ML21137A285

2_AN2-2021-03 Outline Comments

ML21137A285
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/08/2021
From:	Greg Werner Operations Branch IV
To:	Entergy Operations
References
Download: ML21137A285 (4)

Text

Attachment 6 OBDI 202 - IOLE Process Rev 3 PROPOSED OUTLINE COMMENTS Facility:

ANO2 First Exam Date:

29 March 2021 Written Exam Outline (Date)

Comment Resolution 1 NRC Generated K/A replacements approved.

2 Document link to 10CFR55.43(b)(1) in SRO question 99. Outline is missing 55.43 link currently.

Updated as requested.

Administrative JPM Outline (Date)

Comment Resolution 1

Generic JPM Comment: In the Type Codes and Criteria field at bottom of ES-301-1, summarize the exact number of JPMs in each category for quick reference.

Updated as requested.

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

Comment Resolution 1

Generic JPM Comment: Combine the ES-301-2 Forms into 1 form for quick reference, with S8 (RO-only) in italics, and the SRO-U JPMs bolded.

Updated as requested.

2 Generic JPM Comment: For alternate path JPMs, include a brief 1 or 2 sentence summary of the alternate path in the JPM title.

Updated as requested.

3 Generic JPM Comment: For JPMs that are Modified, please briefly summarize what was modified about them. Include the JPM Overview Description excerpts at the end of the ES-301-2 file for quick reference (same for ES-301-1).

Updated as requested.

Simulator Scenario Outline Comments (Date)

Comment Resolution 2019 Scenario Major Events 1-Loss of Heat Sink + 2 stuck rods n/a, reference only OBDI 202 - IOLE Process Rev 3 2-ATWS + LOCA 3-Feedwater Line Break 2017 Scenario Major Events 2-Stuck open MS Safety ESD 3-LOOP to SBO, no DGs avail 4-SBLOCA, loss of HHSI.

Scenario 2 1 Major Event: SGTR n/a, reference only 2

Event 3, credit it as a C instead of R for all positions. An I/C malfunction is more valuable than an R to an SRO-I, who has to have two in the ATC position.

Updated as requested.

3 CT-2: Is a 1-hr bounding criteria post-trip for isolating A SG reasonable /

sufficiently discriminatory? I recognize that we have used that bounding criteria on previous exams (2015, 2014). I would prefer to caveat it with, or upon completion of 2202.010 Attachment 10, whichever comes first. Meaning that it if the crew reports Attachment 10 complete and the SG has not been isolated, we wont wait for a full hour to see if the error is caught.

1 hr. is the FSAR required time for SG tube rupture isolation.

Updated with caveat requested.

4 CT-2: List the specific valves that must be closed to satisfy CT.

Updated as requested.

OBDI 202 - IOLE Process Rev 3 Scenario 3 1 Major Event: Intersystem LOCA n/a 2

Scenario is characterized as Modified; 1021 ES-301 says A significant modification means that, for each scenario, at least two events have not been used on the previous two NRC initial licensing operating exams.

Clarify what previous exam this scenario is modified off of, and what was changed.

This was from 2014 Scenario #2. 1 event was removed, and 3 others were modified.

Discussed with lead examiner. It was determined that this was not modified and thus removed the modified tag.

3 Event 4, rephrase in D-1 to intersystem leak vice LOCA, as its only 15 gpm at this point.

Updated as requested.

4 Event 4, credit it as a C instead of R for all positions. An I/C malfunction is more valuable than an R to an SRO-I, who has to have two in the ATC position.

Updated as requested.

5 Generic - on the pages that include the CT summaries, see if you can make those pages appear in landscape mode for wider columns and easier reading.

May need to create section breaks.

Updated as requested.

Scenario 4 1

Major Event: Loss of Heat Sink w/

LOOP n/a 2

For the TS portion of Normal event 1, make that a separate event, credited as TS-only for the CRS. Reads a little clearer on the D-1 that way.

Updated as requested.

3 Event 5, credit it as a C instead of R for all positions. An I/C malfunction is more Updated as requested.

OBDI 202 - IOLE Process Rev 3 valuable than an R to an SRO-I, who has to have two in the ATC position.

4 Event 6 2A-1 bus lockout, credit it as a C vice M.

Updated as requested.

5 CT-1: Reads like a conditional CT, so rephrase to WHEN both S/G levels are

<= 70 WR. Also what is the starting point for 5F RCS heatup?

Updated as requested.

The heat up point must be determined during actual performance. It would be the temperature when SG level is low enough to no longer be a heat sink.

6 CT-1: Specify the alphanumeric designators of the valves that are required to be opened in performance indicators.

Updated as requested.

Scenario 5 1 Major Event: LOOP.

n/a 2

A loss of offsite power where at least 1 EDG can be immediately manually started doesnt strike me as a very discriminatory major event would you not be in and immediately out of the SBO procedure? I prefer this to be a true SBO where the AAC DG is the success path, especially since Unit 2 is the unit that has control of the AAC DG.

I assume you are trying to avoid overlap with the 2017 SBO scenario?

This was discussed with the Lead examiner and it was determined that it would be left as submitted on the original outline submittal.

Generic Comments