ML052430758

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Facility Post-Examination Comments for the Clinton Initial Examination - July 2005
ML052430758
Person / Time
Site: Clinton Constellation icon.png
Issue date: 07/18/2005
From: Setser G
AmerGen Energy Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML052430228 List:
References
50-461/05-301 50-461/05-301
Download: ML052430758 (15)


Text

FACILITY POST-EXAMINATION COMMENTS FOR THE CLINTON INITIAL EXAMINATION -JULY 2005

An Exelon Company Clinton Power Station R. R. 3. Box 228 Clinton, IL 61727 U-603743 July 29, 2005

.. 4 Mr. J. L. Caldwell Regional Administrator, Region Ill U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Comments Regarding Reactor Operator License Examination Question Administered on July 25, 2005 This letter is to request that questions 81 and 96 be removed from the Senior Reactor Operator License Examination administered on July 25, 2005. Enclosed are the questions and associated documentation that justifies this request. Required references have been provided with the original exam submittal on letter U-603730 dated May 26, 2005.

If you should have any questions concerning this matter please contact Mr. G. D. Setser at Sincerely yours, (217) 937-4122.

g 5. y William S. II Regulatory Assurance Manager Clinton Power Station EET/blf Attachments cc' NRC Clinton Licensing Project Manager (w/o Attachment)

NRC Resident Office, V-690 (w/o Attachment)

Reference Test Item (Question.)

Concern or Problem Recommended Resolution I

Missed by RO and I SRO-I No grading change required, however distractor C can he enhanced by adding Standby Liquid Control PUMp Remarks Keyed answer is correct.

SRO-I chose answer B and RO chose C.

I schemes. Some candidates felt the simulator responded differently than the 2

correct answer.

Both chose B. Choice based on faulty reading of the question (asking for single rod, answered for all rods).

Missed by 1 SRO-I, SRO-U No grading change No candidate comments.

5 1

Both chose answer B. Possible knowledge weakness related to DC distribution and DC control power No grading change No candidate comments.

Missed by 2 SRO-I 9

11 related to system knowledge.

2 SRO-I chose A, RO chose C.

Missed by 2 SRO-I and RO No grading change Correct technical errors in justification for why answer A/C incorrect.

100% missed. All candidates chose A.

Possible training weakness. Relates to NSPS/VG inter-relationship.

Missed by RO, 2 SRO-I and SRO-U No grading change No candidate comments.

15 Missed by 1 SRO-I, SRO-U No grading change Modify fact in stem as follows:

...DIRECTLY proportional to the PRESENT battery r-I capacity (in ampere-hours) dissed by RO and 1 SRO-I No grading change.

Modify portion of stem by deleting statement in parantheses.

Hissed by RO and 1 SRO-I Missed by RO and 1 SRO-I No grading change No candidate comments.

No grading change No candidate comments.

Missed by RO and SRO-I No grading change No candidate comments.

2 part question related to battery h g e n production and loss of battery

,m ventilation. Required knowledge of sedum1 requirements for loss of tery r w m ventilation.

2005-07-0082A submitted.

Missed by I SRO-I No grading change Candidate commented that although the procedure is clear that Containment temperatures are not available, he had k e n train& that if parameter showed green (good data) it can he used. This parameter docs not show green during SBO.

49 Missed by 2 SRO-I and SRO-No grading change U

No candidate comments.

Ith chose A.

lates to Fire Pump trip signals.

x h chose D.

meet answer required knowledge of irious EOP related parameter Setpoints relation to EOP entry conditions.

0th chose B.

equired recognition between iterrelationship of RR EOP-rn circuit nd downshift circuit.

loth chose A.

equired knowledge of loads on DC listribution busses.

Hissed by one candidate, listed here to

apture the candidate comment.

2 chose B, one chose c.

This question required knowledge of the low pressure operating mode of the RT letdown flowpath.

SRO-U

. DELETE QuESnoN see attached table with justification for this action.

Missed by 1 SRO-I, SRO-U I

87 1 Missed by 2 SRO-I o grading change

,,hancement only: Remove the word ZONE from distractor

. and C l o grading change.

nhancement. Add to stem *...and squib valves will not fire.

DELETE QuESnON see attached table with justification for this action.

No grading change 2 chose D, one chose A.

