ML090230060

From kanterella
Jump to navigation Jump to search
301 Written Examination - Post Exam Comments
ML090230060
Person / Time
Site: Catawba  
Issue date: 12/10/2008
From:
- No Known Affiliation
To:
NRC/RGN-II
References
50-413/08-301, 50-414/08-301
Download: ML090230060 (45)


Text

POST-EXAM COMMENTS (Green Paper)

C,ttTIfaJ8A 200~ -3D {

Wr~ll~ 8}(f(l(J1 - P~f fYIrM GM~b h~ ~l~ - l~ ~ /0 ~ tl>()t Licensee Submitted Post-Exam Comments LX]

Attached

[

]

None

Post Exam Comment 1 Question 5 Unit 1 was in Mode 5 preparing to enter Mode 6, Given the following:

Both trains of NO have been lost The crevllentered AP/1!Al5500t019 (Loss of Resldual Heat Removal System) but actions to restore cooilling have failed.

The OSM has determined an immediate need to tak,a an act~on per 10CFR50.S4(X).

Per the requirements of OMP 1-7 (Emergency/Abnolmal Procedure Implementation Guidelines):

'I, Is notiftcation to the NRC Operations Center required poor to taking the actioll?

2. How many addi1ional SROs (if any) are required to agree with the OSM prior to the action being taken?

A

1. Yes
2. None B.
1. Yes
2. One additional SRO C.

'I. No

2. None D.
1. No L.. One additional SRO o applicants chose answer A o applicants chose answer B 5 applicants chose answer C 4 applicants chose answer D Answer D was designated as the correct answer based upon the following:

Operation's administrative procedure OPM 1-7 (Emergency/Abnormal Procedure Implementation Guidelines) has a section 7.6 (Deviation From Approved Procedures) and 7.7 (Situations Not Covered by Procedure). The question developers considered this condition to fit into a situation not covered by procedure; therefore, OMP 1-7 section 7.7 would apply and Page 1 of5

Post Exam Comment 1 paragraph B which states, "The planned course of action shall be reviewed and approved by a second SRO... " would require one additional SRO to approve the desired action.

The applicants who chose answer C believed that OMP 1-7 section 7.6 (Deviation From Approved Procedures) applied because the stem of the question stated that the OSM determined an immediate need to take action. Section 7.6 paragraph C.3 states that actions outside approved procedures can be taken when, "Actions are needed to minimize immediate personnel hazardlinjury or damage to plant equipment." Section 7.6 paragraph D. 2 states that only one SRO must approve the action.

If the OSM's chosen actions are taken from various procedures unrelated to the current condition, then section 7.6 would apply. If the OSM's chosen actions aren't described in any procedure then section 7.7 would apply. The question didn't provide enough information for the applicants to know whether to apply section 7.6 or 7.7. Therefore, we request that both answers C and D be accepted as correct answers.

Page 2 of5

Post Exam Comment 1 Opel'aticmo :!vlrumgemenT Procedure 1-7 Page 18 of 31 7 "6" Deviation From Approved Procedures 2\\"OTE:

A..

EP::JAPs may not co,;/er aU sllm.t10tls. licensed Operators sllall take appropriate actio.t1 as desc.ribed belmv to place tlle plant in a safe condition.

Opel"lltor action tllken m anticipation of automatic actions 01' action taken to correctaf.'1iJ.eal or inc>omplete automatic action is not considered a cle,\\'tatiofL B.

Deviations !t'J'!l1 EP',/AP.s are normally not allowed.

C.

Hov\\,e-\\."er, actions outside p1'0cedurai g1lidauee may be taken tmder the follo,v1.ng com:!it:icm;.:

1.
3.
4.

The existing guidance is mcoll'ect 01' 1l0U-COlls.ervattye due tQc1.m'entplallt oreqniptllent condit.ions, A sitltatlonocenrs \\vl1ere established procedures do 110t apply.

Actiom are needed to minimize iUlmediate per:'1Qnnel hazat'd/injmy or damage to plaut eqnipment An unexpected 01' nncontrolled 10"s fluids/gasses occu!';'.

D In the e,'eut c,f au emergency. the licens*ed Senior Reactor Operators ha'.:e theanth01'ity and respon"ibility to take action m.'ces~.aty to plOteer the health and safety of the public asst~teo in 10CFR50.54(X) and H1CFR50.72 which reads:

1.

A licensee may take rea~.orulble action that depalts from ii.cense condition or a technical specification in an emergency ",hen this acti'::m is immeditlteiy needed to protect the public health 3UO safety and no action Cotl'.>ll'>tent '11h ]icen~e conditions,~ud tedmical specificatio!lS thllt can pwvide ade"llHlte or erluivalent Pt"lG'recttOn is immediately apparent.

Licensee action permitted by the previous pat'agraph shall be apprm-ed at a mitmnum, by a licensed Semol' Reactor OpetatDf (SRO) prior to takmg the action.

Page 3 of5

Post Exam Comment 1 Operation~ ~v~an.agemellt Pt'Ocedure 1-7 Page 19 on!

7..7

"iOTE:
3.

The licensee shan notify the NRC Opef"ations Center by ENS te.leph;:me of emergeucy circumstances requiril1g the licensee to take 1Iny protective action that depans fmm a !.tcense c{mdition Of technical specifk.ation as permitted b:'l the preceding paf"agraphs. ';,Vhen tillle permits. t.he notificatiOil must be made befNe the plOtectin acti.on is taken: othe!""',vise, the notification must be made as soon as possible thereafter. The Commission rna y require \\vritten statements ft",;:'m a licensee concerning its action. Also, the licemee should notify the Resident NRC 111spect01" as soon as practical.

