ML050480053

Draft - Nrc/Facility Comments (Folder 2)

ML050480053
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	01/17/2005
From:	Caruso J, Suzanne Dennis NRC/RGN-I/DRS/OSB
To:	Conte R NRC/RGN-I/DRS/OSB
Conte R
References
Download: ML050480053 (20)

Text

J. Caruso S. Dennis OPERATING EXAM REVIEW COMMENTS General Comment: Please make all applicant hand out material a different color paper including all cue sheets and reference materials. Licensee agreed Admin. J PMS 0

A.1.2 - Review of logs - initiating cue too leading - delete second sentence. Done 0

A.4 - 1 For the initiating cue, why are we telling SRO applicants the procedure and section? Done 0

A.l.l - Respond to Red event - recommended to licensee to mark the front of this JPM in BOLD and CAPS, SENSITIVE SECURITY INFORMATION DO NOT RELEASE FOR PUBLIC DISCLOSURE Licensee agreed to this. In addition, Greg Smith, Sen. Region I Security Inspector was consulted regarding the marking of this procedure.

OP 31 32, Response to Security Events is not classified sensitive security information.

Greg contacted site security and discussed classifying this procedure as Proprietary to help prevent inadvertent public disclosure, Also from an industry wide perspective, Greg recommended that W security contact NE1 to discuss a standardized approach for the industry to classify such procedures for the future.

Simulator JPMs 0

Swap Pressure Regulators - edit initiating cue to delete procedure reference - all are SRO applicants - they should not need to be directed to the proper procedure. This was done also revised this JPM to make alternative path.

0 Shift RPS bus Power: 1) edit initiating cue to delete procedure reference - all are SRO applicants - they should not need to be directed to the proper procedure. 2)This JPM really does not adequately discriminate. Should either be replaced or beefed-up.

Licensee agreed to just designate for the SROI applicant not for the SROUs.

0 Perform alt Rx injection with A RHRSW - 1) for alt path JPMs, please indicate on cover page of JPMs that are is ah path. 2) Edit initiating cue to delete procedure reference - all are SRO applicants also move/relocate Another operator will perform step 1... to scripted cue. 3) Step #5 critical? 4)Dont see what makes this JPM alt.

path ? Licensee indicated that the high sump level which required throttling pump flow was intended to be their alt path but conceded that this was really just compliance with a system precaution and did not involve real change in procedure direction (i.e., alt path). JPM was replaced with another proposed Terminate and Prevent JPM that was also determined not be alternate path.

However, retained this as a normal JPM 0

Reset Group I logic: 1) edit initiating cue to delete procedure reference - all are SRO

applicants - they should not need to be directed to the proper procedure. 2) requires very little operator action and is a weak assessment tool. LOD -1.5, very weak. This may have been accepted in past exams. Licensee agreed to either replace or just designate for the SROl applicant not for the SROUs. This was a compromise considering there were 3 simplistic tasks in this set of JPMs. Added steps to equalize and open MSIVs.

0 Restart S/D Cooling: edit initiating cue to delete procedure reference - all are SRO applicants - they should not need to be directed to the proper procedure. Done 0

Respond to a Rod Drift: edit initiating cue to delete procedure reference - all are SRO applicants - they should not need to be directed to the proper procedure. 2) Steps #

4&5 critical? Determined steps 4&5 not critical also revised intiating cue to remove procedure reference.

0 Secure SBGT: 1) edit initiating cue to delete procedure reference - all are SRO applicants - they should not need to be directed to the proper procedure. 2) Steps #

6&7 critical?

In-plant JPMs Operate RClC from Alt s/d panel - doesnt look like replacing a burned out light bulb/fuse adequate alt path. Determined after validation week that the JPM was an adequate alt. Path JPM.

Vent scram air header - weak borderline acceptable. Licensee agreed to designate for the SROl applicant not for the SROUs.

Scenario #1

1.

Critical Tasks - General Comment Regarding All Cts - Why isnt the opening of SRVs considered a CT for the BOP? Should script all related actions in and bold as part of the Cts. Revised scenario.