Candidates initially commented that c &

D were correct, but after review of the procedure (which was provided for the test) agreed that only one answer correct.

All chose A.

General knowledge weakness of the refueling bridge interlocks Both chose C.

Apparent lack of recognition that the RSD procedure does contain procedure steps that allow termination and prevention of HPCS, Feedwater, and RCIC remotely. Specific comment was that the RSD procedure does not contain a section called Terminate and Prevent.

TR 2@35-07-0083A written No correct answer.

A ion; 'omments: All questions missed by 2 or more candidates analyzed.

Exam Analyzer comments: Separate table attached with iustitications for 2 proposed deletions.

Final Resolution:

I / /

?/I Reviewed by:

l I 7 / z q / k -

Approved by:

/ JidP Facility Author I Date Facility Mresentative I Date

2uestion Number I1 (Attached)

Keyed Lnswer 3

Pertinent Reference CPS ITS 3.6.5.4 and Bases Proposed iction 3elete

?uestion Justification Choice B is not completely correct. Part (2) DIRECT communication of the blowdown energy contained in the dryweell airspace, to the suppression pool inventoy, should a LOCA occur, describes the circumstance that is EXPECTED to occur during a LOCA and not the POTENTIAL consequences of NOT restoring an out-of-limit Drywell to Containment dP during non-LOCA conditions. This statement would apply regardless of initial conditions and therefore is NOT a consequence of a high out of spec Drywell to Containment dP. Therefore the keyed answer did not address the question.

Conditions of the stem indicate that drywell pressure is higher than Containment press, therefore the following wording from CPS ITS 3.6.5.4 Bases apply:

The limitation on positive drywell-to-primary containment differential pressure helps ensure that the horizontal vents are not cleared with normal weir annulus water level and limits drywell pressure during an accident to less than the drywell design pressure.

A limitation on the drywell-to-primary containment differential pressure of 2 -0.2 and 5 +1.0 psid is required to ensure that suppression pool water is not forced over th weir wall, vent clearing does not occur during normal operation, containment conditions are consistent with the safety analyses, and LOCA drywell pressures and pool swell loads are within design values.

Nothing in the stem conditions indicate that a LOCA condition exists nor

~

that weir level is other than normal.

16 (attached)

P-AA-1003
P-AA-1 1 1
p-AA-1 12-00 Mete 2uestion i n example of a correct answer for this portion of the question would hen be

!) Clearing of the vents during normal operation.

3hoices A, C, and D are incorrect for the conditions stated in the key.

ft is therefore felt that there is no completely correct answer for the juestion and that it should be deleted.

Ihere is no correct answer to this question. Stem conditions state (in

?art), At Time = +20 minutes, an UNISOUBLE primary system iischarge causes operators to enter EOP-8 because an Area Temperature has JUST REACHED its EOP-8 entry value.

Facts:

1) The word UNISOLABLE is defined in EP-AA-1003 as A breach or leak that cannot be isolated from the Control Room or within 15 minutes by operators in the field. Therefore if a leak has been classified as UNISOLABLE, an unsuccessful attempt has been made either in the MCR or the field (or both) to isolate it. The question does not elaborate as to the reason for this condition.
2) The phrase an area temperature has just reached its EOP entry value defines the particular temperature as the Max Normal, vice the Max Safe temperatures. (Refer to CPS EOP-8 and to Table F1 in EP-AA-1003 page CL 3-8).

The keyed answer justifying C as correct makes the assumption that the only EAL threshold of concern at time +20 minutes is that related to the Max Normal area temperature (FA1). However with both a Max Normal temperature AND an UNISOLABLE discharge, the appropriate EAL would be FS 1 based on Potential Loss of RCS (related to area temperature Table F1) AND Loss of Containment (related to either c.1 01 c.2).

This therefore changes the correct answer for part 2 of the question:

2) by when the event MUST be ESCALATED to the HIGHEST Classification Level necessary for these plant conditions?

