IR 05000263/2007301

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Er 05000263-07-301 (Drs); 02/12/2007 - 02/19/2007; Nuclear Management Company, LLC; Monticello Nuclear Generating Plant; Initial License Examination Report
ML070680188
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 03/08/2007
From: Hironori Peterson
Division of Reactor Safety III
To: Conway J
Nuclear Management Co
References
50-263/07-301 ER-07-301, IR-07-301
Download: ML070680188 (32)


Text

rch 8, 2007

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT NRC INITIAL LICENSE EXAMINATION REPORT 05000263/2007301(DRS)

Dear Mr. Conway:

On February 19, 2007, the Nuclear Regulatory Commission (NRC) completed initial operator licensing examinations at your Monticello Nuclear Generating Plant. The enclosed report presents the results of the examination which were discussed on February 16 and March 1, 2007, with you and Mr. Earl, respectively, and with other members of your staff.

The NRC examiners administered initial license examination operating tests during the week of February 12, 2007. Members of the Monticello Nuclear Generating Plant Training Department administered an initial license written examination on February 19, 2007, to the applicants.

Four senior reactor operator and four reactor operator applicants were administered license examinations. The results of the examinations were finalized on March 6, 2007. Six applicants passed all sections of their examinations resulting in the issuance of two senior reactor operator and four reactor operator licenses. Two applicants failed the written examination and will not be issued licenses. The applicants who failed the NRC examination were issued proposed license denial letters.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). We will gladly discuss any questions you have concerning this examination.

Sincerely,

/RA/

Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket No. 50-263 License No. DPR-22

Enclosures:

1. Operator Licensing Examination Report 05000263/2007301(DRS)

2. Simulation Facility Report 3. Post Examination Comments and Resolutions 4. Written Examinations and Answer Keys (RO/SRO)

REGION III==

Docket No: 50-263 License No: DPR-22 Report No: 05000263/2007301(DRS);

Licensee: Nuclear Management Company, LLC Facility: Monticello Nuclear Generating Plant Location: Monticello, Minnesota Dates: February 6 through February 19, 2007 Examiners: N. Valos, Chief Examiner B. Palagi, Examiner C. Zoia, Examiner Approved by: Hironori Peterson, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY OF FINDINGS

ER 05000263/2007301(DRS); 02/12/2007 - 02/19/2007; Nuclear Management Company, LLC;

Monticello Nuclear Generating Plant; Initial License Examination Report.

The announced initial operator licensing examination was conducted by regional NRC examiners in accordance with the guidance of NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9.

Examination Summary:

  • Eight examinations were administered (four senior reactor operator and four reactor operator).
  • Six applicants passed all sections of their examinations resulting in the issuance of two senior reactor operator and four reactor operator licenses.
  • Two applicants failed the written examination and will not be issued licenses. The applicants who failed the NRC examination were issued proposed license denial letters.

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA5 Other

.1 Initial Licensing Examinations

a. Inspection Scope

The NRC examiners conducted an announced initial operator licensing examination during the week of February 12, 2007. The facility licensees training staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, to prepare the outline and develop the written examination and operating test. The examiners administered the operating test, consisting of job performance measures and dynamic simulator scenarios, during the period of February 12 through February 16, 2007. The facility licensee administered the written examination on February 19, 2007. Four senior reactor operator and four reactor operator applicants were examined.

b. Findings

Written Examination The NRC examiners determined that the written examination, as originally submitted by the licensee, was within the range of acceptability expected for a proposed examination.

All changes made to the submitted examination were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors.

A total of ten post-examination comments (8 RO; 2 SRO comments) were submitted by the applicants to the facility training department. One of the post-examination comments was associated with a clarification made to a question by the facility during the administration of the examination. Of the ten post-examination comments, the facility agreed with two of the comments. The post-examination comments were submitted to the NRC on February 26, 2007. The results of the NRCs review of the comments are documented in Enclosure 3, Post Examination Comments and Resolutions.

Operating Test The NRC examiners determined that the operating test, as originally submitted by the licensee, was within the range of acceptability expected for a proposed examination.

All changes made to the submitted examination were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors."

Examination Results Six applicants passed all sections of their examinations resulting in the issuance of two senior reactor operator and four reactor operator licenses. Two applicants failed the written examination and will not be issued licenses. The applicants who failed the NRC examination were issued proposed license denial letters.

.2 Examination Security

a. Inspection Scope

The NRC examiners briefed the facility contact on the NRCs requirements and guidelines related to examination physical security (e.g., access restrictions and simulator considerations) and integrity in accordance with 10 CFR 55.49, Integrity of Examinations and Tests, and NUREG-1021, Operator Licensing Examination Standard for Power Reactors. The examiners reviewed and observed the licensees implementation and controls of examination security and integrity measures (e.g.,

security agreements) throughout the examination process.

b. Findings

The licensees implementation of examination security requirements during examination preparation and administration were acceptable and met the guidelines provided in NUREG-1021, Operator Licensing Examination Standards for Power Reactors. No violations of 10 CFR 55.49 occurred during the examination preparation and administration.

