ML21137A289

6_AN2-2021-03 Operating Test Comments (Final)

ML21137A289
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/08/2021
From:	Greg Werner Operations Branch IV
To:	Entergy Operations
References
Download: ML21137A289 (8)

Text

ANO 2 2021-03 Draft Operating Test Comments NOTE: This summary is being provided in lieu of Form 301-7, Operating Test Review Worksheet, because the licensees operating test submittal was reviewed and overall deemed SATISFACTORY.

Scenario 2 (100% MOL):

1. MAJOR: SGTR

2. Is there a handout for this scenario? Not in package.

• No procedure handout for this scenario, it does not include a Normal.

3. Quantitative attributes: 5 Abnormal Events, if you include ARPs. Scenario is within reasonable level of difficulty, additional abnormal events compensate for reduced normal/reactivity events.

• Updated Scenario 2 and 301-4

4. CT-2, add whichever comes first to CT acceptance criteria.

• Adjusted CT in D1 and D2 to match

5. Event 1: Tech Specs 3.3.1.1. and 3.3.3.5 both need to list all of the FUNCTIONAL UNITS which are affected, from their respective tables, which direct entry into the required action statements.

• For T.S. 3.3.3.5, added instrument number for table 3.3-9 to examiner notes.

Removed 3.3.1.1. note due to not being in the mode of applicability.

6. Event 3, specify that TS 3.4.5 Action A is required to be entered.

• Added action a to Tech Spec examiner note.

7. Put Attachment 51 starting on its own page, with a page break.

• Page break inserted, columns adjusted.

8. Swap the numbering of events 7 and 8, and update D-1 and D-2 headers.

• Updated D1 and D2 for swapping event 7 to Letdown fails to isolate and event 8 to Gland Seal Regulator fails closed.

Post-Validation

1. Narrative: include TS 3.7.1.2.a and 3.4.5.b in Scenario Narrative.

2. CT-2: Measurable Performance Indicator, the 2 MSIV header #1 isolation switches on 2C17 and 2C16 are an OR statement.

3. Event 1 annnunciators: 2K04 H4 and 2K09 J5 are N/A

4. Event 1: points 1 3 4 are not bypassed, only point 2.

5. Event 3: Include steps for 2104.003 Att R, since thats what the ATC chose to use.

6. Event 3: Step 9 PG 17 BOLD 2CV-1000-1

7. Event 3: Add TS 3.7.1.2.a

8. Event 6/7 Event description, should by SG A tube rupture.

9. Event 6/7 page 41: delete note that SDBCS byp valves are not avail due to loss of IA.

Scenario 3 (74.5% MOL):

1. MAJOR: Inter-system LOCA

2. Event 1, reference what procedure is being performed at the very start.

• Updated Event 1 to note implementing EH Procedure at start

3. Event 2, Tech Specs 3.3.3.6 needs to list the FUNCTIONAL UNITS which are affected, from the respective table, which directs entry into the required action statement.

• Added functional unit 4 for pressurizer level to TS examiner note.

4. Event 5/6 pg 33 says 250 gpm LOCA but D-1 says 300 gpm.

• Updated D2 Event 5/6 to 300 gpm to match D1

5. I dont see Exhibit 9, ESFAS Actuation included needed?

• Added Exhibit 9 steps for SIAS and CCAS to end of event 5&6 and examiner note at step directing exhibit 9.

6. Page 32, reference the actual CT-2 number.

• Updated with CT-2

7. Page 17, explicitly restate CT-1 verbage.

• All CTs updated in D2 to match D1

8. I dont see CT-3 referenced in the body of the guide page 43? Later?

• CT-3 added to D2 at EOP commence cooldown step Post-Validation

1. Event 2 - Lpzr control back in AUTO as a transition criteria

2. Event 3 description is opposite to the trains of CCW in service.

3. Event 5/6 page 40 add field for recording time of entry to LOCA procedure 2202.003

4. Event 5/6 page 45 add procedure header for Section 3 Unisolated LOCA

5. Add page breaks so that the procedure header appears at the top of the page

6. Event 7 - bold or highlight Exhibit 9 step for verifying Red Train HPSI pump in service.

7. Event 7 - list HPSI termination criteria.

8. Termination criteria: include completion of Att 5 and Att 51 Scenario 4 (80% EOL) (100% MOL ):{Draft comments had this marked as 80%}

1. Major Event: Loss of Heat Sink w/ LOOP

2. 5 Abnormal events. Scenario is within acceptable bounds of difficulty and length.