E.

In the event of a llatiotll.dsecurity emet*gem:y, licensed Senior Reactol" Operator;; have the authority to takeactiol1 necessary to implement national se'CtU"ity objectives *a:,* stated in 10CFR5054(dd) whi.ch reads:

A licensee mary take reasonable actio.ll that departs [tom li.cense condition or a technical specification in a nattOilal"ecurity emergency vihe.ll dus actiml is im111edlate!"y needed to implement national security objectives as designated the lllltional C0l1U1l21illd authortit:y through the C::JIllluissicn. and no action consistenT ';'lith licea'>e ccnditio.lls and tecbnica!

specifications that can meet na!iomd $ecurity m:'leC[J.V'",~

is immediately apparent A national secm"ity emergew::yis all occurrence, indudil1g nudear attBid:, a natimwl disaster, or other emergency, l,\\/!uch serionsly degrades or seriously tlueatells the national security of the United State, OJ.

has been (tedared by the COl1gre"FLA L1atlotlal,>ecm*ity emergency is estabIished a !,nv enacted by the or by all order or directi':e i;.~ue.d by The President pnr<;uant to statues or the CCtl'1tltution cfthe United States.

Situaticms Not Covered Procedure If sufficient time exists, a procedllfe revision is always the preferred route.

Page 4 of5

Post Exam Comment 1 Opef!'ltion~ Ivfrulllgernen¢ PtDcedure 1-7 Page 20 of 3]

\\\\'he:n situations OCOll!' where established procedures do not apply,or pian! operat1.011 oan not be perfcrmedin30con:lanoe 1.'lith appro\\'1~d procedure", use oithe procedure shall be;:uspended and actiollshall be taken to pl.ace the plant in a safe conditiO'n, Any actions beyO'nd those l*equired to pIllce the planT 1n a safe condition shaH apply the conservative deci'>10m-making philosophy_ (SOER Further actions shall not be t:lIken without fnst performing the foUmving steps:

A.

Ba"ed on knowledge and resO'urce:; needed (induding the partl,lllly APs or EPs), the SRO,hall develop a planned course of action, The SRO is responsible for e1lsurillg these action'> afe within the bound~ of Techrucal Specifioations and licensed ba'lCis. lithe required aotionsaJ'e outside the bounds of Technical Specifications O'r hoellsed then 10CFR5054(x) "hal! be declared and the associated H=quirements of 10CFR50..54(x) "haH be imp!emE'J:l.ted (PPRB mvfP 1-7/94-11 B.

The planned cour~e of action shall be reviewed and approved by a ~econd SRO,preferahly the Operations Shift Ivbiuager.

The SRO"i1ould obtain other revievls such as Slation Manager, Group Superintenciem, TSC Of other involved gwnp'1,as ne'2essary based ou the comple:,uty ofthe situation and the tin",:

aHowed.

C.

If time aU,)\\-v", the plan shall be entered in the SRO !ogboc,k.

Otherwise, this may be (bne after rheactio1'!s have been taken.

D.

The SRO shaH carefully monitor the situation to' ensure the course of action is appropriate., As soon as approyed procedures can be re-entered, the SRO shall returu to the applicable procedure.

Page 5 of5

Post Exam Comment 2 Question 19 Given the following events and cond*itfol1s on Unit 1:

NC system is at full temperature and pressure.

"An Shutdown Bank control rods are fully wlthdrawl1.

CRD BANK SELECT swltch is in the "SBB" position.

The OATC is wifh<:lrawm9 "8" Shutdown Bank control rods with the current bank. posilion at 64 sreps withdrawn.

The OATC releases the ROD MOTION switch but "8" Shutdown Bank control rods continue to withdraw.

i. What is the current plant Mode of Operation?
2. Which of the following describes the first required action(s) for this sluation per AP/1/,A/550OI015 (Rod Conlro! Malfunction)?

A.

1. Mode2
2. Irnmedi3tely trip the reactor.
8.
1. Mode 3
2. tmmediately trip the reactor.

C.

1. Mode 2
2. Immediately place CRD BANK SELECT switch IN MiANUAL; it rods continue to move then trip the reactor.

D.

Mode 3

2. ~mmediately place CRD BANK SELECT switch IN MANUAL; if rods continue to move then trip the reactor.

I applicant chose answer A 4 applicants chose answer B o applicants chose answer C 4 applicants chose answer D Answer D was designated as the correct answer based upon the following:

Unwarranted continuous rod movement is an entry condition for procedure APIlIN55001015 Rod Control Malfunction Case II. The immediate actions of the AP are to place the rod bank select switch in manual, verify rod motion stops and trip the reactor if the rods continue to move.

The question developers considered strict procedural compliance when developing the question.

Page 1 of4

Post Exam Comment 2 The intent of the step C.l is to remove the CRD Bank Select switch from Auto. Any rod movement with the switch in any position other than Auto indicates a fault in the rod control system, and a reactor trip is warranted.

lfthe CRD Bank Select switch is in any position other than AUTO the rods can only be moved manually. The applicants who selected answer B applied NSD 705 allowance of intent met, and understood that any position other than AUTO is a position that only supports manual control of the rods; therefore, the intent of step C 1 was already met and the only required action was an immediate trip of the reactor per step C.2 RNa.

The applicants who selected answer D considered that strict procedural compliance required the rod bank select switch to be placed in the MAN position. Per strict procedural compliance answer D is correct.