4OA6 Meetings

Exit Meeting The chief examiner presented the examination teams preliminary observations and findings with Mr. J. Conway, Site Vice President, and other members of the licensee management on February 16, 2007. A subsequent exit via teleconference was held on March 1, 2007, with Mr. J. Earl, General Supervisor Operations Training, following review of the site post-examination comments. No proprietary items were identified during the administration of the examination nor during the exit meeting with the licensee. The licensee acknowledged the observations and findings presented.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Enclosure 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Conway, Site Vice President
B. MacKissock, Operations Manager
S. Halbert, Training Manager
J. Earl, General Supervisor Operations Training
G. Allex, Supervisor Operations Training - Continuing
O. Olson, Supervisor Operations Training - Initial
J. Ruth, Operations Training

NRC

N. Valos, Chief Examiner
B. Palagi, Examiner
C. Zoia, Examiner
S. Thomas, Senior Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF ACRONYMS

ADAMS Agency-Wide Document Access and Management System

CFR Code of Federal Regulations

CR Condition Report

DRS Division of Reactor Safety

NRC Nuclear Regulatory Commission

PARS Publicly Available Records System

RO Reactor Operator

SRO Senior Reactor Operator

Attachment

SIMULATION FACILITY REPORT

Facility Licensee: Monticello Nuclear Generating Plant

Facility Licensee Docket No.: 50-263

Operating Tests Administered: February 12 through February 16, 2007

The following documents observations made by the NRC examination team during the initial

operator license examination. These observations do not constitute audit or inspection findings

and are not, without further verification and review, indicative of non-compliance with

CFR 55.45(b). These observations do not affect NRC certification or approval of the

simulation facility other than to provide information which may be used in future evaluations.

No licensee action is required in response to these observations.

During the conduct of the simulator portion of the operating tests, the following items were

observed:

ITEM DESCRIPTION

There was one simulator exam scenario delay of approximately 30 minutes on

the morning of February 14, 2007, until three Process Computer screens could

be restored in the simulator. CAP01077256 was written associated with the

issue.

Enclosure 2

Post Examination Comments and Resolutions

Question Number 4

A LOCA is in progress. Both Core Spray pumps are injecting at 3000 gpm each to maintain

RPV water level above the top of active fuel. Which of the below listed plant parameters may

be an indication of pump cavitation in the Core Spray pump(s)?

A. Steadily lowering of Core Spray pump amps

B. Steadily lowering of Core Spray discharge pressure

C. Annunciator 3-A-29 (CORE SPRAY 1 PRESS VLV LEAKING) in alarm

D. Repeated alarming and subsequent clearing of annunciator 3-A-41(AC INTERLOCK)

Answer: D

Applicant Comment:

An applicant commented that answer A should also be accepted as correct.

Answer A should also be accepted. The discharge head of the Core Spray (CS) pumps is

approximately 300 psig. The setpoint for the annunciator alarm AC Interlock is 100 psig. The

stem of the question states both CS pumps are in service. Both CS pumps must be below

100 psig to clear the alarm. Even with severe cavitation, the applicant does not believe that

both CS pumps would drop in discharge pressure at the same time to clear the alarm. Even

though the Bases for C.4-B.04.01G, ECCS Suction Control During LOCA stated that the

alarm may be an indication of ECCS suction plugging, this statement assumed only one CS

pump was running. That was NOT the case in the question stem. Step 1.f of C.4-B.04.01G

stated that the pump motor amperage would be erratic or decreasing for plugging strainer.

Therefore, answer A is the most correct answer.

Facility Proposed Resolution:

The question grading for the exam should not change. The effects of cavitation include

fluctuations in discharge pressure and motor current. This is supported in Lesson Plan

M-8120L-114, Fluid Statics and Dynamics, which was part of the Initial License Training (ILT)

Generic Fundamentals Course. Answer A, Steadily lowering of Core Spray pump amps,

may be an indication of suction plugging, but is not an indication of pump cavitation; the

question asks for indication of pump cavitation.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer.

Enclosure 3

Post Examination Comments and Resolutions

The applicant stated that the Bases for C.4-B.04.01G assumed that only one CS pump was

running, when stating that the AC INTERLOCK alarm may be an indication of ECCS suction

plugging. However, the Bases for C.4-B.04.01G does not stipulate how many ECCS pumps

may be running. The applicant stated that pump motor amperage would be erratic or

decreasing for plugging strainer. Though this is valid, the question did not ask for an indication

of a plugging strainer, the question asked for an indication of pump cavitation in the Core Spray

pump(s). The Bases for C.4-B.04.01G stated that one indication of an ECCS suction strainer

plugging is: Erratic and dramatic fluctuations in pump discharge pressure. One alarm that

may clue the operator to this condition is the alarming and subsequent clearing of AC

INTERLOCK (3-A-41).

The indications that a pump is cavitating include fluctuations in discharge pressure and motor

current. These effects of cavitation are supported in Lesson Plan M-8120L-114, Fluid Statics

and Dynamics, which was part of the Initial License Training Generic Fundamentals Course.

