGN-III/DRS/OLB
Zoia C
Shared Package
ML17164A408 List:
References
50-373/18-301, 50-374/18-301, RA18-100 50-373/OL-18, 50-374/OL-18
Download: ML20265A259 (9)
v • d • e


Text

LAS Operating Test Outline Comments As included in the attached Preliminary Form 301-7 documentation, there were no significant Operating Test Outline Comments. All review comments were provided to the licensee, resolved at the Onsite Validation (OV), and any changes made were documented in file LaSalle 2018 ILE Form ES-301-7.

ES-301 Operating Test Review Worksheet Form ES-301-7 Facility: LaSalle Exam Date: November 2018 1 2 3 4 5 6 ADMIN Attributes Job Content LOD Admin JPMs Topic U/E/S Explanation (1-5) I/C Critical Scope Perf.

and K/A Job Cues Overlap Key Minutia Focus Steps (N/B) Std. Link NRC: The Technical Specifications should be listed as COO A-SRO-39 2 E being required for the JPM setup.

2.1.20 Response:

COO A-SRO-20 2 S 2.1.18 NRC: Fire Protection Impairment Permit given to the applicant for review lists MMD as the work group in EC section I. Based on the nature of the work and the A-SRO-68 2 X E 2.2.17 expected answer key, the work group should be listed as EMD.

Response

RC A-SRO-37 2 S 2.3.4 NRC: Step 18 indicates the applicant should enter code EP 20 when contacting IEMA. It appears that LaSalle is A-SRO-101 3 X E 2.4.30 code 25 based on page 2 of the NARS form.

Response

NRC: What are the verifiable actions for the critical steps COO where the applicant checks or determines A-RO-1 3 X E?

2.1.25 something? How is this documented? (GENERIC)

Response

NRC: What are the verifiable actions for the critical steps COO where the applicant checks or determines A-RO-46 2 X E?

2.1.5 something? How is this documented? (GENERIC)

Response

NRC: Initial conditions 5th bullet is missing the word be EC A-RO-48 2 X E preceding 12,500 GPM.

2.2.44 Response:

NRC: Include the limiting LGA-009 conditions in the JPM RC A-RO-47 2 E Standard.

2.3.5 Response

1 Simulator/In-Plant Safety Function JPMs and K/A 4

S-RH-29 203000 3 S A4.11

ES-301 Operating Test Review Worksheet Form ES-301-7 3 NRC: On JPM summary sheet, indicate that this is not S-MS-06 239001 2 E an alternate path JPM.

A2.03 Response:

NRC: 2nd bullet in initial conditions needs to be corrected as it reads, 1B TDRFP and the Both Feed Reg Valves 2 are in Auto. It should read 1B TDRFP and both Feed S-RL-01 259002 2 X E Reg Valves are in Auto. Also, consider an earlier exit A1.04 strategy since all critical steps are completed after Step 6 is performed (OV).

Response

1 NRC: Acknowledging a confirmatory pop-up message does not seem to be a Critical Step - suggest combining S-RM-02 201002 2 X E with step 8.

K1.08 Response:

6 NRC: Please clarify within the guide how each method is S-AP-08 262001 2 E arrived at and performed (OV).

A2.07 Response:

NRC: The LOR given is for the 1B RHR SERV WTR RAD HI. The applicant is shutting down the 1A RHR 9 heat exchanger. The LOR number also does not S-RH-28 272000 3 X E correspond to step 4 either (B112 vs. B212) and was A1.01 probably written for the 1A RHR heat exchanger rad monitor.

Response

NRC: JPM Summary indicates that the K/A supported is 8 400000 A2.01. This is not the correct K/A as recorded on the ES 301-2 operating test outline - K/A 400000 S-WR-02 400000 2 E A4.01 was supposed to be tested. The JPM meets both A4.01 K/As so this issue can be considered an enhancement.

Response

7 NRC: Initial conditions 4th bullet should read, has been checked. Also, this is actually a New (vs. Modified, as S-RP-05 212000 2 X E the outline indicates) JPM.

A4.07 Response:

5 P-PC-06 223001 2 S A2.07 4 NRC: Error message stated with no initial conditions P-RH-04 205000 2 X E given on paper copy only - possible file error?

A2.03 Response:

2 NRC: If intention is to have some applicants perform the jpm on Unit 2, ensure that Attachment 2B is provided.

P-CY-05 295031 3 E Not provided with review packet.

EA1.08 Response:

ES-301 3 Form ES-301-7 ES-301 4 Form ES-301-7 Facility: LaSalle Scenario: 1 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 S 3 X X S 4 S NRC: No event termination criteria established.

E 5 Response:

6 X S 7 X S 8 X S 9 XX S NRC: In addition to initiate Emergency Depressurization, establish RPV level controlled and in band (provide values) and containment pressure X E < (provide value) and being controlled as event termination criteria.

10 Response:

10 0 0 0 0 2 3 7 E NRC: See above comments.

ES-301 5 Form ES-301-7 Facility: LaSalle Scenario: 2 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 S 3 X S Note: Verifiable action step for BOP occurs if SRO recognizes ODCM S

4 entry requirement and orders 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action requirement performed.

5 X -

NRC: Based on HPCS initiating on an invalid Level 2 signal, the lo-lo level instrumentation appears that it is indeed inoperable. With the actions taken to shutdown HPCS and prevent its restart, LCOs 3.3.5.1 and 3.5.1 BOTH appear appropriate to be entered. The HPCS DG is X X E not affected by plant conditions, and therefore it would not be appropriate for the SRO to enter or consider LCO 3.8.1 with HPCS inoperable for reasons other than operability of the HPCS DG.

6 Response:

7 X S 8 X S NRC: Action for SRO to direct and BOP perform inhibiting ADS not labeled as a Critical Task. Identified as a Critical Task in summary XXXX E section of scenario.

9 Response:

9 0 0 0 0 2 4 5 E NRC: See above comments.

ES-301 6 Form ES-301-7 Facility: LaSalle Scenario: 3 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 S 2 S 3 S 4 X S 5 X S NRC: Consider reordering this event to just before the major event or just before the FRV fails open event as an untimely response to this failure could lead to a procedurally driven manual scram (runback E

occurs with power > 20%RTP).

6 Response:

7 X S 8 S 9 X S 10 X X S 11 XX X S NRC: Critical task to initiate suppression chamber sprays is not listed in the summary front matter section of the scenario paperwork.

E

Response

ES-301 7 Form ES-301-7 Facility: LaSalle Scenario: 4 Exam Date: November 2018 1 2 3 4 5 6 7 8 9 10 Required Verifiable Scen.

Event Realism/Cred. LOD TS CTs U/E/S Explanation Actions actions Overlap 1 X S 2 S 3 S 4 S NRC: This failure is silent as there is no annunciator that will sound and comprises one valve losing indications lights. It is very likely the applicants may not notice this event has occurred without some form of X X U prompting.

5 Response:

NRC: More actions should be listed on the D-2 including review PPC for rod positons, LPRM indications, run OD-20, contact QNE, etc.

X E 6 Response:

7 X X S 8 S NRC: ATC will be directed to manually scram the reactor with a primary system discharging into secondary containment. D-2 should include X E action to scram when directed and those actions taken post reactor 9 scram IAW LGP 3-2.

10 X X S 10 0 0 0 1 2 2 6 U NRC: See above comments.

ES-301 8 Form ES-301-7

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