2CAN042102, 10 AN2-2021-03 Post-Exam Comments

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10_AN2-2021-03 Post-Exam Comments
ML21134A243
Person / Time
Site: River Bend Entergy icon.png
Issue date: 04/16/2021
From: Edwards J
Entergy Operations
To: Thomas Farina
NRC Region 4
References
2CAN042102
Download: ML21134A243 (35)
v • d • e


Text

ANO Unit 2 NRC Initial NRC Written Exam Proposal for Question #80 Allowing Two Correct Answers Page 1 of 3 Proposed justification for accepting two correct answers for Question #80 on the ANO Unit 2 ILO NRC Written Exam administered on 4/8/2021.

The question was given as stated:

Consider the following:

  • Unit 2 has tripped from 100% power due to a loss of all AC power.
  • No AC sources have been recovered.
  • OP-2202.008, Station Blackout, is being implemented.
  • 40 minutes have elapsed.

In accordance with OP-2202.008, Station Blackout, RCS Inventory Control Safety Function will be challenged due to ____(1)____ flow.

In accordance with OP-2202.008, Station Blackout, this challenge to RCS Inventory will require the SM/CRS to ____(2)____ to isolate the flow path.

A. (1) controlled bleedoff (2) Approve and dispatch the WCO to enter Containment B. (1) controlled bleedoff (2) Contact the TSC to coordinate a Containment entry C. (1) minimum letdown (2) Approve and dispatch the WCO to enter Containment D. (1) minimum letdown (2) Contact the TSC to coordinate a Containment entry The original specified correct answer is:

B. (1) controlled bleedoff (2) Contact the TSC to coordinate a Containment entry This proposal is to also accept A as a correct answer based on the following justification.

A. (1) controlled bleedoff (2) Approve and dispatch the WCO to enter Containment

ANO Unit 2 NRC Initial NRC Written Exam Proposal for Question #80 Allowing Two Correct Answers Page 2 of 3 For the given conditions in the stem, the part (1) of the question is correct and this proposed change does not alter the acceptance for the (1) controlled bleedoff part of the correct answer.

For the given conditions in the stem of question 80, OP-1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION revision 59 would have the Shift Manager declare a Site Area Emergency using SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses 2A3 and 2A4 for 15 min.

For part (2) of the correct answer, the applicant feedback during the written exam debrief revealed that the consideration of the given 40 minutes have elapsed was a valid reason to select Approve and dispatch the WCO to enter Containment for the part (2) of the answer since the stem did not specify that the Emergency Response Organization (ERO) was operational at this point in the given scenario.

This coupled with the guidance in NUREG 1021 Appendix E POLICIES AND GUIDELINES FOR TAKING NRC EXAMINATIONS section B.7. which states:

When answering a question, do not make assumptions regarding conditions that are not specified in the question unless they occur as a consequence of other conditions that are stated in the question.

A review of the ANO and Entergy guidance on the ERO being operational is found in the references provided here and show that the ERO which includes the Technical Support Center (TSC) is not assured of being operational until 60 to 90 minutes (reference OP-1903.081 TECHNICAL SUPPORT CENTER (TSC)

ACTIVATION revision 0) after the declaration of the Emergency Action Level of Alert or higher. During an emergency, the on-shift Shift Manager has Emergency Direction And Control per OP-1903.064 EMERGENCY RESPONSE FACILITY - ATTACHMENT 1 - POSITION GUIDE A FOR THE CONTROL ROOM STAFF - SHIFT MANAGER/EMERGENCY DIRECTOR revision 16 section D Step 2.b. which states:

Direct and control the Initial Response Staff (IRS) effort until the Emergency Director (ED) assumes Emergency Direction and Control.

Referring to EN-EP-801 Emergency Response Organization revision 17 Attachment 7 ANO Site-Specific ERO Information, the TSC has a response time of 60-90 minutes after notification and this timing coupled with the guidance in OP-1903.064 supports the reasoning the applicant used to select Answer A as a correct answer.

However, it is reasonable to expect that during certain conditions such as a dayshift with normal staffing of the plant personnel, the ERO, including the TSC, could be operational within the 40 minutes given in the stem. The question worksheet for the administered #80 stated The TSC will be activated at this time as Unit 2 will be in an SAE Eplan classification as the Blackout has lasted greater than 15 minutes.

The proposal to allow two correct answers is supported by the guidance in OP-2202.008 STATION BLACKOUT which provides the guidance in step 28 of revision 17 to:

IF no RCS makeup capability available, THEN CONTACT the TSC concerning a CNTMT Bldg. entry to close RCP Bleedoff Relief Isol (2CV-4856).