Using the allowance of intent met, the first required action is to trip the reactor, and answer B is correct. Considering strict procedure compliance the first required action is to place the CRD Bank Select switch to manual, so the first require action is to place the switch in the MAN position, and answer D is correct. Therefore, we request that both answers Band D be accepted as correct.

Page 2 of4

Post Exam Comment 2 eNS AP '*1 /A"5<50'0I015 ROD CONTROL MALFUNCTIONS Case n Continuous Rod Movement ACTION/EXPECTED RESPONSE C. Operator Action~

Ensure "CRD BANK SELECT" switch -IN MANUAL

--G Verify* aU rod rnotion - STOPS.

Perform the fcHewing:

oL Trip reactor.

PAGE NO.

goff 12 Revisioni1 b

}30 JO EPtliAISGGWE-O (Reactor Trip Or Safety' ';""o,,~t"r""\\

704.5 PROCEDURE USE PHILOSOPHY Page 3 of 4

Post Exam Comment 2 hI' ;'

IS DN~uTrac:ks Su brnlI!I;d I,,1' I Page 4 of 4

Post Exam Comment 3 Question 23 Given the Unit! is operntll19 '""ith a kn*O"Nn CU3 GPO SiG tube leak

.1A CF pump and results in a pk.nt Fl.. mbadi.

The CFfPN has stabilizd the plant at the run bad; target per APrIlAJ5E,OOlQ03 (load Rejection)

The tmnsient has caused f)'1e h.Jbe leak to increase to 12 GPO.

Vvlhich one of the foilo'Ning indications vvill provide the best i!ldication and timely) that the S/G tube leak has in creased?

.~.

Observing 1 EMF-26, 27, 28 and 29 (Steam line 1 A - '10)

B.

S/(; feed flow to steam flow ObserVin,;! 1 EMF-33 (Condense r,Air Ejector Exhaust)

[1.

Observ'ing1EMF-7l, 72,73,74 (SiG A-D leakage')

o applicants chose answer A o applicants chose answer B 5 applicants chose answer C 4 applicants chose answer D Answer D was designated as the correct answer based on the following:

sensitive The question developer considered the EMFs 71-74 to be correct because their location on the steam lines makes them the first monitors to detect the change in secondary contamination.

The applicants who chose answer C selected lEMF 33 because it will be the first EMF to generate an alarm.

The question asks for the, "best indication (most sensitive and most timely)." The candidates selected different answers due to making different assumptions about what indication is being observed. Normally the operators infrequently monitor the EMF readings but are frequently monitoring the EMFs' alarm state. AP/1/A/5500/o03 (Load Rejection), which would have been implemented due to the runback, does not require the operators to monitor the EMF readings.

AP/1/A/55001010 (NC System Leakage), which would be entered once a tube leak greater than 5 gpd is detected, requires monitoring of EMF readings every 15 minutes but only if the SG leak rate is greater than 40 gpd. Given the situation described in the question the operators would be monitoring the EMF alarm state not the EMF readings.

Pagelof3

Post Exam Comment 3 In accordance with NSD 513 (see attached) EMFs 71-74 are set to alarm at 5 GPD. 1EMF-33 readings input to a calculation that runs continuously on the Operator Aid Computer (OAC). Per '

NSD 513 that calculation is set to produce an OAC alarm at 5 gpd. 1EMF-33 will produce an alarm on the annunciator panel based upon a predetermined increase in count rate above the background. Consequently, EMF-33 produces an annunciator due to increasing count rate before an OAC alarm based upon the calculated leak rate.

EMFs 71-74 are located on the steam line coming from each ofthe SGs. EMF-33 is monitoring the offgas from the condenser air ejectors. Due to their locations, EMFs 71-74 will be the first to detect an increase in secondary activity due to a tube leak.

This scenario was performed on the simulator at 100% power and again after a runback on loss of a CF pump. A 12 gpd leak in 1 A SG was inserted, and in both cases 1 EMF -71 count rate was the first EMF to increase, but 1EMF-33 was the first EMF to produce an alarm.

Based upon observing the EMF alarm status EMF-33 will be the timeliest indicator, which would make answer C correct.

Based upon monitoring the EMF readings EMFs 71-74 will be the timeliest because they are the first monitors to be exposed to the increase in secondary activity which makes answer D correct.

Since the question didn't clearly ask if the operators were monitoring the EMF readings or alarm state, we request that both answers C and D be accepted as correct.

Page 2 of3

Post Exam Comment 3 NSD 513 Primary-to-Secondary Leakrate Monitoring Program Paragraph 513.4.8 Alarm set point; Ofl the racliation mollitor"s and/or OAC point used to UlOtlitor primarY-To-seooooary' leal:: rate shall be set at a le,'el that ',vii! provide an early tnc1ioati(m ofillcreaslug prim:arycto-secoooary leak rate. Vi/hen the

!llclicated l.eak nne is le:;1> th"n :5 gallons per day. lhe alana shall be ";et to a level that conespo:uds to a leak rate of 5 gallolls per clay, or a level that >,',ill not give tmmerOU5 spurious alanm (1 ')galh:ltls per day Ot le!ls if possible). "Vhen the leak rate im::reac.e'i* to gleater than 5 galkms per day. the ahum ;,hall be set to a level that correspollds toa leak tate of 30 gallons per day. \\Vhen the leak rate iflcrea.',.es to greater tha:u 30 ga!k,ns pet' the alarm shall be set to a level that corH~".pollcl; to a leak rate of 30 gallons per day above the cunent leak rate, or l1'1e smtion ~:Imtclov'm lmut (Acticm Leve12 limit). v;hicbt"i"er is ies>.