• There are only 4 abnormal events are credited for this scenario (3, 4, 5, 6).

Event 2 would not meet requirements for an observable action taken. During event 7 the crew may elect to trip the reactor without entering an AOP or ACA.

3. Event 2 is TS only for the CRS, there should not be any addition Component Malfunction credit given for the BOP or CRS. Ensure 301-5 updated too.

• Removed CRS & BOP component malfunction credit from scenario and 301-5 for crew a, e, f, & g.

4. Event 1, reference what procedure is being performed at the very start.

• Added to Event 1,2 Table to implement 2104.014

5. Ct-1: add a space in the D-2 to document starting CET temperature, to assess satisfaction of the CT.

• Added space to document starting CET temperature

6. I dont see any termination criteria for the scenario in the D-2

• Added terminate criteria at end of the D-2 for after once through cooling has been initiated.

7. Event 6: We need to be certain that Tc will increase high enough to require entry into TS 3.2.6, since there is only 1 other event with a TS call.

• Loss of Main Feed Pump at 100% power requires turbine load reductions at a pace that ensures that the crew exceeds the Tc Tech Spec limit

8. Is crew going to perform 2202.010 Attachment 10, to isolate a SG (page 36)? If so do we need it in the guide?

• Examiner Note added to explain that both steam generators are expected to lower to 70 WR at approximately the same time which will drive the crew to implement OTC actions vice isolating the steam generators. Standard attachment 10 not expected to be be observed prior to reaching termination criteria.

9. Having to implement OTC due to a loss of heat sink should count as an EOP Contingency, even though its not a separate procedure at this plant. Its a loss of critical safety function.

• Updated scenario to take credit for EOP contingency. Updated 301-4.

Post-Validation

1. CT-1: Remove LTOP isolation valves from measurable performance indicator.

2. Missing page 23 in Event 6.

3. Add Att 54 - reset A EFW pump

4. Add 2202.010 attachment 10 SG isolation.

Scenario 5 (4% MOL):

1. MAJOR: LOOP

2. Event 1, reference what procedure is being performed at the very start.

• Procedure referenced at beginning of event in D2

3. Event 3, All Tech Specs must reference the applicable FUNCTIONAL UNITS from the associated tables, for each applicable action statement.

• Added functional unit references in examiner note in Event 3

4. Page 27, the EOP 2202.001, Standard Post Trip Actions title bar is in a weird location.

• Deleted this row, it was extraneous Post-Validation

1. CT3 - Update performance indicator to include AAC DG aligned to a bus as acceptable to meet CT.

2. Correct the points to be bypassed event 3 page 14.

3. OP-2104.037 Att E has undergone new procedure Rev - update steps in examiner guide.

JPM S1:

1. No comments at this time.

JPM S-2:

1. No comments at this time.

JPM S-3:

1. No comments at this time.

JPM S-4:

1. No comments at this time.

Post-Validation

1. Step 6 should say 2B3 not 2B4 JPM S-5:

1. What happens if applicant doesnt start Lift Oil Pump before securing RCP?

• The lift pump is interlocked to automatically start when the RCP breaker opens.

JPM S-6:

1. No comments at this time.

Post-Validation

2. Add Unit is in Mode 3 to I/C JPM S-7:

1. Are CCW Surge tank cross-connects (Surge Tank 2T-37A Drain (2CCW-1022) and Surge Tank 2T-37B Drain (2CCW-1023)) controlled from the control room? If so, back up and start JPM at step 13.10.

• These valves are not operated from the control room. Step 13.10 would just be directing a local operator to close the valves.

2. Why are there 2 handouts for this JPM, that are different Revs?

• Accidently included last handout before procedure change. Only one handout will be given with the most up to date procedure revision. Updated in folder.

3. Make step 3 critical, even though its directing the NLO to perform, if not directed then the system will not be properly aligned.

• Made step 3 critical.