2.

CTs# 2&3 Alt Scram actions % ED - what are the 10 minute and 5 minute bases - these numbers should not have been arbitrarily elected but based on some meaningful safety concern. Established in LORT program by Ops as reasonable goals for sat.

performance.

3.

Are we going to have them classify the events after each scenario - please include expected classification?

General Comment: Please provide the safety bases for established times and or margins for all CTs in all scenarios. Ops Trng Supervisor indicated that the times were based on LORT established CTs.

Scenario #2

1.

Event 6 - Need more specific operator action detail for transfer of house loads to startup

xf m r. Revised scenario.

Event 8 - Initiate a manual scram for the CRO should be a critical task. Need more details - What are table A lntiations and Isolations? What are the OT 3122 Actions are they all scripted? Revised scenario.

2.

3.

Event #9 & 10 you plan to include attachments 2-1, 2, 3 later providing more detailed actions?? Provided on disk.

4.

Other Critical Tasks - Why isnt the opening of SRVs considered a CT for the BOP -

need bold all required actions for CTs. Revised scenario.

5.

See general comment above regarding all Cts for this scenario (i.e., provide the safety bases for established times and or margins for all CTs in all scenarios). Revised scenario.

Scenario #3

1.

Other Critical Tasks - Why isnt the opening of SRVs considered a CT for the BOP?

Re vised scenario.

2.

Weak scenario for SRO evaluation - no competing EOP priorities. Please consider beefing up. However only the back-up scenario - accepted as-is.

General Comment: Completed review of the last 2 operating exams administered for overlap with the currently proposed Operating exam and concluded zero actual overlap. The radcon admin JPM was testing the same general area but it was modified.

v

1.

2.

3. Psychometric Flaws

4. Job Content Flaws

5. Other

6.

7.

Explanation Q# LOK (F/H)

(1-5) Stem Cues T/F Cred. Partial Job-Minutia

1. /

Back-Q= SRO u/E/s Focus Dist.

Link units ward WA Only Y

N S

1 H

2 2

H 3

Y N

S 3

H 3

Y N

E Add to Stem.. Assume NO additional actions are taken by the operators.

Done 4

H 3

Y N

S Need Additional references or prints which discuss or show the tie between the light indication and blown fuses. Additional references provided and reviewed - no concerns identified.

5 H

3 N

N E

WA -doesnt seem t match unless the tie is a main generator trip and subsequent turbine trip. Also, what is the significance of the 10 seconds in stem. Licensee expandedjustification to explain WA tie and 10 sec. delay.

this question.

6 F

1-2?

Y N

S Borderline LOD 1-2. Licensee disagreed 2 of 5 validators missed

~

3. Psychometric Flaws

4. Job Content Flaws I 5. Other

7.

Explanation 2

1 The procedure has you first place the MTS-13-1 switch to Emergency prior to placing the other transfer switches to emergency. Therefore the stem statement regarding the transfer switches seems to indicate that the procedure was performed out of order. Is this procedure required to be performed sequentially in order? There may be no correct answer for this question if that is the case.

Additionally, the question seems to be how DC affects RCIC and NOT the ability to monitor or operate DC distribution for control room abandonment as stated for the WA. Looks like 217000K6.01 (Knowledge of effect that a loss of electrical power supply will have on concern also upon further review agreed that WA fits DC distribution is being monitored as it affects control room abondonment - question was determined to be acceptable as revised.

RCIC) is a much better WA fit Licensee revised stem to fix first Y?

Y Y

Y Y

Y LOD=I too BasWFundamental loads cooled by TBCCW. Licensee agreed and replaced question using same WA.

H 3

F 3

X Stem should state that the RHR pumps cannot be restored, otherwise lacing the other loop in service should be the first choice and therefore there may be no correct answer. Suggest modifing stem second bullet Shutdown cooling lost, and it is not possible to restore the RHR system any time soon Licensee agreed and incorporated comment.

2 correct answers - B could also be correct. Licensee agreed with comment and revised both a&b distractors for symmetry.