Page 3 of3

Post Exam Comment 4 Question 42 Grven the following:

to A !;srge break LOCA has occurred.

to Containment pressure is 3.2 psig and slowly decreasing.

The crew has just transitionoo to EPtltAl5000IES-1.3 (Transfer to Cold Leg Recirculation)

What is the minimum containment sump level that will support operatiQn of all ECGS pumps and the NS pumps?

A.

0.5 ft B.

2.5ft C.

3.3 ft D.

5.0ft o applicants chose answer A 5 applicants chose answer B 4 applicants chose answer C o applicants chose answer D Answer C was designated as the correct answer based on the following:

The question developer considered the level required to support all ECCS and NS pumps taking suction on the containment sump. The crew enters EP/ES-1.3 when the FWST level decreases to 37%. The ND pump suctions automatically align to the containment sump, and the operators will align the remaining ECCS pumps suctions' from the FWST to the ND pump discharge per ES-1.3. When FWST level decreases to 11 % the operators will align the NS pumps' suction to the containment sump per ES-1.3.

The stem states that the crew has just entered EP/ES-1.3; therefore, at that point in time the only pumps with their suction aligned to the sump are the ND pumps and all other pumps are still aligned to the FWST. EP/ES-1.3 step 2 checks for a sump level> 3.3 feet. Ifit isn't, the RNO verifies sump level> 2.5 feet at step 2.f. Iflevel is > 2.5 feet then the NV and NI pumps' suctions can be aligned to the containment sump. In this situation a level of2.5 feet will support the operations all ECCS pumps while the NS pumps are still aligned to the FWST.

Page 1 of6

Post Exam Comment 4 When the FWST level decreases to 11 % ES-l.3 directs aligning the NS pumps to the containment sump using enclosure 2. Step 2 checks for a sump level of> 3.3 feet. Ifit isn't then the NS pump suction isn't aligned to the containment sump. Therefore, after FWST level has decreased to 11 %, 3.3 feet in the containment sump is required to support operation of all EeeS pumps.

The stem didn't provide the applicants information concerning the FWST level. That information is needed to determine which pumps are supposed to be aligned to the containment sump. If FWST level is <37% and > 11 %, then answer B is correct. If the FWST level is < 11 %

then answer e is correct.

Since the question didn't have enough information for the applicants to know the point in time they are required to evaluate the question, we request that both answers Band e be accepted as correct.

Page 2 of6

Post Exam Comment 4 CNS TRANSFER TO COLD LEG RECIRCULATION PAGE No..

EPf1/AI5000lES-l.3 2 of 38 Revision 2'1 ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED 1,

Mooiltor Enclosure 1 (Foldcut Page).

C~VI!QN SII recirculaticn flQW tQ NC System must be maintalnedatal! times.

NOT!;

.. Steps 2 through 8 should be performed without delay.

'" CSF should not be impl.ementeduntil directed by th'is procedure, 2

Verify at least lOne cf the f01l0wi09 annunciatcrs. UT:

'" lAD-20, Bl3 "CONT. SUMP LEVEL >3.3 fI'"

OR

'" 1AD-2'l, B/3 "CONT. SLJlvlP LEVEL >3,3 fi",

Perform the following:

a. Ensure Sfl - RESET:

'I) ECCS.

2) DiG load sequencers.
3) IF AT ANY TIME a BlO occurs, fHE~ restart Sli equipment previously on.
b. Ensure the following valves - CLOSED:
  • 'I FW-27A (ND Pump 'IA Sud From FV\\lST)
  • 1FV\\I-558 (ND Pump 'I B Suet From FWST).

(RNO continued on next page)

Page 3 of6

Post Exam Comment 4

2. (Continued) 3 Verify KCflow to NO Ileal exchangers -

GREATER THAN 500{) GPM..

RESPONSE NOT OBTAINED

c. IE valve(s) will not close, THt;~:

_1) Stop associated ND pump(s).

2) Depress the foUovlfjng "DEFEAT" pushbufton{s) for the affected train(s):
  • "C-LEG REGIR ANST TO CONT SUMP SWAP TRN A"
  • "C-LEG RECIR FVVST TO CONT SUfvlP S\\NAP TRN 8".

_:3) Close the associated ND pump(s) containment sump suction valve(s).

d. lE F\\;VST level less than 37% due to FWST puncture, ItiEN. REIJ,!.RI':J. IQ procedure and step in effect.

e, IE both NS pumps are off, I!:::IEt.:-l. Gg IQ Step 2 RNa g.

f.

IE either of the following annunciators are lit:

  • lAD-20, B/2 "CONT SU~v'iP LEVEL

>2.5 fil' OR

  • tAD-2"1, Bl2 "CONT SUfvlP LEVEL

>2.~5 ftl~l (RNa continued on next page)

Estal)lis~1 KC flow to affected ND Hx{sl.

Page 4 of6

Post Exam Comment 4 CNS EP!1/A/5000IES-1.3 TRANSFER TO COLD LEG RECIRCULATION PAGE NO.

12 of 38 Revision 21 ACTION/EXPECTED RESPONSE

5. (Continued)
i.

Verify proper recire flow as follows:

  • "NY Sf! FLOW" -INDICATING FLOW
  • NI pumps -INDICATING FLOW
  • NO pumps - INDICATING FLOW.

6..