Per Lesson Plan M-8120L-114, the indication specified in distractor A, Steadily lowering of

Core Spray pump amps, is not an indication of cavitation of the CS pumps. Since distractor

D, Repeated alarming and subsequent clearing of annunciator 3-A-41(AC INTERLOCK),

provided the only indication of pump cavitation of the CS pumps, distractor D was retained as

the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 17

During a Reactor startup, when do plant conditions support the design limitations of the Reactor

Water Level Control System allowing it to be placed in 3 Element Control?

A. When the first Feedwater Control Valve is placed in automatic.

B. When the Master Feedwater Level Controller is placed in automatic.

C. When the second Feedwater Control Valve is placed in automatic.

D. When feedwater flow is sufficient to clear Reactor Recirc pump low flow interlock.

Answer: C

Applicant Comment:

An applicant commented that answer D should also be accepted as correct.

Answer D should also be accepted as correct. Ops Manual B.05.07-01, Reactor Level

Control states that the steam and feedwater flow signals lose their accuracy below 30% power.

Also, on page 7 of B.05.07-01, it states that a separate single element control scheme is used

when reactor power is less than 20% of rated. The question asked per design limits of the

water level control system, when can the Digital Feedwater Control System (DFCS) be placed

in 3 element control. The 3 element would work at greater than 20% feed flow and with one

Feedwater Fegulating Valve (FRV) in service. Although the start up procedure C.1, places

the DFCS in 3 element control at approximately 40% power and after the second FRV is in

service, the design of DFCS allows it to be placed in service with feedwater greater than 20%

per its design.

Facility Proposed Resolution:

The question grading for the exam should not change. Per Ops Man B.05.07-01, Steam flow

and feedwater flow signals (used in three-element control) lose their accuracy below 30%

power and, therefore, become less desirable as controlling inputs. Answer C (exam correct

answer) is the only choice describing an action above 30% power. The conditions cited by the

applicant with feedwater greater than 20% are for transition from the Feedwater Low Flow

Regulating Valve to the Main Regulating Valves.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer. Ops Manual B.05.07-01, Reactor Level

Control states that the steam and feedwater flow signals lose their accuracy below 30% power.

Both the steam and feedwater flow signals are used when in 3 Element Control.

Enclosure 3

Post Examination Comments and Resolutions

The design limitations of the Reactor Water Level Control System would not allow placing 3

Element Control in service with inaccurate steam and feedwater flow signals. The applicant

also stated that a separate single element control scheme is used when reactor power is less

than 20% of rated power. However, this statement is related to control of the Feedwater Low

Flow Regulating Valve, not to 3 Element Control of the Main Feedwater Regulating Valves.

Thus, distractor D, When feedwater flow is sufficient to clear Reactor Recirc pump low flow

interlock, which occurs at approximately 20% reactor power would not be a correct answer.

Since, per C.1, Reactor Startup, at approximately 40% power, the second Main Feedwater

Regulating Valve is placed in service, and then Reactor Level Control is transferred to 3

Element Control, distractor C was retained as the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 20

What would be the effect on 4.16 KV breaker operation if all D.C. control power is lost?

Breaker operation with the control switch would be lost to

A. all 4.16 KV breakers.

B. all 4.16 KV breakers EXCEPT for buses 13 and/or 14.

C. all 4.16 KV breakers EXCEPT for buses 15 and/or 16.

D. all 4.16 KV breakers EXCEPT for buses 17 and/or 18.

Answer: D

Applicant Comment:

An applicant commented that answer A should also be accepted as correct.

A clarification was made to question 20 which changed the acceptable answer. Without the

clarification, answer D would be correct since the 17 and 18 buses use AC control power and

are not affected by loss of DC control power. However, the proctor stated to add Control

Room Control Switch to the stem of the question. Since there are no bus 17 or bus 18 control

switches in the control room, there would be no control switches that could operate 4 KV

breakers in the control room due to the loss of all DC control power. This would make answer

A the only correct answer. Based upon whether a student already completed the question or

did not apply the additional verbal clarification, then both answer A and D should be

accepted.

Facility Proposed Resolution:

The question grading for the exam should be changed to accept both A and D as correct

answers. This is due to the information given during exam implementation, as stated above,

that changed the intent of the question. This question is correct, as written, and does not

require any changes prior to incorporation into the exam bank.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept the facilitys comment and accept both answer A and D as correct

answers.

During the administration of the examination, a question was asked by an applicant as to which

control switch the question stem was referring to (i.e., the control switch in the Control Room or

Enclosure 3

Post Examination Comments and Resolutions

at the breaker). The facility provided a clarification that the question stem was asking Breaker

operation with the Control Room control switch would be lost to, with the words underlined

added for clarification. This clarification of the question was communicated to all of the

applicants. The clarification provided changed the intent of the question. Buses 17 and 18 are

in the plant discharge structure, with control power supplied alternating current (AC) from one of

two control power transformers. There are no bus 17 or bus 18 control switches in the control

room.