ANO Unit 2 NRC Initial NRC Written Exam Proposal for Question #80 Allowing Two Correct Answers Page 3 of 3 Also, OP-1015.021 ANO-2 EOP/AOP USER GUIDE revision 19 provides guidance where the on-shift SRO would apply ATTACHMENT E Procedure Deviations to not perform the step as written in order to take actions necessary to mitigate the event and maintain the safety function.

With two credible correct answers and given that their supporting information does not conflict nor contradict with the ultimate same action taken to address the inventory control safety function. It aligns with the reasonable direction taken by applicants to either: answer based on the guidance in OP-2202.008 or use the guidance in OP-1903.064 and EN-EP-801 considering the timing of the given conditions for activation of the TSC. Both pathways utilize the function of the emergency response organization (either the IRS directed by the SM or ERO personnel directed by the TSC) to perform the required action in the containment building to address the inventory control safety function.

Therefore, the station proposes accepting both A and B as correct answers for question #80.

PROC./WORK PLAN NO.

1903.010 PROCEDURE/WORK PLAN TITLE:

EMERGENCY ACTION LEVEL CLASSIFICATION PAGE: 207 of 243 CHANGE:

059 - Emergency Action Level Technical Bases Category:

S - System Malfunction Subcategory:

1 - Loss of Vital AC Power Initiating Condition:

Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer EAL:

SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to vital 4.16 KV buses A3[2A3] and A4[2A4] for 15 min. (Note 1)

Note 1:

The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2).

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1)

The integrity of the reactor coolant pressure boundary; (2)

The capability to shut down the reactor and maintain it in a safe shutdown condition; (3)

The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Although the AAC may be considered available, it will not prevent declaration of this EAL unless it is powering a vital bus within the 15 minute time period of the EAL.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

Mitigative strategies using non-safety related power sources (FLEX generators, etc.) may be effective in supplying power to these buses. These power sources must be controlled in accordance with abnormal or emergency operating procedures, or beyond design basis

PROC./WORK PLAN NO.

1903.010 PROCEDURE/WORK PLAN TITLE:

EMERGENCY ACTION LEVEL CLASSIFICATION PAGE: 208 of 243 CHANGE:

059 - Emergency Action Level Technical Bases accident response guidelines (e.g., FLEX support guidelines) and must be capable (alone or in combination) of supplying power for long term decay heat removal systems. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC AG1, FG1 or SG1.

This EAL is the hot condition equivalent of the cold condition EAL CA2.1.

Reference(s):

1.

1SAR Figure 8-1 Station Single Line Diagram

2.

OP-1202.007 Degraded Power

3.

OP-1202.008 Blackout

4.

OP-2104.037 Alternate AC Diesel Generator Operations

5.

2SAR Figure 8.3-1 Station Single Line Diagram

6.

OP-2202.007 Loss of Off-Site Power

7.

OP-2202.008 Station Blackout

8.

OP-2107.006 Backfeed of Unit Auxiliary Transformer

9.

NEI 99-01 SS1

PROC./WORK PLAN NO.

1903.081 PROCEDURE/WORK PLAN TITLE:

TECHNICAL SUPPORT CENTER (TSC) ACTIVATION PAGE:

3 of 14 CHANGE:

000 5.0 INSTRUCTIONS 5.1 TSC ACTIVATION 5.1.1 The Emergency Response Organization (ERO) will begin activating following the initial announcement of an Alert, Site Area or General Emergency by the Shift Manager.

5.1.2 The requirement is for the TSC to be operational within 60 -

90 minutes following the declaration of an Alert, Site Area or General Emergency.

5.1.3 The TSC Manager is responsible for ensuring that the TSC is set up in accordance with the guidance established in Form 1903.081A, "TSC Activation Checklist".

5.2 SECONDARY TSC 5.2.1 The Secondary TSC is located in the Emergency Operations Facility (EOF) room 260.

5.2.2 The Secondary TSC is designed to the same radiological habitability as the onsite Control Rooms.

5.2.3 The Secondary TSC is also equipped with the facilities for monitoring the course of an accident.

5.2.4 A floor diagram and activation checklist for the Secondary TSC is included on Form 1903.081B, "Secondary TSC Activation Checklist".

5.3 SECONDARY TSC EVACUATION 5.3.1 IF the Secondary TSC is operational and an EOF evacuation is

ordered, THEN facility staff are to gather plant drawings, maps, logbooks, status reports, and other essential materials and portable equipment or instrumentation (e.g. laptops, etc.) in preparation for evacuation.

5.3.2 IF the Secondary TSC is operational and an EOF evacuation is

ordered, THEN TSC personnel will report to the Alternate EOF located at the Entergy Arkansas, Russellville Office located at 305 South Knoxville Avenue.

