ML20265A259

Ile Operating Test Outline Comments

ML20265A259
Person / Time
Site:	LaSalle
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: ML20265A235 ML20265A239 ML20265A245 ML20265A252 ML20265A254 ML20265A257 ML20265A259 RA18-100, Ile NOV 2018 Ltr No Comments
References
50-373/18-301, 50-374/18-301, RA18-100 50-373/OL-18, 50-374/OL-18
Download: ML20265A259 (9)

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

Attributes 4

Job Content 5

6 Admin JPMs ADMIN Topic and K/A LOD (1-5)

U/E/S Explanation I/C Cues Critical Scope Overlap Perf.

Key Minutia Job Link Focus Steps (N/B)

Std.

A-SRO-39 COO 2.1.20 2

E NRC: The Technical Specifications should be listed as being required for the JPM setup.

Response

A-SRO-20 COO 2.1.18 2

S A-SRO-68 EC 2.2.17 2

X E

NRC: Fire Protection Impairment Permit given to the applicant for review lists MMD as the work group in section I. Based on the nature of the work and the expected answer key, the work group should be listed as EMD.

Response

A-SRO-37 RC 2.3.4 2

S A-SRO-101 EP 2.4.30 3

X E

NRC: Step 18 indicates the applicant should enter code 20 when contacting IEMA. It appears that LaSalle is code 25 based on page 2 of the NARS form.

Response

A-RO-1 COO 2.1.25 3

X E?

NRC: What are the verifiable actions for the critical steps where the applicant checks or determines something? How is this documented? (GENERIC)

Response

A-RO-46 COO 2.1.5 2

X E?

NRC: What are the verifiable actions for the critical steps where the applicant checks or determines something? How is this documented? (GENERIC)

Response

A-RO-48 EC 2.2.44 2

X E

NRC: Initial conditions 5th bullet is missing the word be preceding 12,500 GPM.

Response

A-RO-47 RC 2.3.5 2

E NRC: Include the limiting LGA-009 conditions in the JPM Standard.

Response

1 Simulator/In-Plant Safety Function and K/A JPMs S-RH-29 4

203000 A4.11 3

S

ES-301 Operating Test Review Worksheet Form ES-301-7 S-MS-06 3

239001 A2.03 2

E NRC: On JPM summary sheet, indicate that this is not an alternate path JPM.

Response

S-RL-01 2

259002 A1.04 2

X E

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

Response

S-RM-02 1

201002 K1.08 2

X E

NRC: Acknowledging a confirmatory pop-up message does not seem to be a Critical Step - suggest combining with step 8.

Response

S-AP-08 6

262001 A2.07 2

E NRC: Please clarify within the guide how each method is arrived at and performed (OV).

Response

S-RH-28 9

272000 A1.01 3

X E

NRC: The LOR given is for the 1B RHR SERV WTR RAD HI. The applicant is shutting down the 1A RHR heat exchanger. The LOR number also does not correspond to step 4 either (B112 vs. B212) and was probably written for the 1A RHR heat exchanger rad monitor.

Response

S-WR-02 8

400000 A4.01 2

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

Response

S-RP-05 7

212000 A4.07 2

X E

NRC: Initial conditions 4th bullet should read, has been checked. Also, this is actually a New (vs. Modified, as the outline indicates) JPM.

Response

P-PC-06 5

223001 A2.07 2

S P-RH-04 4

205000 A2.03 2

X E

NRC: Error message stated with no initial conditions given on paper copy only - possible file error?

Response

P-CY-05 2

295031 EA1.08 3

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

Not provided with review packet.

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 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap U/E/S Explanation 1

S 2

S 3

X X

S 4

S 5

E NRC: No event termination criteria established.

Response

6 X

S 7

X S

8 X

S 9

XX S

10 X

E NRC: In addition to initiate Emergency Depressurization, establish RPV level controlled and in band (provide values) and containment pressure

< (provide value) and being controlled as event termination criteria.

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 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap U/E/S Explanation 1

S 2

S 3

X S

4 S

Note: Verifiable action step for BOP occurs if SRO recognizes ODCM 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

6 X

X E

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 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.

Response

7 X

S 8

X S

9 XXXX E

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

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 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap U/E/S Explanation 1

S 2

S 3

S 4

X S

5 X

S 6

E 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 occurs with power > 20%RTP).

Response

7 X

S 8

S 9

X S

10 X

X S

11 XX X

S E

NRC: Critical task to initiate suppression chamber sprays is not listed in the summary front matter section of the scenario paperwork.

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 Event Realism/Cred.

Required Actions Verifiable actions LOD TS CTs Scen.

Overlap U/E/S Explanation 1

X S

2 S

3 S

4 S

5 X

X U

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 prompting.

Response

6 X

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

Response

7 X

X S

8 S

9 X

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