Given that:

1) The highest classification is FS1,
2) The event requiring classification of FS1 actually occurs at +20
3) The SM takes the full allowed time of 15 minutes to classify the minutes, and
event, The correct answer to part 2 is 35 minutes. Part 1 remains correct since the escalation from a UE to a SAE occurs before the notification for the UE must be made. (Refer to EP-AA-111)

In summary, the correct answer should be:

1) 50 minutes
2) 35 minutes

Question #81 The plant is operating at rated power, when the following occurs:

A PARTIAL loss of Drywell Cooling (VP) occurs As a result:

o Drywell Average Air Temperature rises and STABILIZES at 145.6"F o Drywell-to-Primary Containment d/p rises and STABILIZES at +1.1 psid Which ONE of the following describes:

(1) the required action, and (2) the POTENTIAL consequence of NOT taking that action?

A.

(1) Restore the Drywell-to-Primary Containment dlp to within its Tech Spec limits.

(2) Weir wall overflow, should an inadvertent upper pool dump occur.

B.

(1) Restore the Drywell-to-Primary Containment dlp to within its Tech Spec limits.

(2) DIRECT communication of the blowdown energy contained in the drywell airspace, to the suppression pool inventory, should a LOCA occur.

C.

(1) Restore the Drywell Average Air Temperature to within its Tech Spec

limits.

(2) Drywell temperatures in excess of the drywell STRUCTURAL design temperature, should a LOCA occur.

Objective:

LP85223.1.I6 D.

(1) Restore the Drywell Average Air Temperature to within its Tech Spec limits.

(2) Drywell temperatures in excess of the drywell EQUIPMENT QUALIFICATION temperatures, should a COMPLETE loss of VP occur.

Question Source:

Level of Difficulty:

New

3.3 Answer

B References provided to examinee:

Explanation:

None B is correct - Per Tech Spec 3.6.5.4, 1.1 psid is beyond the upper limit of 1.O psid. Condition A requires that d/p be restored to within the limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Refer to Basis for this LCO, B 3.6.5.4, page B 3.6 - 122, the 'Background discussion portion that reads..."The limitation on positive...". This discussion means that too high a drywell-to-CNMT can cause the vents to be already uncovered ('cleared) at the onset of a DBA LOCA (as a result of the downward force on the annulus water level). If a LOCA, then, were to occur, the RPV blowdown energy would communicate directly into the suppression pool inventory. See LP65223.

Figure 2 for an illustration of this physical arrangement.

A is incorrect - Part (1) is correct, but Pan (2) describes the consequence of too low a d/p (i.e., below the lower LCO limit of -0.2 psid). Refer to the same page E 3.6 - 122 discussion.

C and D are incorrect -The 'stabilized drywell average air temperature of 145.6"F is lower than the entry point for Tech Spec 3.6.5.5 (i.e., 146.53'F).

I I

I I

References:

L Date Written:

03/31/05 CPS Tech Spec 3.6.5.4, Dryweil Pressure (and its Bases)

CPS Tech Spec 3.6.5.5, Drywell Average Air Temperature (and its Bases)

Author:

Ryder LP85223. Primary Containment Although Part (1) is arguably a requirement for both RO/SRO Candidates, Pad (2) is not. Part (2) asks for the potential 'consequence' of not restoring the LCO limits, which is only found in the Tech Spec Bases (as weii as in the USAR). What's more, it is the Part (2) requirement that applies the KA statement's 'ability to interpret' portion. This question is in fact presented at an SRO-only level.

MODIFIEDINRC Enhancement, Deleted all reference to times in all distractors (ie...within X hours). Changed stem from "Drywell-to-Primary Containment d/p rises and STABILIZES at

+1.2 psid" to "Drywell-to-Primary Containment d/p rises and STABILIZES at +1.1 psid.

GDSetser 6/14/05

Question #96 Using the provided references, answer the following.

The plant is operating at rated power, when the following occurs:

At Time = 0 minutes, ALL annunciators on P877 are lost due to a blown power supply At Time = +20 minutes, an UNISOLABLE primary system discharge causes operators to enter EOP-8 because an Area Temperature has JUST REACHED its EOP-8 entry value At Time = +55 minutes, as directed by EOP-8, operators perform an RPV Blowdown Which ONE of the following identifies the LATEST time:

(1) by when the FIRST required StatelLocal agency NOTIFICATION must be completed, and necessary for these plant conditions?

(2) by when the event MUST be ESCALATED to the HIGHEST Classification Level A.

(1) Time = +30 minutes (2) Time = +35 minutes

6.

(1) Time = +45 minutes

(2) Time = +40 minutes C.

(1) Time = +50 minutes (2) Time = +70 minutes D.