PROC. /WORK PLAN NO.

1903.064 PROCEDURE/WORK PLAN TITLE:

EMERGENCY RESPONSE FACILITY - CONTROL ROOM PAGE:

8 of 18 CHANGE:

016 POSITION GUIDE A SHIFT MANAGER / EMERGENCY DIRECTOR (ED)

Page 1 of 6 NOTE Items on this position guide are not necessarily in sequential order.

The user should scan the entire list and prioritize activities as appropriate to the situation, rather than necessarily perform the items in the order listed.

A.

Normal Reporting Location Control Room B.

Reports To Operations Manager C.

Supervises/Coordinates IRS personnel D.

Duties 1.

Immediate Actions a.

IF an emergency class IS declared, THEN notify the Control Room Communicator from the unaffected unit to report to the Control Room.

b.

Ensure at an ALERT/SAE/GE, the operations personnel in the field log onto the Emergency RWP.

c.

Emergency Forms File:

(1)

Procedure Forms:

Form 1903.023B, "Personnel Emergency Checklist (Shift Manager)"

Form 1903.030B, "Plant Evacuation Checklist" Form 1903.011J, "NUE Emergency Direction and Control Checklist" Form 1903.011M, "Alert Emergency Direction and Control Checklist" Form 1903.011P, "SAE Emergency Direction and Control Checklist

- Shift Manager" Form 1903.011S, "GE Emergency Direction and Control Checklist

- Shift Manager" Form 1903.011-Y, "Emergency Class Initial Notification Message" Form 1903.011-Z, "Emergency Class Follow-up Notification Message"

PROC. /WORK PLAN NO.

1903.064 PROCEDURE/WORK PLAN TITLE:

EMERGENCY RESPONSE FACILITY - CONTROL ROOM PAGE:

9 of 18 CHANGE:

016 POSITION GUIDE A SHIFT MANAGER / EMERGENCY DIRECTOR (ED)

Page 2 of 6 2.

Emergency Direction And Control Actions a.

Non-Delegable Responsibilities (1)

Decision to notify offsite authorities (a)

The Arkansas Dept. of Health must be notified within 15 minutes of EACH emergency class declaration using Form 1903.011-Y.

(b)

The Nuclear Regulatory Commission (NRC) must be notified immediately after each notification to the ADH and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of each emergency class declaration using the ENS telephone.

(c)

Follow-up notification to the ADH is required within approximately 30 minutes after an Initial Notification.

(d)

Follow-up notifications to the ADH and NRC should be performed at least hourly or when significant events have occurred using Form 1903.011-Z (ADH) and the ENS telephone (NRC).

(2)

Decision to notify offsite authorities concerning Protective Action Recommendations (PARs)

(a)

The formulation of PARs based on radiological conditions is performed by a Chemist from the Control Room.

(b)

The formulation of PARs based on plant conditions is performed by the Shift Manager or his designee from the Control Room.

b.

Direct and control the Initial Response Staff (IRS) effort until the Emergency Director (ED) assumes Emergency Direction and Control.

c.

IF there are ERO positions within the Control Room that have not been

filled, THEN refer to Desk Guide EP-021, Filling ERO Vacancies During an Event for guidance.

d.

IF ALERT or higher emergency classification, THEN request the Control Room Communicator to notify the ERO in accordance with Form 1903.011-Y.

e.

The Shift Manager has the responsibility for event classification.

Once the ERO is notified, the EOF Technical Advisor responding to the EOF is responsible for informing the individual with Emergency Direction and Control of possible event classification caused by changing conditions.

PROC NO TITLE REVISION PAGE Section 1 2202.008 DG Operations STATION BLACKOUT 017 23 of 85 CAUTION RCP Controlled Bleedoff Flow to the Quench Tank will result in an RCS inventory loss of approximately 4 gpm until RCP Bleedoff Relief Isol (2CV-4856) is closed

28. IF no RCS makeup capability available, THEN CONTACT the TSC concerning a CNTMT Bldg. entry to close RCP Bleedoff Relief Isol (2CV-4856).
  • 29.

CHECK RCS MTS 30°F to 50°F.

  • 29.

PERFORM the following:

A. IF RCS MTS greater than 50°F, THEN:

1) MAINTAIN RCS temperature and allow RCS pressure to lower.
2) GO TO Step 30.