JPM S-8:

1. No comments at this time Post-Validation

2. Reduce scope of JPM to only test either shunt or UV trip.

3. Task standard has a ghost (UV in it.

4. Clarify in the initating cue that applicant is desired to test the shunt trip only.

JPM P-1:

1. Add JPM Complete to examiner cue on steps 14? and 23.

• JPM complete added to step 14 and 23 Post-Validation

1. Add examiner cue step 5, If asked, There is not sufficient time to place standby dryer in service

2. Examiner cue at end, if applicant checks 2PIT-3013 = 100 psig JPM P-2:

1. No comments at this time.

2. For JPM Step 8 (procedure Step 7), for the Examiner Cue for A302 AC Amps, what is the value? It is blank.

• Input normal battery charger 35 amps for this step.

Post-Validation

1. Need picture in place of FME cover

2. Step 6, note that lock is taken from B64-D5 in step 5 and placed on 2B54-G3 JPM P-3:

1. No comments at this time.

ALL ADMIN JPMS COMMENT: For any JPM that the applicant has to use a plot or a form to conduct calculations, include a filled-out key for the examiner to quick-reference.

• Updated: key for A6 JPM A-1:

1. Step numbers are weird in the JPM guide.

• Updated steps in the JPM guide

2. There should be no range for calculating coil current in step 5.a. 7mvdc is given in cue, and dividing by 0.002 Ohms gives an exact answer = 3.5A

• Removed range for step 5.a standard

3. For CEA coil temp range acceptance criteria: if a single of value of 3.5A for I-coil is used, then the Rcoil2 value comes out to 10.618 ohms. Allowing a range of 508.316 to less than 516.649 for temp allows for an applicant to interpolate between the two values if they desire. Anything less than 508 should not be justified though.

• Updated allowable range to 508 to 516.649 JPM A-2:

1. No comments at this time.

Post-Validation

2. Include relevant pages from EN-OP-121 in examiner guide as a reference.

JPM A-3:

1. Add in accordance with the Key to the task standard.

• Updated task standard JPM A-4:

1. Include the required values in the task standard.

• Inserted alarm setpoint and dial setpoint into task standard

Post-Validation

2. Task standard include acceptable value for allowable count rate 540 to 542 CPM.

JPM A-5:

1. Ensure the correct answer range for A-1 and A-5 match each other.

• Updated A-5 range to match A-1 range JPM A-6:

1. Remove #1 from first initiating cue in applicants 1st handout, could be cueing.

• Removed #1 from 1st handout.

2. Include marked up 3.7-1 in key.

• Added a key for Tech Spec Table markup JPM A-7:

1. Include in task standard that 3.7.1.2.E is NOT applicable.

• Updated task standard.

JPM A-8:

1. Include dose values for both operators in task standard.

• Updated Task Standard

2. Include the math being used to calculate total dose for both operators, unless I just missed it.

• Added calculations for examiners note in performance checklist.

3. The task standard seems really general. Normally used to seeing specifics. Doesnt appear to meet App C B.3, which in part states, The JPM must clearly identify the task standard (i.e., the predetermined qualitative or quantitative outcome) against which task performance will be measured.

• Optional Standard change:

• Calculated Joe Mechanics dose (9457 to 9532) and Ralph RPs dose (10428 to 10503). Determined that both Joe Mechanic and Ralph RP can be directed to make entry to stop the release.

• Added Examiner Note: The event in progress meets criteria for exceeding 10CFR20 limits for protection of Large populations. Joe Mechanic can exceed the 5 Rem limit for protecting critical infrastructure necessary for public welfare and Ralph RP can exceed the 10 Rem limit for Protection of large populations.

4. Estimated dose ranges need to be based on some realistic values. Where did the numbers come from? For instance, on Step 1 for Joe Mechanic, realistically, the lowest dose would be 9125 mrem (dose rate divided by time without adding Joes current dose) up to 9507 mrem, current dose + calculated exposure dose). Pretty straightforward calculation, so should there be a range?

• Adjusted range for bands due to rounding to 9457 to 9532 and 10428 to 10503

5. Not sure the 2nd part of the question has enough discrimination to be a satisfactory question. During an emergency, per the procedure, they could complete the task and get over 25 rem, but would have to volunteer. Consider changing results to one over 25 and one under 25 rem for better discriminatory value.

• 10 rem is the discriminatory valve for this JPM. From 5 to 10 rem, entry can be directed for protecting critical infrastructure necessary for public welfare. From 10 to 25 rem, entry can be made for lifesaving or protection of large populations.

This is discriminatory with one person exceeding this limit for protection of a large population.

JPM A-9:

1. No comments at this time.