In answering the clarified question, since there are no bus 17 or bus 18 control switches in the

control room, there would be no control switches that could operate 4.16 KV breakers in the

control room due to the loss of all DC control power. This would make distractor A, all

4.16 KV breakers, a correct answer. However, in answering the clarified question, distractor

D is still correct, since there are no control room switches for bus 17/18 breakers. Distractors

A and D thus reduce to the same answer all 4.16 KV breakers. Therefore, the answer key

was modified to accept both A and D as correct answers.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 31

A plant transient was in progress with the following conditions present:

- D/W pressure 15 psig and rising

- D/W temperature 285°F and rising

- RPV water level -175 inches and slowly lowering

- RPV pressure 850 psig

- All Control rods are fully inserted

- EOPs 1100 and 1200 have been entered and are being executed

- The SAMGs have not been entered

- Drywell spray is directed to be placed in service

Which of the following predicts the impact on Drywell temperature and why?

A. Drywell temperature would continue to rise; Drywell Spray is NOT ALLOWED as plant

conditions are outside the Drywell Spray Limit curve.

B. Drywell temperature would lower; as Drywell Spray IS ALLOWED to be initiated by

placing the Containment Spray/Cooling LPCI Initiation switch in Bypass and opening the

Drywell Spray inboard and outboard isolation valves.

C. Drywell temperature would continue to rise since neither Drywell Spray inboard or

outboard isolation valve is allowed to be opened under these plant conditions.

D. Drywell temperature would lower as drywell spray is allowed to be initiated by placing

both the Containment Spray 2/3 Core Height Bypass and Containment Spray/Cooling

LPCI Initiation switches in BYPASS, and then opening the Drywell Spray inboard and

outboard isolation valves.

Answer: C

Applicant Comment:

An applicant commented that answer D should also be accepted as correct.

Answer D should also be accepted. The RHR logic allows drywell sprays to be placed in

service after bypassing the 2/3 core height interlock and the Containment Spray(CS)/Cooling

Low Pressure Coolant Injection (LPCI) initiation switch. Although the Drywell (DW) spray

procedure (Part C of procedure Ops Man C.5-3502, Drywell Spray - RHR-A) stated that this

should be done when in the Severe Accident Management Guidelines (SAMGs), the logic would

allow answer D to be correct. The applicant assumed other pumps (like High Pressure

Coolant Injection and CS) were available to recover level. The basis did state DW spray and

injection can be alternated to provided adequate cooling. Therefore, answer D also correctly

answered the question.

Facility Proposed Resolution:

Enclosure 3

Post Examination Comments and Resolutions

The question grading for the exam should not change. Site procedures, other than SAMGs, do

not allow bypassing of the interlock for DW spray; the question states The SAMGs have not

been entered. Although system design provides the means to bypass the interlock with the

given conditions, utilization is clearly not allowed by site procedure.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer.

The question asks, for a given set of conditions during a plant transient, to predict the impact on

Drywell temperature and why? Distractor D states Drywell temperature would lower as

drywell spray is allowed to be initiated by placing both the Containment Spray 2/3 Core Height

Bypass and Containment Spray/Cooling LPCI Initiation switches in BYPASS, and then opening

the Drywell Spray inboard and outboard isolation valves. Procedure Ops Man C.5-3502 only

allows placing the Containment Spray 2/3 Core Height Bypass switch to MANUAL OVERRIDE

and the Containment Spray/Cooling LPCI Initiation switch in BYPASS, if required to spray the

containment by the SAMGs. The question stem states The SAMGs have not been entered.

Although system design provides the means to bypass the interlock with the given conditions,

bypass of the interlock is clearly not allowed by site procedure. Therefore, distractor C was

retained as the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 46

With the reactor operating steady state in MODE 1, what effect, if any, will a loss of instrument

air have on the Reactor Building to Suppression Pool Vacuum Relief Dampers, AO-2379 and

AO-2380?

A. These valves would fail OPEN.

B. These valves would fail CLOSED.

C. No effect as these valves are normally aligned to air and use nitrogen as a backup

supply.

D. No effect as these valves are normally aligned to nitrogen and use bottled nitrogen as a

backup supply.

Answer: D

Applicant Comment:

An applicant commented that answer C should also be accepted as correct.

Answer C should also be accepted. Loss of the instrument air will have no effect on the

valves. Therefore, the first part of the question was true. As to the alignment, instrument air is

normally aligned to the system, but pressure set points have this valve closed (CV-7478). The

valve would automatically open if a problem existed with the Instrument Nitrogen system. The

second part of answer C states that nitrogen is used as a backup supply. This is true.

Alternate Nitrogen is used as the backup supply for these valves. Therefore, answer C is

technically correct also.

Facility Proposed Resolution:

The question grading for the exam should not change. As stated in the applicant comment

above, valve CV-7478, in its normal plant operating status, blocks instrument air from the

supply line leading to the Vacuum Relief Dampers; therefore, the Vacuum Relief Dampers are

NOT normally aligned to air as distractor C stated. Answer D is the only correct answer.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer. The normal supply to the Reactor Building

to Suppression Pool Vacuum Relief Dampers (AO-2379 and AO-2380) is the Instrument

Nitrogen supply from the Liquid Nitrogen Tank (reference drawing NH-36049-12). Bottled

nitrogen from the Alternate Nitrogen System is the first backup supply to the Vacuum Relief

Dampers (reference drawing NH-36049-10). The Instrument Air system supplies a secondary

Enclosure 3

Post Examination Comments and Resolutions

backup supply to the Vacuum Relief Dampers via valve CV-7478, which opens on low nitrogen

header supply pressure (reference drawing NH-36049-12). Therefore, the Vacuum Relief