B. IF RCS MTS less than 30°F, THEN INITIATE a cooldown as follows:

1) ENSURE EFW pump 2P7A running.
2) Manually CONTROL EFW to maintain at least ONE SG level 10% to 90% using Attachment 46, Establishing EFW Flow.
3) PERFORM necessary steps of 2105.008, Steam Dump and Bypass Control System Operations, Exhibit 2, Manual Operation of Upstream Atmospheric Dump Valves.
4) RESET Low PZR Pressure and Low SG Pressure setpoints during cooldown and depressurization.
5) IF MTS can NOT be maintained, THEN CONTINUE RCS heat removal using two-phase natural circulation by ensuring the following:

a) Feeding and steaming of SGs.

b) Average CET temperature less than superheated.

4.26 NON-SEQUENTIAL STEPS Procedure steps for which the order of performance within the set of non-sequential steps is unimportant. Non-step number.

4.27 NOTE Statement used to provide supplementary information to the procedure user in interpreting step information or in making decisions.

4.28 OPTIMAL RECOVERY PROCEDURES (ORPs)

Plant specific EOPs written to strategically address a specific set of symptoms. Each set of symptoms usually corresponds to a specific event or class of events (e.g. LOCA, SGTR, etc.) causing the transient or accident.

4.29 PLACEKEEPING PAGE Provides a summary of all high-level steps in a procedure. It also shows the type of step (continuous action or Floating) and gives the page number in the procedure where the step is located. Spaces are provided for the operator to check when a step is completed.

The placekeeping page is located at the end of a procedure, and is printed on a foldout page.

4.30 PROCEDURE DEVIATION Inability to perform the procedure as written is a procedure deviation. In EOP/AOP space the use of procedure deviation takes on added significance. A full discussion of procedure deviations is contained in Attachment E, Procedure Deviations. Note that non guidance contained in this procedure.

ATTACHMENT E Page 1 of 2 PROCEDURE DEVIATIONS For the sake of this discussion, four levels of operating procedure compliance exist:

Simple Verbatim Compliance Following the steps of a single operating procedure as written, with no actions being required from other outside operating procedures.

Example:

FEED and BLEED of Stator Cooling System using 2106.004, Stator Cooling Water System.

Verbatim Compliance is allowed and requires no special controls.

Referencing/Using steps (also known as Parallel Actions)

Performing steps from two or more operating procedures at the same time. One of the operating procedures is typically considered the Controlling Operating Procedure. The concept to be understood under these circumstances is that the Controlling Operating Procedure was written with the knowledge that these other operating procedure actions would occur.

Example:

2102.004, Power Operation contains many steps that direct specific system operations using the appropriate system operating procedure:

ENSURE Seal Steam supply transferred to Unit 2 Main Steam using 2106.013, Gland Seal Steam System.

START EITHER MFP AND commence S/G feed using 2106.007, Main Feedwater Pump and FWCS Operations.

SECURE EFW chemical addition AND vacuum drag to hotwell using 2106.028, Secondary System Chemical Addition.

Example:

2203.037, Loss of DC AOP contains steps that direct specific system operations using the appropriate system operating procedure:

ENSURE at least ONE Charging pump running on Green Train, REFER TO 2104.002, Chemical and Volume Control.

RESTORE Battery Charger to 125v Vital DC bus 2D01 using 2107.004, DC Electrical System Operations.

Parallel actions are allowed and require no special controls. Parallel actions are common in operating procedures, but less common in other procedures.

ATTACHMENT E Page 2 of 2 Procedure Deviations

1. The following are examples of EOP/AOP deviations:

Skipping a step Performing a step out of sequence Performing additional steps Not performing the step as written

2. During the performance of an EOP/AOP it may be necessary to deviate the procedure. A bias toward conservatism should be the overriding factor with regard to this decision.
3. SM and CRS approval is required before performing the deviation.
4. Should the need arise to deviate, the following criteria shall be applied:

The actions are necessary to mitigate the event and maintain the safety function.

The actions are necessary to prevent equipment damage.

The actions are necessary for the safety of Plant personnel.

The actions to be performed will NOT affect the ability to assess the status of the safety functions.

5. As time permits, write a condition report to document the deviation.
6. The expectation is that procedure deviations occur infrequently.
7. The following are examples of what is NOT a deviation:

Performing floating steps or continuous actions steps IAW their intent Prudent actions When action has been initiated to start a step the user can move forward to the next step unless the procedure states, Do Not Continue.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 1 of 18 RO Final Written Examination Analysis and Exam Review The threshold for determination of questions to be analyzed was a percentage of 50%

incorrect responses. We also analyzed other missed questions during the post exam review with the applicants. Those comments and questions during the RO Exam review are listed at the end of this RO Written Examination Analysis and Exam Review.

  1. 12 17/21 total candidates answered incorrectly (81%). Twelve applicants chose A, three chose C and two chose B.

The correct answer is D.