WHEN FWST level decreases to 11%

(1AD-9. Era tlFWST lO-LO LEVEL" alarm lit), THEN perform the foflowing:

a. Stop N5 Pumps.

b.. AHgn NS for redrc. REFER TO (A!igning NS for Recirculation).

RESPOf4SE NOr OBTAINED L IF any 511 pump on witham a suctron flowpath, THEN stop the affected pump(s).

Page 5 of6

Post Exam Comment 4 eNS EPI1lAlSOOOIES-'l.3 TRANSFER TO COLD LEG RECIRCULATION

  • Page 'I of '13 PAGE NO.

2"1 of 38 Revision 21 Aligning NS for Recirculation ACTION/EXPECTED RESPONSE I.

Close the following valves:

NS-2QA (NS Pump 1A Suet From FWST)

.. 'I NS-38 (NS Pump 16 Suet From F\\NST).

2.

Verify at least one of the foHowing annunciators - UT:

.!AD-20, 8/3 "CONT. SUMP LEVEL >3.3 ftl' OR

  • lAD-21, 8!3 "CONT. SUMP LEVEL >3.3 ft'*'.

RESPONSE NOT OBTAINED Perform the following:

8, WHEN at least one "CONT. SUlvlP lEVEL >3.3 ft" annunciator is LIT I!1ENG'g IQ Step 3.

b. Do not continue in this enclosure Llntil at least one annuciator is LIT Page 6 of6

Post Exam Comment 5 Questions 55 Unit 1 is operating at 100% power with a routine containment air release in progress through 1VQ-10 (VO Fans Disch To Unit Vent).

1. At what eornainm ant pressure will 1VQ-10 first raee ive a &OClOSE signal?
2. What is tle basis for dosing 1VQ-10 at that pItH.sure?

A.

1. -0.00 psig
2. Non-compliance with technical specification 00 containment pressure B.
1. -0.00 psig
2. Unexpected opening of ice condenser inlet doors C.
1. 0 psig
2. Non-compli'ance with technical specification 00 containment pressure
o.
1. Opsig
2. Unexpected opening oHce condenser inlet doors o applicants chose answer A o applicants chose answer B 3 applicants chose answer C 6 applicants chose answer D Answer C was designated as correct based upon the following:

Valve VQ-lO gets a close signal at 0 psig. The fans are large enough to reduce containment pressure below the Tech Spec limit (See Attached). Therefore, basis for closing the valve at that o psig is to prevent the VQ fans from reducing containment pressure to the minimum tech spec value.

The 6 applicants who chose answer D rejected answer C because the wording of the answer implied that the minimum tech spec value had been reached when the valve closed which is incorrect since the minimum tech spec value is -0.1 psig. At 0 psig the plant is in compliance with Tech Specs; therefore, the answer is not technically correct. Had the answer stated, "To prevent non-compliance... " then the answer would have been correct.

Page 1 of 4

Post Exam Comment 5 The VQ fans are sized small enough to prevent them from opening the ice condenser doors; therefore answer D is wrong. (See attached.)

We recommend that this question be deleted from the exam since there is no technically correct answer.

Page 2 of 4

REFERENCES:

VQSYSTEMFANS Post Exam Comment 5 Design Basis Specification for the Containment Air Release and Addition (VQ) System CNS-1585.VQ-OO-0001 The VQ System fans are sized large enough to relieve pressure from containment during all normal modes of plant operation. The pressure rise that occurs during plant start-up when the containment is initially heating up, provides the conditions where maximum pressure build up in containment occurs during normal plant operation. Thus the VQ fans are sized with a flow rate high enough to relieve pressure during plant start-up.

One other consideration in the sizing of the fans is to size the fans small enough to eliminate possible impacts on containment safety related functions. The fans take suction from the upper containment. The fans are sized small enough to eliminate the possibility of lifting the ice condenser doors due to the pressure differential between upper and lower containment.

The non-safety Containment Air Release and Addition Fans (VQ) are capable of challenging the containment negative pressure design limit of -1.5 psig as stated in the FSAR. There is no safety related input which ensures this fan is tripped prior to exceeding this limit. Assuming the VQ controller was to fail and the fan allowed to run unchecked, the fan could theoretically develop a negative pressure exceeding the -1.5 psig design limit.

1.1.1.1 Containment Air Release Flow Control Valve (1 VQ1 0)

This valve is controlled by controller 1 VQSSOlOO, which is located on control board 1MC5 in the main control room. A permissive signal of containment pressure above 0 psig is required to open this valve.

Valve 1 VQlO closes automatically at 0 psig containment pressure decreasing and upon high radiation in the unit vent.

1.1.2 SYSTEM LIMITS AND PRECAUTIONS

1. Containment Pressure Technical Specification limits are -.1 to +0.3 psig with operational limits between -0.08 psig and +0.25 psig.

Page 3 of 4

Post Exam Comment 5 VQ lesson pg 5 rev 24 1.1.1 Containment Air Release Fans 1.1.1.1 Two fans per unit (A and B fans) with normal flow rates at 250-300 SCFM per fan. VQ fans are used only to release air from containment.

1.1.1.2 Fans are large enough to relieve containment pressure during normal operations but small enough to prevent opening ice condenser doors from the pressure differential created across the doors. The fans take suction on upper containment.

1.1.1.3 The fan could lower containment pressure to -2.8 psig should the release not properly terminate automatically with the closure of VQ-1 O.