Dampers are not normally aligned to air as distractor C stated. Distractor D, No effect as

these valves are normally aligned to nitrogen and use bottled nitrogen as a backup supply,

properly described the pneumatic supply to the Vacuum Relief Dampers, and distractor D was

retained as the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 59

The reactor was operating at rated conditions when the following events occurred: (Assume

SPDS is NOT available)

- 0700: 5-B-46 (CONDENSER LOW VACUUM) alarm was received

- 0705: 7-B-16 (VAC 24 IN TRIP #1) alarm was received

- 0705: 7-B-17 (VAC 24 IN TRIP #2) alarm was received

- 0708: PR-1264, CONDENSERS A AND B VACUUM, on C-07 indicated 6.1 Hg Abs.

- 0710: PR-1264, CONDENSERS A AND B VACUUM, on C-07 indicates 7 Hg Abs. and

remains stable

Given the above information, when is the EARLIEST time a manual Reactor Scram is required

to be initiated?

A. 0721

B. 0726

C. 0729

D. 0731

Answer: C

Applicant Comment:

An applicant commented that answer B should also be accepted as correct.

Answer B should also be accepted. Annunciators 7-B-16 and 7-B-17 alarm at 24 inches. By

typical engineering convention atmospheric pressure is 30 inches. Therefore, absolute

pressure in the condenser would be 6 inches Hg Abs, which would place one in the ALERT

region of Figure 1 at time 0705, requiring a scram 20 minutes later. Although procedure

Ops Man C.4-B.06.03.A, Decreasing Condenser Vacuum, stated that the operator should use

recorder PR-1264 when the Safety Parameter Display System (SPDS) was not available,

scramming the reactor at time 0729 would be 21 minutes later, which would not be in

accordance with the C.4-B.06.03.A procedure.

Facility Proposed Resolution:

The question grading for the exam should not change. The referenced procedure,

C.4-B.06.03.A, Decreasing Condenser Vacuum, under INDICATIONS, listed the annunciator 7-B-16 and 7-B-17 alarm setpoints of 24 Hg Vacuum as being equivalent to approximately

5" Hg Abs on recorder PR-1264; this procedure would override the stated typical engineering

convention. The procedure also required a reactor scram when in the ALERT region for

Enclosure 3

Post Examination Comments and Resolutions

longer than 20 minutes, therefore scramming at T+21 minutes is in accordance with the

C.4-B.06.03.A procedure.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer. Procedure Ops Man C.4-B.06.03.A,

Decreasing Condenser Vacuum, step 2.a under INDICATIONS, listed the annunciator 7-B-16 (VAC 24 IN TRIP #1) and 7-B-17 (VAC 24 IN TRIP #2) alarm setpoints of 24 Hg

(inches of Mercury) Vacuum as being equivalent to approximately 5 Hg Abs (Absolute) on

recorder PR-1264. Thus at time 0705, when the alarms for annunciators 7-B-16 and 7-B-17

were received, the plant was not in the ALERT region of Figure 1, Turbine Exhaust Pressure

Limits, of Ops Man C.4-B.06.03.

A. For the reactor at rated conditions, as stated in the

question stem, the ALERT region of Figure 1 extended from a Turbine Exhaust Pressure of

6.0" Hg Abs to 7.5" Hg Abs. (NOTE: Figure 1 was provided to the applicant with the

examination.)

Procedure C.4-B.06.03.A stated that the operator should use recorder PR-1264 when the

Safety Parameter Display System (SPDS) was not available (the question stem stated that

SPDS was not available). The first instance at which the plant was in the ALERT region was

at time 0708 when it was given in the question stem that recorder PR-1264, CONDENSERS A

AND B VACUUM, on C-07 indicated 6.1 Hg Abs. Since the C.4-B.06.03.A procedure required

a reactor scram when the plant was in the ALERT region for longer than 20 minutes, time

29 (as specified in distractor C) was the earliest time at which a manual Reactor Scram was

required to be initiated in accordance with the procedure (when the plant was in the ALERT

region for 21 minutes).

The applicant stated that distractor B should also be accepted as a correct answer. He stated

that by typical engineering convention atmospheric pressure is 30" Hg. Since annunciators 7-B-16 and 7-B-17 alarm at 24" Hg Vacuum, the absolute pressure in the condenser would be

6" Hg Abs when annunciators 7-B-16 and 7-B-17 alarmed. This would place one in the

ALERT region of Figure 1 at time 0705, requiring a scram 20 minutes later. The applicant

stated that since distractor B was time 0726 (21 minutes after time 0705), this would make

distractor B a correct answer.