The question asked the following:

Consider the following:

  • Main Feedwater has been lost at full power operations.

NOW

  • Both SG Levels have lowered to the point Once Through cooling Heat removal is needed.
  • The CRS directs performance of LOF EOP Step 15, Once Through Cooling Heat Removal.
  • Step 15 directs actuating SIAS/CCAS AND starting RCS Makeup pumps The reason for initiating the CCAS is to ____(1)____.

Step 15 will require the crew to ENSURE ALL available Charging pumps running AND ENSURE at LEAST ____(2)____ HPSI pumps are running.

A. (1) limit the pressure rise in Containment during Once Through Cooling (2) TWO B. (1) align SW to RCB Fan Coolers since Chill Water flow is isolated by the SIAS (2) THREE C. (1) align SW to RCB Fan Coolers since Chill Water flow is isolated by the SIAS (2) TWO D. (1) limit the pressure rise in Containment during Once Through Cooling (2) THREE The answer for this question comes from OP-2202.006, Loss of Feedwater (LOF) EOP Step 15:

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 2 of 18

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 3 of 18 IF there are NO offsite power issues, Steps 15.E and 15.F directs starting all three HPSI pumps. Two are allowed (one on each safety bus) ONLY if powered by the EDGs (Contingency Action E.2) a). Step G allows a contingency action if NO HPSI pump are running (Contingency Action G.1). In this question no contingency actions were needed, and all three HPSI pumps were available, thus three should be started per Step F. Part 1 in distractors B and C are incorrect because Chill Water flow to the RCB Fan Coolers is isolated by a CIAS NOT SIAS. Therefore, answer D is correct.

Based on feedback from the applicants during the exam review, they were not 100% familiar with all the requirements of this this step from memory and they stated that the words at LEAST in the Part 2 stem could imply that Step 15 could be satisfied with only two HPSI pumps running under normal power alignments. This question and procedure step were reviewed with all the applicants to enhance their knowledge of all the requirements of Step 15. As a recommended enhancement from the applicants, the words at LEAST were deleted from the Part 2 stem of this question in the Master Exam Database for future testing After the review, the applicants agreed this was a valid question with the correct answer. ANO Unit 2 recommends that the answer should NOT be changed AND the question should NOT be deleted.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 4 of 18

  1. 65 12/21 total candidates answered incorrectly (57.0%). Twelve applicants chose A The correct answer is C.

The question asked the following:

Consider the following:

  • Unit 2 is at 100% power.
  • Condensate Pumps 2P2A, 2P2B, and 2P2C are running.
  • Condensate Pump 2P2D is in standby.

NOW

  • Condensate Pump 2P2B trips on over current.
  • MFWP Suction Pressure is 435 psig.

The correct action to take for these conditions will be to ENSURE 2P2D Condensate Pump

____(1)____ using the ____(2)____ procedure.

A. (1) is manually started (2) Annunciator Corrective Actions for 2K03 C-9, OP-2203.012C B. (1) is manually started (2) Loss of Main Feedwater Pump AOP, OP-2203.027 C. (1) automatically starts (2) Annunciator Corrective Actions for 2K03 C-9, OP-2203.012C D. (1) automatically starts (2) Loss of Main Feedwater Pump AOP, OP-2203.027 The answer for this question comes from Annunciator Corrective Actions for 2K03 C-9, in OP-2203.012C and the starting logic for the condensate pumps in Condensate System STM 2-20 Rev. 18 Section 2.3.3.2:

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 5 of 18

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 6 of 18

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 7 of 18 During a Low MFWP suction pressure, the standby pump will automatically start (refer to logic in the STM Section 2.3.3.2 B) on a trip of one Condensate pump with three running due to seeing at least one MFW Pumps running as the MFW pumps do not trip until less 325 psig suction pressure and IAW the directions in Annunciator 2K03 C-9 "MFWP PUMP SUCT PRESS LO" Annunciator Corrective Actions (ACA) Step 2.4, the RO must ensure the standby condensate pump is running and by design should have automatically started. Therefore, answer C is correct.

Based on feedback from the applicants during the exam review, the applicants that missed this question could not remember the exact starting logic for the 2P2D Condensate Pump under the given conditions and thought that a manual start of the pump was correct. This question, procedure and pump starting logic was reviewed with all the applicants to enhance their knowledge of all the automatic starting logic associated with the Condensate pumps.

After the review, the applicants agreed this was a valid question with the correct answer. ANO Unit 2 recommends that the answer should NOT be changed AND the question should NOT be deleted.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 8 of 18

  1. 68 21/21 total candidates answered incorrectly (100.0%). All applicants chose A The correct answer is B.