(1) Time = +85 minutes (2) Time = +70 minutes Answer: C Explanation:

C is correct - Part (1): The earliest that an EAL threshold is reached is at Time = +15 minutes. for EAL

'MU6 (see CPS Annex page CL 3-11). Per EP-AA-112-100, Section 2.1, the Shift Manager (SM) would have until Time = +30 minutes to classify/declare the event as a UE, and until Time = +45 minutes to complete the required State/Lccal notifications. However, at Time = +20 minutes, the 'FA1' EAL threshold is reached due to a 'Potential Loss of RCS' (see Annex page CL 3-8). Again, the SM would have until Time =

+35 minutes (20 + 15 = 35) to classify/declare the event as an ALERT. Per EP-AA-Ill, Section 4.1, the Znd NOTE, once this higher classification level is declared, if the UE notification has not yet been made, the UE event is essentially dismissed (without further consideration), in favor of the more 'severe' ALERT event declaration. In other words, given these stem conditions, the UE event (loss of annunciators) does not result in a 'First required' State/Local agency notification. Rather, the SM has until Time = +50 minutes to complete the ALERT notifications. And since the next plant transient that requires a re-classification (escalation) to an SAE (i.e.. the RPV Blowdown) doesn't even occur until Time = +55 minutes. the SM does in fact get a chance to complete the ALERT notifications at Time = +50 minutes. This, therefore, amounts to the 'First required State/Local agency notification for these given plant conditions. Part (2): An SAE is the highest classification required for these plant conditions (i.e.. the 'FS1' EAL is reached due to Loss of Containment; see Annex page CL 3-8). Again, per EP-AA-112-100. Section 2.1, the SM must declare this escalation (from an ALERT) no later than Time = +70 minutes (+55 + 15 minutes = +70 minutes).

A is incorrect - Far the reasons already described above. Part (1) is plausible to the Candidate who disregards the EP-AA-111, Section 4.1, requirements, and mistakenly applies a +30 minute requirement

(+15+ 15=+30minute) of EP-AA-112-100, Section2,1,totheg&of the'thresholdclcck'for'MU6. Part (2) is plausible to the Candidate who recognizes the need to escalate to an ALERT by no later than Time =

+35 minutes (FA1 threshold at Time = +20, +15 minutes to classify, per EP-AA-112-100, Section 2.1). This Candidate does recognize that the RPV Blowdown at Time = +55 minutes results in a further escalation to an SAE ('FS1' EAL).

B s incorrect - For the reasons already descriDed above Part (1) IS plamble to tne Candlaate who aitnoJgh correct y z i t s lor the MU6 thresnolo clock to become active' ( e me thresua szet) Dgore -

applying the +30 minute allowance of EP-AA-112-100, Section 2.1, fails to apply the EP-AA-I 11, Section 4.1 requirement that essentially dismisses the MU6 event. Part (2) is designed to provide psychometric balance with Part (2) of choice 'D (i.e., a time value that is earlier than its associated Part (1) value). It has sufficient face validity for the thoroughly confused Candidate, as well.

Objective:

LP87537.1. I O D IS incorrect - For the reasons alreaoy descnbed above This choice (both Parts) is piausiole to the Canddale wno cannot elfectively lranslate tne caller of the EOP-8 actions tdentdied,n the stem conoitions.

and nstead simply applies tne f nal slate 01 the pant (RPV Blowdown is progress) and conclJaes that EAL FSI' applies Th s Cand date wdl necessanly recognize that the SM has 15 mmtes to classty the SAE

( e, Time = +55 m nJtes 15 minutes = +70 mmtes). yielding Pan (2) of the answer cho ce S mi.arly. the SM has an add t.onal 15 minutes, from Tame = +70 minutes. to complete the State/Local notif cat on5 (Time

= -70 + 15 minutes = +85 minutes). yield ng Pan (1) 01 tne answer choice Ouestion Source:

Level of Difficulty:

New 3.3 I

I I

I Date Written:

0511 6/05 Author:

Ryder References provided to examinee:

References:

EP-AA-1003. Clinton Radiological Annex, pages CL 3-6 thru 3-13 EOP flowcharts EP-AA-1003. Clinton Radiological Annex EP-AA-112-100. Control Room Operations EP-AA-111, Emergency Classification and PARS CPS EOP-8. Secondary Containment Control