However, procedure C.4-B.06.03.A listed the annunciator 7-B-16 and 7-B-17 alarm setpoints of

Hg Vacuum as being equivalent to approximately 5 Hg Abs on recorder PR-1264 (and not

Hg Abs), which provided a more accurate representation of the absolute pressure

corresponding to 24" Hg Vacuum on recorder PR-1264 than that provided by the estimate of 6"

Hg Abs per typical engineering convention. The applicants were also provided with a book of

Steam Tables in which the conversion factor of 2.0360 was given for obtaining pressure in

inches of Hg from a pressure specified in pounds per square inch (psi). Using this

conversion factor, a pressure of 14.7 psig would correspond to 29.93 Hg Abs (since Monticello

is at approximately the 935 foot elevation above sea level, the nominal atmospheric pressure at

the site would actually be reduced to approximately 14.25 psig or 29.0" Hg Abs per Marks

Enclosure 3

Post Examination Comments and Resolutions

Standard Handbook for Mechanical Engineers). Using the high end value of 14.7 psig

(29.93" Hg Abs) for the pressure corresponding to atmospheric pressure at the Monticello site,

when annunciators 7-B-16 and 7-B-17 alarmed at 24" Hg Vacuum, this would correspond to a

pressure of 5.93" Hg Abs (NOTE: 24" Hg Vacuum would correspond to 5.0" Hg Abs for the

elevation at the Monticello site). Both the values of 5 Hg Abs (on recorder PR-1264) and 5.93"

Hg Abs (from the calculation described above) would place one below the ALERT region entry

of 6" Hg Abs (i.e., in the ALLOWABLE OPERATION region) of Figure 1. Therefore, the

procedural requirement to scram when in the ALERT region for longer than 20 minutes would

not begin when annunciators 7-B-16 and 7-B-17 alarmed at time 0705. Therefore, distractor

B is not a correct answer, and distractor C was retained as the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 62

While performing test 0081 (CONTROL ROD DRIVE SCRAM INSERTION TIME TEST) the

incorrect control rod was withdrawn from position 14 to 48. The crew recognized the error.

What action is required to ensure adequate margin to fuel thermal limits exists?

A. Notify Reactor Engineering to run a predictor and provide a recovery plan.

B. Obtain fuel thermal limit information before any rod recovery is performed.

C. Insert the control rod to its previous position without obtaining information on fuel

thermal limits.

D. Fully insert the control rod to position 00 and obtain further guidance from Reactor

Engineering.

Answer: C

Applicant Comment:

An applicant commented that answer D should also be accepted as correct.

Answer D should also be accepted as correct. Ops Manual B.01.03-05 H.10, Inadvertent

Control Rod Withdrawal/Rod Drift Out is used for an inadvertent control rod withdrawal/rod drift

out which is the condition in the question stem. This procedure stated that if annunciator 5-A-19, ROD SELECT BLOCK TIMER MALFUNCTION was not in alarm (which would be the

case in accordance with the question stem), then to immediately insert the rod to position 00

using normal or emergency insert.

Facility Proposed Resolution:

The question grading for the exam should not change. The question asked for the required

action following a control rod mispositioning event. The correct answer C was to Insert the

control rod to its previous position without obtaining information on fuel thermal limits this is per

site procedures. The applicants missed this question for various reasons, not recognizing the

procedural guidance for a control rod inadvertently withdrawn due to operator error, and

specifically, for expediting return of the rod to its original position. Distractor D would not be a

correct action response to the given event; with no equipment problems, there is no reason to

insert the control rod further than its original position. A NOTE in the same procedure step

referenced in the applicant comment stated In this case the timer malfunction circuit is

deficient; this reinforces that this is the incorrect procedure for this event. CAP 01078752 has

been initiated to reinforce practical training on this type of event and to clarify procedural

guidance.

Enclosure 3

Post Examination Comments and Resolutions

It is recommended that the wording for the correct answer be revised to state:

Insert the control rod to its previous position prior to obtaining information on fuel thermal limits.

The current wording could be implied to mean that fuel thermal limits would not be checked

even after rod re-positioning.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer. The applicant stated that the correct

procedure to use for the conditions stated in the question stem was Ops Manual

B.01.03-05 H.10, Inadvertent Control Rod Withdrawal/Rod Drift Out, since this procedure is

used for an inadvertent control rod withdrawal/rod drift. However, the Bases for the procedure

states that the procedure is used for inadvertent control rod withdrawal or rod drifting during

notch-out movement, for the situation where the rod continues to withdraw past the desired

notch at the normal speed or drifts out with a slow erratic movement. These conditions were

not those stated in the question stem.

The question was associated with a situation in which the incorrect control rod was withdrawn

from position 14 to 48, with the crew subsequently recognizing that the wrong control rod was

withdrawn. For this situation, procedure Ops Manual B.01.05-05, Section 3, Recovery From an

Inadvertent Control Rod Withdrawal was the correct procedure to use. In this procedure, the

control rod that was inadvertently withdrawn is inserted to its previous position without obtaining

information on fuel thermal limits. The Bases for this procedure states that check thermal

margins prior to inserting the mispositioned rod would result in an unnecessary delay in

returning the reactor to its desired configuration. Therefore, distractor C, Insert the control

rod to its previous position without obtaining information on fuel thermal limits, was retained as

the only correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 70

Which of the following describes the MCPR safety limit?

A. With the reactor steam dome pressure < 785 psig AND core flow < 10% rated core flow:

Thermal Power shall be 25% RTP.

B. With the reactor steam dome pressure < 785 psig OR core flow < 10% rated core flow:

Thermal Power shall be 25% RTP.

C. With the reactor steam dome pressure 785 psig AND core flow 10% rated core flow:

MCPR shall be 1.12 for two recirculation operation or 1.10 for single recirculation

loop operation.