F F -

2 2 -

X

~

~~~~~

Need to change to fundamental - this is a design basis question fundamental disguised as a comprehensive knowledge question. Changed to

4. Job Content Flaws

5. Other

6.

3. Psychometric Flaws

7.

'artial Job-Minutia

-ink I

>red.

Dist. -

Explanation H -

F -

H F -

2 -

2 X

a&d distractors not credible with reference in hand. direct lookup on EOP graph??. Licensee changed question, answer and sitractors so each requires equal usage of EOP-1 2

2 3

H H -

F 3 -

1 2

~~

The answer seems incomplete per reference "ensure TS 4.8.k.2 is alsc completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />" Licensee made change.

distractors C not credible. Licensee revised also discussed why D i!

plausible.

Need to review other procedures referenced in the distractors to ensure they are incorrect. Received additional references and dentified na

. concerns.

H F -

F H

F -

2 -

2 3

2 -

Yarified justifications for distractors.

Define long term and Why will they trip on thermal overload? License, svised stem and provided more justification for answer.

I. This is WA mismatch. It is a RClC based question not suppression io01 cooling question as stated in the WA

!. No correct answer. With a group 1 isolation and no RHR, why wouldn IOU be required by TS or administratively to shutdown the plant as your irst course of action (unless there is an assumption that a shutdown ilready occurred). Licensee replaced question using same WA.

I N

X rn

E 50 51 52 53 54 55 -

56 57 -

58 59 60 -

~~

3. Psychometric Flaws

5. Other I 6.

4. Job Content Flaws

7.

red.

Dist.

X -

Explanation LOD=I, basic question non-discriminating. b&d distractors not plausible sampling in and of itself will not prevent asphyxiating atmosphere or explosive mixture could determine concentrations. Modified distractors.

H 2

F H -

3 3 -

References were unclear to support correct answer. Reviewed additional references sent - no concerns identified.

Iont understand justification PSV-55 shuts pump explain further. Fixec justifications to ready more accurately.

F 2

F -

H 2 -

3 Need to discuss how reference supports correct answer. Reference indicates RHR-65 Auto opens on RHR initiation signal. Reviewed additional references sent - no concerns identified.

No correct answer. References state that the rupture discs are designec to open between 56 and 62 #. At 59 # as stated in the correct answer,

he disc may not have ruptured, therefore no change in DW pressure wil have occured. Explain configuration, it sounds like even with TVS-86 open there is no vent path until the rupture disc ruptures?? Modified answer choices to get rid of rupture set point unnecessary.

H F -

3 2 -

I

n ru 0

6.

UIUS

7.

Explanation E

Change stem question to what procedure direction is required to be implemented confused by justification for a&b shouldnt b justifcation read Local firing will not work Changed stem from should to is required also added more detail to justification.

S Rich, stem wording procedures required rather than should. Done 1

reference doesnt support answer. Reviewed additional references sent - no concerns identified.

kg -

? g I

w I

I I

13

'#/

7.

At a minimum, explain any "U" ratings (e.g., how the Appendix B psychometric attributes are not being met).

1.

2.

3. Psychometric Flaws

4. Job Content Flaws

5. Other

6.

7.

LOD (1-5) Stem Cues T/F Cred. Partial Job-Minutia

1. /

Back-Q= SRO UIws Explanation Focus Dist.

Link units ward WA Only NUREG-1021, Revision 9

Rev 1: Now includes agreed upon changes agreed to via phone on 1/25/0g.

Question # NRC Exam Problem Fix or Justification Done 3

Add to stem assume no additional actions.

4 CWD and additional references provided.

Need additional ref prints to tie light indication to fuses.

K&A doesnt match unless Gen. Trip causes TB. Trip.

Also, why 10 secs in stem?

5 Gen trip causes TB trip. 10 secs gives time for diesels to start to make distracters credible. Added this information into the exam justification section.

6 LOD of 1.

Disagree, 2 of 5 valuators missed it.

Took out of stem portion that says all switches in emergency. Left it as MTS 13-1 not in emergency. K&A fits question. DC distribution is being monitored as it affects control room abandonment.

Agreed, auestion redaced.

7 The stem says all switches in emergency except MTS 13-1.

That is procedurally out of order and may have no right answer. K&A might not be a good fit.

LOD 1.