Page 4 of 4

Post Exam Comment 6 Question 76 Given the futlowmg Unit 1 conditions and sequence of events:

NCsystem temperature Is 200"f NC system pressure is 350 psig 1A NV pump is red iagg,ed to replace its 1 ETA breaker 1 B N I pump is 'White tagged 1A NO and 1B NO loops operating in residual heat removal mode

  • An ND pump suction relief has. spuriomdy lifted and has oot reseated Both NO pumps have been secured per AP/1/AJ55 001021 (Shutdown LOCAl
1. What is the corred: procedure ffowpath for this situation?
2. What is the limiting component that the current ECCS pump oonflQuratioo is designed to proted from over-presswizatioll?

A.

1. Remain in AP/HN5500I02J (Shutdown lOCA)
2. NC 'loop crossover pipe
s.
1. Transition to APf1/N5500I019 (loss of Residual Heat Removal System)
2. NC loop crossover pipe
c.

t...Remain in APJ1fAl550OI021 {Shutdown lOCAl

2. Reactor vessel D.
1. Transition to AP/1IAf550OI019 (loss of Residual Heat Removal System)
2. Reactor vessel o applicants chose answer A o applicants chose answer B 4 applicants chose answer C 3 applicants chose answer D Answer D was designated as correct based on the following:

The stem told the applicant that the ND suction relief was leaking. The applicant was required to know that the ND relief valves discharge to the PRT. The applicant was also required to know that AP127 will transition the operator to AP/19 if PRT level is increasing without indication that the input is from the NC system pressurizer.

The symptoms of this event would be pressurizer level and pressure decreasing and PRT level increasing. These symptoms match the entry conditions for AP/19 rather than AP127. (See attached.) Therefore, entry into AP127 was an incorrect diagnosis of the event.

Page 1 of8

Post Exam Comment 6 In the event of a leak step 3 of AP/27 will stop any ND pump taking suction on an NC system loop to protect the ND pump from damage.

AP/27 step 4 looks for PRT level increasing without indication of safety valve input. The intent of this step is to rule out input to the PRT from the pressurizer safety. If the safety valve is not discharging to the PRT, then the procedure assumes the input is from the ND system and the operator is directed to transition to AP/19. The only indication available for the operator to determine if the PRT input is from a pressurizer safety is safety valve tailpipe temperature and acoustic flow monitors. The question did not provide the applicant the status of those indicators.

Additionally, the question didn't provide the applicant with information about the status of PRT level before or after the actions of AP127 were performed. AP127 step 4 doesn't specifically state pressurizer safety. The ND relief valve is a safety valve which discharges to the PRT. The background document for that step doesn't clarify that the step applies to pressurizer safety valves. The stem stated that the ND relief was open can be interpreted as indication that a safety is discharging to the PRT. Procedure change request number CNS-2008-5216 has been submitted to revise AP127 step 4a to state "pressurizer safety valve."

All of the applicants correctly answered part 2 of the question. However, the applicants were not given information about pressurizer safety valve status and PRT level response which was needed adequately determine the proper procedure flowpath.

Given the ambiguity of AP/27 step 4, and the lack of information to properly evaluate the status of the pressurizer safeties and PRT level we request that question 76 be deleted.

Page 2 of8

Post Exam Comment 6 eNS SHUTDOWN lOCA PAGE NO.

API1IA!5500m21 301162 Revision 29 AcnON/EXPECTED R£SPO~SE RESPONSE NOT OBTAINED c.. Operator Actions

1.

Monitor Enclosure 1 (Foldout Page).

2.

Verify any NlDtrain suction - ALIGNED TONClOOP~

3.

.lEAl MYJlMf either of thefolmwiDg cond.Itions occurs:

_. ?zr ie'Iet-LESSTHAN 11% (20% ACC)

QB

_. NC System subroofing based on a:Jffi exit TiCs - lESS THAN O'"F.

<I. stop NO pump(s) with suction aiigned toNC loop.

b. Ensure the following valves - CLOSED:
  • 1 NO-32A {NO Train 1A Hot leg lnj 1:SOl}

.1ND-65B (NO Train1B Hot leg Inj lsoI).

_.oo.m Step 5.

Page 3 ofS

Post Exam Comment 6 CNS APl1/.A155OOID21

4.

Verify leak is on ND:

3. Vemy indications of a leak 00 NO::
  • Plam alarms arid indications -

INDICATE LEAK OUTSIDE CONTAINMENT OR SHUTDOWN lOCA

  • PRT level -INCREASING WITHOUT lNDICATION OF SAFETY VAlVE INPUT.

D. GO TO AP!1!N55OO!019 (Lass of Residua! Heat Removal System).

5.

Initiate containment evacuation.

Page 4 of8

Post Exam Comment 6 CNS AP/1JAl5500ID21 B.. Svmntoms pZf*leveI - DECREASING NC WJR Pressure - DECREASING SHUTDOWN lOCA NC Hot leg LIR Pressure - DECREASING 1An-1l, Ail ""ICE CONO l.OWER INLET DOORS OPEN" - lIT He System subcooling - DECREASING UNCONTROLLED Any of the following EMF indications -INCREASING OR IN ALARM:

., EMF-41 {AID[ BJag Venl:Uationj

., 1EMF-38 (Containment Pamculate)

., 1EMF-39 (Containment Gas)

., 1EMF-46A (Componenl '~ing Train A)

., 1EMF-46B (Component Coaing Train B).

Containment floor and equipmeftt sump leveI(s) - INCREASING.

PAGE NO..