D. With the reactor steam dome pressure 785 psig OR core flow 10% rated core flow:

MCPR shall be 1.12 for two recirculation operation or 1.10 for single recirculation

loop operation.

Answer: B

Applicant Comment:

An applicant commented that there is no correct answer.

There was no correct answer. Answer B is a Reactor Core Safety Limit (SL) (or conditions) at

which Minimum Critical Power Ratio (MCPR) limits do not apply. It is NOT the MCPR limit. The

MCPR limits are 1.10 for two loop operations or 1.12 for single loops operations. The first two

distractors (A and B) only identifed when MCPR limits may or may not apply. The question

specifically asked which of the following described the MCPR safety limits, NOT when the

MCPR limits did not apply. The applicant thought the values were reversed in the chosen

answer, and went with it, because the first two distractors (A and B) did not answer the

question.

Facility Proposed Resolution:

The question grading for the exam should not change.

The Bases for the Reactor Core SLs, BACKGROUND, states that the limits of 2.1.1.1, Fuel

Cladding Integrity, provide a margin to the conditions that would produce onset of transition

boiling (i.e., MCPR = 1.00).

In the APPLICABLE SAFETY ANALYSES of Technical Specification Section B2.1.1.1,

Reactor Core SLs (the Bases for Safety Limits), the following is stated: The fuel cladding must

not sustain damage as a result of normal operation and Anticipated Operational Occurrences

(AOOs). The reactor core SLs are established to preclude violation of the fuel design criterion

Enclosure 3

Post Examination Comments and Resolutions

that a MCPR limit is to be established, such that at least 99.9% of the fuel rods in the core

would not be expected to experience the onset of transition boiling.

The argument in the applicant comment contradicts these statements in the Bases.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to delete the question from the examination. The question asked Which of the

following describes the MCPR safety limit? In the Bases for the Reactor Core SLs

(Section B 2.1.1), the terminology MCPR SL is only associated with reactor core SL 2.1.1.2,

which is:

2.1.1.2 With the reactor steam dome pressure 785 psig and core flow 10% rated

core flow:

MCPR shall be 1.10 for two recirculation operation or 1.12 for single

recirculation loop operation.

The above definition of the MCPR SL is not associated with any of the distractors.

In Section B 2.2.1.1, distractor B (the original correct answer) is associated with reactor core

SL 2.1.1.1, Fuel Cladding Integrity. The BACKGROUND for the Bases for the Reactor Core

SLs, does state that the fuel cladding SL is defined with a margin to the conditions that would

produce onset of transition boiling (i.e., MCPR = 1.00). However, the Bases does not define

Section 2.1.1.1 as representing the MPCR SL. Only section 2.1.1.2 in the Bases is defined as

representing the MPCR S

L. Therefore, there is no correct answer, and it was decided to

delete the question from the examination.

NOTE: The facility was contacted about the NRC Resolution stated above. The licensee

acknowledged the NRC Resolution.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 79

The reactor was operating in MODE 1 with the following conditions present:

- 11 Instrument Air Compressor, K-1A, is in LEAD

- 14 Instrument Air Compressor, K-1D, is in STBY

- 13 Instrument Air Compressor, K-1C, is taggout out for routine maintenance

- It is the 1900-0700 shift

- The Clearance Order Holder is NOT on site

- Instrument air pressure is 95 psig

If K-1A fails and K-1D is determined to NOT be able to maintain long term instrument air header

pressure above the low pressure alarm point, what actions are required for the CRS to direct

the removal of Danger Tags and place K-1C in service? (Assume instrument air pressure is

lowering 1 psig per 30 minutes.)

A. Immediately sign off the Clearance Order Holder(s) and direct the tags be removed.

B. With concurrence of the Shift Manager, immediately sign off the Clearance Order

Holder(s) and direct the tags be removed.

C. Attempt to contact the Clearance Order Holder(s) and if they cannot be reached, direct

the tags be removed.

D. Attempt to contact the Clearance Order Holder(s) and if they cannot be reached, and

with permission from the WCC, direct the tags be removed.

Answer: C

Applicant Comment:

An applicant commented that answer D should also be accepted as correct.

Per procedure FP-OP-TAG-01, Fleet Tagging, the Note in section 3.7 stated that Ops Shift

Supervision may be carried out by an Senior reactor Operator (SRO) or persons designated by

Ops Management in the Work Control center (WCC) acting for Ops shift supervision, provided

the operating crew is kept informed and involved in decisions, when necessary. Ops Shift

Supervision and the WCC should be considered to be the same. WCC personnel hours are

different than the shift schedule and the WCC person would be there at some time during the

shift. Since, in answer D, the applicant asked for the WCC permission, this told the applicant

the applicant that a WCC person was available to perform the task. For normal day to day

operation at the plant, as the CRS, the applicant stated that he would direct the WCC person to

perform the necessary actions and have the tags removed; at a minimum, since most work

started and ended with the WCC, the applicant stated that he would seek their concurrence

and/or permission.

Enclosure 3

Post Examination Comments and Resolutions

Facility Proposed Resolution:

The question grading for the exam should not change. The question specifically asked for

actions required for the CRS to direct removal of the tags and place the unit in service.