Add to stem that RHR pumps can not be restored soon.

2 correct answers, reword b.

Not comurehensive.

8 10 Done Done.

11 12 Changed to fundamental.

14 A&D distracters are direct lookup with EOP in hand.

Changed question, answer and distracters so each requires equal usage of EOP 1 mauh.

16 Doesnt match K&A and is fundamen tal.

Disagree. Candidate must first determine why RPVED is required. Then he must know that over pressurizing the containment is possible if RPVED is not performed due to the reduction in its heat capacity (lowering level reduces heat cauaci tv).

19.

Baseline off-gas reading is needed. Answer is incomplete.

It needs additional TS section and that it is completed in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Done.

Distracters C&D not credible.

May be an LOD 1 or 2.

20 LOD of 2 because it is an RO question that is asking the bases for a SM action.

It is not the bases for an RO action or duty. C & D are credible. For C the admin building and RCA entrance are at

21 22 23 24 26 27 Need other procedures referenced in distracters.

C&D not credible.

Define long term. Why do RRUs trip on overload?

K&A mismatch and no correct answer because GP 1 would require a plant shutdown.

LOD 1. RPVED is more for personnel safety and equipment reliability.

Distracters A&B are cued as wrong because the stem gives the title of APP AA (i.e. non-the same elevation and have no barrier.

D is credible because it is the normal assembly area with the normal (non C02) announcement being All non-essential personnel stay clear of the area (as opposed to evacuate).

Changed distracter C to say the evacuation is necessary to relocate the TSC (the TSC is on the upper, non-evacuated floor. The OSC is on the lower floor).

Done.

They are credible, re-justified C&D. Air mixing for hydrogen control occurs at other BWRs. Our SAGS allow a type of mixing through a vendpurge operation with N2 or air.

Removed the term long term and put in a DW press and temp. Put justification in that says pumping of the steam causes a high current and thus exceeds the thermal settine.

The logic and valves are in the tripped condition. The loss of the MSIVs, while at power, causes a scram thus the plant is shutdown. The K&A matches because it requires the candidate to know when SP.

Cooling is required to prevent a SP high temp.

However, it is agreed the question if overly wordy, complex and that a better K&A match can be found.

The question was replaced.

Disagree, LOD 2. Must know that RWCU is primary system. Must know definition of 2 AreaKOcations (Le.

Channels 9-12 are considered on location). Added this information into the exam justification section.

Changed reason for RPVED to equipment reliability.

Title of App AA removed from stem.

28 30 31 37 39 42 43 46 47 rad trips are bypassed).

Distracters A&C are not credible. Terminate and prevent prior to RPVED is basic knowledge.

Does the minimum flow valve need control oil to stay open?

Will the 12A be full open or stroking open?

LOD 1 because only suction pressure is a negative pressure.

Distracters A&C not credible because stem says SRVs are not available.

Does a high power IRM scram happen?

B&C not credible. How does an SRV activation be determined by tailpipe pressure?

Need more info on the logic.

K&A mismatch unless the AC/DC motors are the motor generator.

Disagree. This is an RO level question.

Level had been kept at 45 with condensate and feed (the first terminate and prevent had to be lifted to maintain level). The second terminate and prevent is in EOP 5 which is not Drovided.

No.

The plant was in a startup (i.e. normal heatup and pressurization) when an LNP occurs. The valve will not stroke at <=

350# during a startup. It must also see 82.5 in the vessel or #2.5 in the DW (which it gets during the LNP). During the LNP the valve has no power until 13 secs when the diesel loads. The allowable valve stroke time is between 4.5 to 7.5 secs (OP 4123 provided as a reference). Thus at time 15 secs the valve will be stroking opened. Added this information into the exam iustification section.

Changed to a positive 3# which is less than normal operating limits and similar in range to the 4# turbine exhaust Dressure given.

The stem says they are unavailable after a certain number of openings. The sustained openings use to actually be a procedurally directed step in the EOPs but no longer is. Added this information into the exam iustification section.