The questions asked the following:

An instruction or information from Operations Management of continuing applicability (more than overnight or the weekend) to Operations personnel is called a(n) ____(1)____.

Any of these NEW or REVISED instructions are REQUIRED to be reviewed at a MINIMUM with each crew ____(2)____.

A. (1) Standing Order (2) on the first day of a new shift B. (1) Standing Order (2) during each shift turnover C. (1) Operational decision making Issue (ODMI)

(2) on the first day of a new shift D. (1) Operational decision making Issue (ODMI)

(2) during each shift turnover The answer for Part 1 of this question comes from EN-OP-112, Night and Standing Orders Section 3.0 Definitions, Section 5.0 Instructions, and Section 5.4. The answer for Part 2 comes from EN-OP-115-03 Section 5.1 Step 8 and the instruction in the ANO Turnover Sheet:

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 9 of 18

Unit 2 Shift Relief Sheet Computer Generated Form (EN-OP-115-03)

Use the following list as a place keeping tool for review of items for shift turnover. Check off the items applicable to your watch station.

Review appropriate index on first day back and then use the past 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> section. Bold items must be checked before relieving the watch.

ALL: In compliance with all NRC license/fire brigade medical restrictions AND MRO/ Designee has evaluated all new medical conditions / prescriptions (regardless of consumption of medication)

ALL: ENSURE Corrective Lenses (contacts or respirator glasses) used during FIT TEST are immediately available for use, if required.

ALL: Temporary Modification Log ALL: Station Log Review (CR Staff previous 3-days on 1st day back)

SM, CRS, STA, RO: Review Annunciator OOS Log ALL: TS / TRM / ODCM / Review SM: Review the Emergent Issues Log ALL: Standing Orders ALL: Individual improvement item is understood & discussed ALL: Status Board ALL: Clearance/ Caution Tagout Review ALL: Verify Plateau / Nantel / My Learning (beginning of each week)

ALL: Category E Valve Log SM, STA, COMM, CRS: EITER OOS / Comp Measures Log Review ALL: Configuration Control SM, CRS, STA, RO: Board Walk down ALL: Review Procedures in progress SM, STA, COMMUNICATOR: Pager/VOIP phone turnover ALL: ODMs (at beginning of each work week)

STA: Key Log and Key Cabinet Key SM, CRS: Maintenance Schedule CRS / RO: Review OPS-B38 (Nightshift only)

SM: Ensure PCRS Actions not approaching due date RO, NLO: Watch Stander review of OOS logs SM: EN-OP-104 section 8.7.2 review. Update on Sunday Dayshift RO, NLO, FBM: Key Ring COMMUNICATOR: Sign into Inform to check functionality CARRYOVER ITEMS All:

Control Room:

Fire Brigade Waste Control:

Inside AO:

Outside AO:

Communicator:

WORK MANAGEMENT COMMUNICATIONS OWNER DATE ADDED DUE DATE DELAYED SURVEILLANCES WO STATUS/OWNER LOCATION REASON DUE DATE LATE DATE NEW INSTRUCTIONS / PROCEDURE CHANGES CHEMISTRY / RADIOLOGICAL PROTECTION OPPOSITE UNIT IMPACT STANDING ORDERS:

ODM / ACMPS

SUMMARY

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 11 of 18 As described in the procedures and on the last block of the 2nd page of the Unit 2 Relief Sheet, ALL Standing Orders, which are bolded, should be checked before relieving the watch. The words Review appropriate index on the first day back and then use the past 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> section is referring to the STANDING ORDERS block above the last block on the 2nd page of the Unit 2 Relief Sheet which would include any NEW or REVISED Standing Orders that have occurred in the last 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since they were on shift 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ago. Therefore, answer B is correct.

Based on feedback from the applicants during the exam review, the applicants did not fully understand all the turnover requirements associated with Standing Orders. This question and procedures were reviewed with all the applicants to enhance their knowledge of all the turnover requirements associated with Standing Orders.

The applicants did provide feedback that the words on the first day of a new shift could be loosely interpreted as the next shift they come to work on. As a recommended enhancement from the applicants, the word week was added to end of on the first day of a new shift to the part 2 answer in A and C in the Master Exam Database for future testing.

After the review, the applicants agreed this was a valid question with the correct answer. ANO Unit 2 recommends that the answer should NOT be changed AND the question should NOT be deleted.

OTHER COMMENTS OR QUESTIONS DURING THE RO EXAM REVIEW WITH THE CLASS.

  1. 30 5/21 total candidates answered incorrectly (24.0%). All applicants that missed this QID chose C.

The applicants that missed this question said they were somewhat confused by the words makeup water in the part 2 stem. The class suggested changing the words makeup water in the part 2 stem to dilution to be more accurate. This was changed in the Master Exam Database for future testing.