Although the WCC may also perform these actions, and the WCC may be communicated with

prior to the CRS performing these actions, distractor D is incorrect as the permission of the

WCC is not required.

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to accept only the original correct answer. The question asked what actions are

required for the CRS to direct the removal of Danger Tags for the K-1C Instrument Air

Compressor, in order to place the K-1C compressor in service, during a condition where

instrument air pressure is lowering, no other Instrument Air Compressor is available, and the

Clearance Order Holder is not on site.

An applicant commented that distractor D should also be accepted as the correct answer.

The applicant stated that he would seek the WCC concurrence and/or permission prior to

directing that the Danger Tags be removed, since for normal day to day operation at the plant,

as the CRS, the applicant stated that he would direct the WCC person to perform the necessary

actions and have the tags removed, since most work started and ended with the WCC. The

applicant also stated that he assumed (based on the the description provided in distractor D

about obtaining permission from the WCC) that a WCC person was available to perform the

task.

However, the question specifically asked for the actions required for the CRS to direct removal

of the tags and place the compressor in service. Although the WCC, if available, may also

perform the actions to contact the Clearance Order Holder(s) and if they cannot be reached,

direct the tags be removed, and the WCC may be communicated with prior to the CRS

performing these actions, distractor D is incorrect as the permission of the WCC is not

required to perform these actions. The applicant also stated that he assumed (based on the

the description provided in distractor D about obtaining permission from the WCC) that a

WCC person was available to perform the task. The question stem stated that it was the

1900-0700 shift. The availability of the WCC was a condition not specified in the question

stem. In NUREG-1021, Appendix E, Policies and Guidelines for Taking NRC Examinations, it

stated, in part, that When answering a question, do not make assumptions regarding

conditions that are not specified in the question .... The applicants were briefed verbatim on

the contents of NUREG-1021, Appendix E prior to the administration of the written examination,

and were provided a copy of Appendix E. The applicants did not ask for a clarification of the

question during the administration of the written examination. Since there was no discussion in

the question stem concerning the availability of the WCC, and since permission of the WCC is

not required to perform these actions (to contact the Clearance Order Holder(s) and if they

cannot be reached, to direct the tags be removed), distractor B was retained as the only

correct answer.

Enclosure 3

Post Examination Comments and Resolutions

Question Number 87

During an ATWS event with SBLC injecting, the OATC reports SBLC tank level indicates

400 gallons. Predict the impact of this SBLC system condition on the plant and what actions

you would direct as CRS associated with this SBLC condition?

A. The reactor cannot be determined to be shutdown under all conditions, refill the SBLC

tank with boron solution.

B. Reactor depressurization can begin as Hot Shutdown Boron Weight has been achieved,

secure the SBLC pump.

C. The reactor will remain shutdown under all conditions, secure the SBLC pump when

level indicates 0 inches.

D. RPV water level must be retained between -126 inches and -33 inches until Cold

Shutdown Boron Weight has been achieved, secure the SBLC pump when level

indicates 0 inches.

Answer: C

Applicant Comment:

The applicant recommended removal of this question from the examination due to there being

no correct answers.

The applicant stated that Answer A was the most correct, since there is procedural direction to

refill the Standby Liquid Control (SBLC) tank with boron. Answer B was not correct, because

Cold S/D Boron weight is required to depressurize. Answer C was not correct, because

securing SBLC pump when reactor level indicates 0 inches was wrong. Securing the SBLC

pump had nothing to do with Reactor Level. Answer D was not correct, because Hot S/D

Boron weight is required to raise level and securing the SLBC pump had nothing to do with

Reactor Level at 0 inches.

Facility Proposed Resolution:

The question should be removed from the exam due to there being no correct answer as

worded. The correct answer C, as stated on the exam, stated secure SBLC pump when

level indicates 0 inches. This was not specific as to which level indicated 0 inches. The

SBLC level instruments are in units of gallons, not inches. These inconsistencies could lead

the applicants to assume that the level indication was referencing reactor water level. In this

case, there was no correct answer.

The question should be revised, such that the correct answer states when SBLC tank level

indicates 0 gallons, prior to inclusion to INPO Exam Bank.

Enclosure 3

NRC Resolution:

Upon review of the question, the applicant comment, and the facility proposed resolution, it was

decided to delete the question from the examination. The original correct answer (distractor

C) stated secure SBLC pump when level indicates 0 inches. However, as described by

the applicant and the facility, this statement was not specific as to which level indicated

inches. The SBLC level instruments are in units of gallons, not inches. This inconsistency

of units could lead the applicants (as per the applicant comment) to assume that in distractors

C and D, the level indication specified of 0 inches was referencing reactor water level, and

not a SBLC tank level of 0 gallons. In any case, distractor C is incorrect as written to state to

secure the SBLC pump when level indicates 0 inches instead of secure the SBLC pump

when level indicates 0 gallons. Therefore, there is no correct answer, and it was decided to

delete the question from the examination.

Enclosure 3

WRITTEN EXAMINATIONS AND ANSWER KEYS (RO/SRO)

RO/SRO Initial Examination ADAMS Accession #ML070660539.

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