2 of 162 Revision 29 Page 5 of8

CNS AP11JN55OOlD19 Cue II.

l.eak in NO:

.. pzr level - DECREASING Post Exam Comment 6 LOSS Of RESIDUAL HEAT REMOVAL SYSTEM

.. NC ~

- DECREASING

.. NC ~

level-DECREASING

  • PRT level-INCREASING

.. NO How - HIGH

.. Any of the following EMF iOOicomons - INCREASING OR IN ALARM:

  • EMF-41 (Aux Bk1g Ventilation)
  • Containment sump level-INCREASING

.. 1.1\\0-10, Cl1 "NO & NS ROOMS SUMP LEVEL EMERG HI" - UT

  • 1.1\\0-10, C!2 "NO 8. NS ROOMS SUMP LEVEL HI-Hr - UT
  • Refureiing C3im1llevei - DECREASING.

PAGE NO.

201'154 Revision 51 Page 6 of8

Post Exam Comment 6 Page 7 of8

'hnM~

\\lkw77'rt a_U;i tWlWMt DI!t!

~!

Post Exam Comment 6 CNJ.~.oon!5 APIUM$OOttm S~l..{)CA Ooeu:tmL'lU Su~R.eq~

~

  • tp4lttn mtel"trle~ ~witli_~_

of~~_M 1!>pM I!QUAM!r TIle };il)mmOill rolW¥mru_~*_* _kh~

b:i d!t PIT. iftfuli ill ~tWiq, 1m ~0iI' ~

~

~iW tfulli rill ~limm~¥.

~ImIl!'hWII mAPM.

Page 8 of8

Post Exam Comment 7 Question 77 Unil 2: is at 3% power. Given the following sequence of e\\1eflts:

12101108 1100 LA NI pump tagged to replace the motor cooler.

12103108 050028 DJG tripped on high vibration during pedormance of PTi2fAJ4J5Oloo2B (Diesel Genemtor2B Operability Test).

12103108 0100 You canplete turnover and take the position of CRS.

1. What is the latest time that entry into Mode 3 is required per Technical Specifications assuming both components remain inopembae?
2. When yoo take shift duty at 0100, can the ECCS design criteria for a large break lOCA be assumed to be met?

A

1. 12103100 1200
2. Yes B.
1. 12103JOO 1200
2. No C.
1. 12103100 1600
2. Yes D.
1. 1210310B 1600
2. No o applicants chose answer A 1 applicant chose answer B 1 applicant chose answer C 5 applicants chose answer D Reference provided The answer C was designated as correct due to the following:

The developer considered the basis for Tech Spec 3.8.1 which states either off site or on site power is available, and in this scenario off site power is maintained. Therefore, entry into 3.0.3 was considered to be the time that the design criteria were no longer met. Tech Spec 3.8.1 action B2 requires declaring 2B NI inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after 2B DG was declare inoperable. Thus, at 0700 2B NI is still considered operable; so, the ECCS design criteria for a large break LOCA was met.

All of the applicants that selected answers C and D understood that the 2B NI didn't have to be declared inoperable until 0900. Those who selected answer D considered design criteria to be separate from the declaration of inoperability. Declaration of inoperability is an administrative Page 1 of3

Post Exam Comment 7 function. The Regulatory Compliance department was asked to interpret this scenario.

Regulator Compliance contacted Excel Services who writes our Tech Specs. The following is their reply:

From: Dan Williamson [dan.williamson@excelservices.com]

Sent: Monday, December 15, 2008 8:32 PM To: pwrog@excelservices.com

Subject:

RE: Initial License Exam TS Question Few comments:

>> If not yet adopted, consult TSTF-273 for "intent clarifications" related to this situation.

>>The "ECCS design criteria for a large LOCA" is different than "loss of safety function" typically used in TSpecs / SFDP. The "design criteria" was not met when the first lA SI was inop--

> loss of single failure protection.

>> The example is a bit confusing when the ending question mentions "when 2A DG becomes inoperable" -- prior to this, 2A DG was not at issue (?) Seems a typo of some kind.

>> The [A-SI + B-DG] is still is not a "loss of safety function" (see TSTF-273). The directed declaration of B-SI inop at 4 hrs due to B-DG inop (and one can wait the full 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to make this declaration) can be argued to be the first time that a "loss of safety function" exists --> both A & B SI inop.

Dan Williamson EXCEL Services Corporation Main Offc/Cell: (904) 272-5300 Given that the design criteria were not met when 2A NI pump was declared inoperable, we request that the correct answer be changed to D.

Page 2 of3

Post Exam Comment 7 3.8.1.

The OPERABILITY of the AG electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AG sources OPERABLE during Accident conditions in the event of:

3.5.2

a.

An assumed loss of all offsite power or all onsite AG power; and

b.

A worst case single failure.

The OPERABILITY requirements for the EGGS are based on the following LOGA analysis assumptions:

a~

A large break LOGA event, with loss of offsite power and a single failure disabling one EGGS train; and

b.

A small break LOGA event, with a loss of offsite power and a single failure disabling one EGGS train.

Page 3 of3

Post Exam Comment 8 Question 83 Unit '1 is operating at 100°" power. Unit 2 is in No Mode. The conlrol room has become uninhabitable due to chlorine gas. intrusion and cmtrm has been shifted to the Auxiliary Shutdown Complex per AP/1fAJ550OlO11 (loss of Control Room).

1. How is adequate primal"j side inventory assured?
2. For the situation above, which one oftlle following sets of valves would require a tempora,1"j mooification 10 prevent them from au10maticafty aligning should a safety injection occur?

A.