  1. 62 0/21 total candidates answered incorrectly (0.0%).

The class suggested changing the level bands in A and B to 22 to 25% instead of 22 to 26% to more accurately reflect the actual level bands in the plant. This was changed in the Master Exam Database for future testing.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 12 of 18 SRO Final Written Examination Analysis The threshold for determination of questions to be analyzed was a percentage of 50%

incorrect responses. We also analyzed other missed questions during the post exam review with the applicants. Those comments and questions during the SRO Exam review are listed at the end of this SRO Written Examination Analysis and Exam Review.

  1. 77 6/12 total candidates answered incorrectly (50.0%). Six applicants chose C The correct answer is D.

The questions asked the following:

Consider the following:

  • Unit 2 has been shutdown for an outage from 450 EFPD at 100% Power.
  • SDC Train A is in service during a plant cool down.
  • All RCPs have been secured.
  • RCS Thot is 205°F and lowering; Tcold is 201°F and lowering.
  • RCS Pressure is 270 psia and lowering.

NOW

  • Pressurizer level starts dropping rapidly.
  • The CRS enters Loss of SDC OP-2203.029.
  • All available Charging pumps are started.
  • RCS level can NOT be maintained.
  • RCS temperature and pressure start rising.
  • RCS temperature is currently 210°F Thot/Tcold and rising.
  • RCS Pressure is 301 psia and rising.

Based on these conditions, the SDC overpressure protection will be provided by ____(1)____.

Based on the degrading conditions, the Lower Mode Functional Recovery Procedure (LMFRP) EOP is being implemented.

During the LMFRP implementation, the crew will determine the Safety Function Status associated with Plant Condition ____(2)____.

A. (1) Automatic closure of SDC suction isolation valves (2) A: SG Heat Removal with LTOPs B. (1) Automatic closure of SDC suction isolation valves (2) B: SDC in service NOT in Lowered Inventory C. (1) Manual closure of SDC suction isolation valves (2) A: SG Heat Removal with LTOPs

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 13 of 18 D. (1) Manual closure of SDC suction isolation valves (2) B: SDC in service NOT in Lowered Inventory The answer for Part 1 of this question comes from OP-2203.029, Loss of Shutdown Cooling, Step 9 which was correctly selected by all the applicants. The answer for part 2 comes from OP-2202.011, Lower Mode Functional Recovery Procedure, Steps 10, 12 and 14.

OP-2203.029, Loss of Shutdown Cooling, Step 9:

OP-2202.011, Lower Mode Functional Recovery, Step 10, 12 and 14:

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 14 of 18 As described in the procedures and with no automatic closure associated with the SDC RCS Isolation MOVs, the selected SDC RCS Isolation must be manually closed (Part 1). Also based on Step 10 wording Determine plant condition prior to the event which had SDC in service during a plant cool down NOT in LOWERED inventory (level still in the Pressurizer), Condition B should be the plant Conditioned used in step 14 determine the safety function status. Therefore, answer D is correct.

Based on feedback from the applicants during the exam review, the applicants that missed this question could not remember the exact wording of Step 10 of OP-2202.011, Lower Mode Functional Recovery Procedure and since Steam Generators may still be available, then Condition A may still be a viable option. This question and procedures were reviewed with all the applicants to enhance their knowledge of Lower Mode Functional Recovery Procedure and which Condition should be used to access the safety functions After the review, the applicants agreed this was a valid question with the correct answer. ANO Unit 2 recommends that the answer should NOT be changed AND the question should NOT be deleted.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 15 of 18

  1. 85 7/12 total candidates answered incorrectly (58.0%). Two chose A, one chose B, and four chose C The correct answer is D.

The questions asked the following:

Consider the following at 100% power:

  • At 1100 on April 7th, an earthquake is felt onsite.
  • 5 minutes later the National Earthquake Information Center confirms the earthquake occurred nearby at 5.7 on the Richter scale.
  • Unit 1 reports the Seismic Instrumentation recorded a 0.05g earthquake.
  • Primary and secondary plant parameters are stable and normal on both units.
  • At 1115, the CBOT reports that Unit 2 Reactor Containment Building (RCB) pressure has risen from 14.1 to 14.7 psia (atmospheric pressure) over 10 minutes and stabilized.
  • The WCO is directed to close BOTH CNTMT Building CAMS M/U VLVs 2HPA-75/78 to lower RCB pressure to the normal operating band of 13.9 to 14.2 psia.

NOW at 1200

  • RCB pressure is still reading approximately 14.7 psia (atmospheric pressure).
  • RCB pressure and temperature have been verified to be within the limits of T.S 3.6.1.4, Containment Pressure and Temperature for Modes 1, 2, 3 and 4.