Yes.

Disagree. Each SRV has individual red light that is lit due to a high tail pipe pressure. There is also an alarfn that comes in from pressure that says the relief valve is open and to check these lights. Added this information into the exam iustification section.

Training prints and info provided.

Training print provided. AC motor is the normal driving force for the AC generator and the DC motor is the backup

Stem asks what DC is available but distracters C&D say no DC is available.

LOD 1. B&D not credible since detecting doesnt prevent an explosive/asphyxiating Fundamental. Why isnt it a simple memory load question?

References unclear to support answer.

The PCV shuts the pump down, dont understand.

How does reference support correct answer?

No correct answer. Reference says rupture could go between 65-62 psig.

Reference does not support correct answer.

No correct answer unless with the alarm in the function is disabled.

Why are C&D wrong unless the procedure says it has to be source.

Changed stem to say what DC source, if any, is available.

Changed question to ask if Tech Specs of the TRM requires the action. Changed B&D to detect a possible explosive/asphyxiating atmosphere and A&C to prevent a possible explosive/asphyxiating atmosphere Disagree. First he has to determine if the alarms are normal or abnormal. 2nd he has to determine what they have in common (e.g. RBCCW, power supply, service water). 3rd he must decide that a loss is occurring. 4 he has to determine a loss affects drywell RRUs. 5th he must know that a loss of RBCCW to the drywell RRUs will cause temp to increase.

Provided training material to show how summer and plant indication work.

Misplaced comma in justification. Had read PCV-55 shuts pump, should not trip.

Now reads PCV-55 shuts, pump should not trip.

Provided additional references to include flowpaths and logic for the LPCI valve and sumression D O O ~ cooling valve.

Deleted reference to rupture setpoint since it was unnecessary to the distracters or correct answer. Changed choices A &

C to say Manually oDen...

Disagree. OP 1100, page 9 at the bottom states that the refueling interlocks provide rod blocks. On page 10 the refueling interlocks are listed. On page 11, section G. 1. provides the interlock in the question. The load cell has failed high and thus the grapple is seen as being loaded.

The function is disabled with alarm in.

See the provided ARS 5-K-8 under automatic actions.

C&D changed and the distracters now are procedurally incorrect.

69 70 74 75 85 87 88 92 94 95 99 done one way.

Choice D may not be credible.

Is there a tagout holder manager in the m-ocedure?

LOD 1.

LOD 1.

Add in stem...individual is responsible for coordinating the overall emergency remonse.

Distracters not credible, its a direct lookup.

Delete the word should in stem. Should justification for B read local firing will NOT work?

Why do A, C and E have flow signals of 125%?

Replace should.

Reference doesnt support answer. Redace should.

Replace should.

All actions correct by procedure. Delete the word should.

No. Changed it to the Department Manager which is in the procedure.

Disagree. Essentially the same question was asked on the 2002 NRC Clinton exam.

Agreed. Changed question regarding the meaning of shutdown in the EOPs.

Done.

Disagree. The torus is a primary containment system but is not a primary system as defined in EOP 4. If not determined to be a primary system than EOP 1 entry would be required and the need for an RPVED in EOP 4.

Deleted should and replaced with is required.. The control room switch failed to both fire the squib valves and run the pumps. The firing of the squibs works but it doesnt make the pumps run.

Added a little more to the justification.

The flow converter that feeds these 3 has failed high. This is indicated by its top of scale reading and no corresponding reading from the D & F APRMs flow signals.

Done Added reference to EN-NS-103. Deleted should.

Done Disagree, only one correct answer (but not really proved by provided procedures). Changed the wording of the correct answer so it more directly is supported by the referenced procedure.

Added DP 166 as a reference and justification. Conservative Decision Malung and Reactivity Management stress core safety over power production.

The losddegradation of SW jeopardizes core safety (long term cooling). The scram minimizes heat loads while the

other actions continues power production.