Based on these conditions, Unit 2 ____(1)____ AND ____(2)____.

A. (1) CAN maintain 100% power operations (2) Align Service Water to RCB cooling fans to assist in lowering RCB pressure.

B. (1) MUST be placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (2) Stay in Mode 3 and align Service Water to RCB cooling fans to lower pressure.

C. (1) CAN maintain 100% power operations (2) Have Engineering perform EN-DC-356, Post Earthquake Inspection for Damage.

D. (1) MUST be placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (2) Perform a plant cool down to COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The answer for this question comes from TS 3.6.1.1 and 3.6.1.5:

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 16 of 18 Containment is normally maintained in a slight vacuum to prevent a radioactive gaseous release. In this scenario, the earthquake has caused a big enough air leak into containment to raise pressure to normal atmospheric pressure and normal methods of reducing RCB pressure using the Containment Atmosphere Monitoring System (CAMS) have failed to lower RCB pressure for over one hour.

Therefore, Containment structural Integrity has been breached by the earthquake and TS 3.6.1.1, Containment Integrity, and/or TS 3.6.1.15 Containment Structural Integrity Applies. Therefore, answer D is correct.

Based on feedback from the applicants during the exam review, the applicants that missed this question did not tie the rapid rise in containment pressure due to the earthquake to a crack or breach in the containment building and since TS 3.6.1.4 was satisfied, did not adequately analyze any other Technical Specification that may apply to these conditions. This question and TS 3.6.1.1 and 3.6.1.5. were reviewed with all the applicants to enhance their knowledge of Containment Integrity Technical Specifications.

After the review, the applicants agreed this was a valid question with the correct answer. ANO Unit 2 recommends that the answer should NOT be changed AND the question should NOT be deleted.

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 17 of 18 OTHER COMMENTS OR QUESTIONS DURING THE SRO EXAM REVIEW WITH THE CLASS.

  1. 79 2/12 total candidates answered incorrectly (17.0%). The applicants that missed this QID chose B.

The applicants that missed this question said they were somewhat confused by the word secondary at the end of C and D. The class suggested changing the words secondary at the end of C and D to environment to be more accurate. This was changed in the Master Exam Database for future testing.

  1. 80 1/12 total candidates answered incorrectly (8.0%). The applicant that missed this QID chose A.

During the exam review, the applicant that missed this question (Docket Number 55-XXXX) asked how soon can the ERO be manned up and stated that he assumed that the ERO would not be guaranteed to be manned up at 40 minutes into this event. Thus, he assumed the WCO would need to be the one to isolate controlled bleedoff as directed from the on-shift Shift Manager/Emergency Director.

Consider the following:

  • Unit 2 has tripped from 100% power due to a loss of all AC power.
  • No AC sources have been recovered.
  • OP-2202.008, Station Blackout, is being implemented.
  • 40 minutes have elapsed.

In accordance with OP-2202.008, Station Blackout, RCS Inventory Control Safety Function will be challenged due to ____(1)____

flow.

In accordance with OP-2202.008, Station Blackout, this challenge to RCS Inventory will require the SM/CRS to ____(2)____ to isolate the flow path.

A. (1) controlled bleedoff (2) Approve and dispatch the WCO to enter Containment B. (1) controlled bleedoff (2) Contact the TSC to coordinate a Containment entry C. (1) minimum letdown (2) Approve and dispatch the WCO to enter Containment D. (1) minimum letdown (2) Contact the TSC to coordinate a Containment entry Answer:

B. (1) controlled bleedoff (2) Contact the TSC to coordinate a Containment entry

2021 ANO-2 Initial NRC Exam Analysis Report Administered April 8th, 2021 Page 18 of 18 The reason a less than a one-hour time frame was introduced into this question was to prevent a conflict with Section 1 Step 20 of the Station Blackout EOP Procedure OP 2202.008 which directs implementation of FDS-002, Unit 2 Extended Loss of AC Power.

FDS-002 Procedure would align an alternate source of power to the Unit 2 Makeup Charging pumps and eliminate any RCS inventory concern and no containment entry would be needed. The original question came from the master exam bank and had a time duration of 50 minutes. Exam validators suggested changing the time to 40 minutes to get further away from the time frame of step 20.

To enhance this question for future use, a bullet was added to the Master Exam database to state It is Wednesday on Dayshift at 1200 This would allow the possibility of the ERO to staff up within the 40-minute time frame.

After the review, ANO Unit 2 recommends accepting A and B as correct answers to this question AND recommends that the question should NOT be deleted.

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