1. Automatic swap of NV pump suctions to the FWST
2. 1NI-9A (NY Prop GIL Inj 1so1) and 1NI-108 {NY Prop GIL Inj 15(1)

B.

1. AutomatiC swap of NV pump suctions 10 the FWST
2. 1 NO-26 (NO Hx 1A Outiet CtrQand 1 NO-50 (NO Hx 18 OutletCtrl)
c.
1. Manual swap of NV pump suctions 10 the fWST
2. 1NI-9A {NY Pmp CJllnj lsol} and 1NI-108 (NY Pmp Gllinj Isol)

O.

1. Manual 'swap of NV pump suctions to the FWST
2. 1 NO-26 (NO Hx 1A Outiet Ctr~and '1 NO-50 (NO Hx 1B Outlet Ctrl) 1 applicant chose answer A 3 applicants chose answer B 1 applicant chose answer C 2 applicants chose answer D Answer D was designated as the correct answer for the following reason:

When plant control is aligned to the control room and a VCT Lo-Lo Level (4.3%) is detected the suction valves from the FWST open and the suction valves from the VCT close. The Design Basis Document for Loss of Control room states that all automatic NV functions are disabled when control is transferred to the Auxiliary Shutdown Complex (ASC). The DBD also states that the suction valves from the VCT open upon transfer to the ASC and are blocked from closing on Lo-Lo Level. The Loss of Control Room lesson plan states the same information found in the DBD. The DBD for the NV system doesn't discuss how the suction valves from the FWST are affected by swapping control to the ASC. Additionally, AP/1/A/5500/017 (Loss of Control Room) Enclosure 1 page 12 directs manual alignment of the NV pump suction to the FWST if VCT level is < 23%. The background document for the procedure states that, "All automatic transfer of the NV pump suction to the FWST on low VCT level is lost when control is transferred to the ASP." Based upon controlled information available to the question Page 10f3

Post Exam Comment 8 developers they determined that the automatic swap of the NV pump suction to the FWST on 10-10 VCT level would not occur.

During the exam review the applicants stated that they were taught that the swap to the FWST will occur automatically. The instructor who teaches the Loss of Control Room had determined that the suction valves from the FWST are unaffected by the swap to the ASC, and had included that information in the notes section of the Power Point presentation used to teach the lesson. A copy of the Power Point presentation had been provided to the applicants. The notes section of a single slide of the presentation includes the statement, "NV-252A & NV-253B will auto open on Lo-Lo VCT level, but NV-188A & NV 189B will not close." Brian Woolweber (Senior Engineer) and Nick Burgess (Engineer III) reviewed the electrical drawings and confirmed that the FWST suction valves are unaffected by a swap to the ASC and will in fact open on a VCT Lo-Lo-Level signal. (See attached note from engineering.)

Answer B is technically correct because if the suction of the NV pumps isn't manually aligned to the FWST when VCT level is < 23%, then the valves will automatically open on Lo-Lo VCT level and primary side makeup would be assured.

Answer D is technically correct because the suction supply valves from the FWST are manually opened per the requirements of procedure AP/17 to ensure primary side makeup is assured.

We request that both answers B and D be accepted as correct.

Page 2 of3

Post Exam Comment 8 In researching the applicable electrical elementary drawings, it was determined that both NV252 and 253 will still be able to open once a LO-LO signal has been received from veT level.

Neither of these valve are affected by the transition to the ASP, thus there is no contact that would prevent a signal to open if the LO-LO setpoint is research. Furthermore, it was confirmed that if this LO-LO setpoint is reached, while in normal control, both NV188 and 189 would close, performing the swap to FWST. If control is swapped to the ASP both of these valves are forced open and are prevented from closing, as stated below. These conclusions have also been verified by Brian Wool weber. Hope this clears up any confusion.

Nick Burgess CNS APf1/A.f55O{}1017 I

ACTION/EXPECTED RESPONSE

15. (CoOOnued) lOSS OF CONTROL ROOM Endosure 1-Page 12 of 19 ASP Operator AcOOtlS PAGE 1140...

1801'11 Revision 41 I

I 6} IF pzr lewl is decreasing, THEN:

a} Notify Unit 1 Aux Bldg operator to align UniI: 1 NV pump suam to fWST. REFER lllEndosure 4 (Aux Bldg Operator AcIoos), step 5.

_ bl WHEH charging pump sucioo is aligfBi to FWST, II::IEt! start additional NV pump(s) as required to increase pzr level.

7} If AIMlIJlIIf VeT level decreases to 23%, THEN nOOfy Unit

'I A.ux Bldg operator to align Unit: 1 NV ptmlp suction to fWST. REFER III Enclosure 4 (Aux Bldg Operator AcIoos), step 5.

I Page 3 of3

Post Exam Comment 9 Question 87 The night shift smveillance readings for lake Wylie temperature over the past severnl days are as follows:

8101 108 - 81..50" F.

8102108 - 8825" E 8103108 - 89.00'" F 8104108-89.75" F 8105108. - 00.50" F

1. Assuming lake tempernture continues to increase at a constant rnte, on what date will lake Wylie temperature first exceed the requirements of SlC 16.9-14 (lake Wylie Water Temperature)?
2. What affect, jf any.,. wig this higher lake temperaiure have 00 the ability of the NS system to affect containment pressure following a large break tOeA?

A.

1. 8109J08
2. Minimal impact prior to ice meat, but signifICant impact later tn the accident sequence when the ice has been depleted.
5.
1. 8109J08
2. Minimal impact during the entire accident sequence §tnee lake temper.arure is still below the design basis accident assumptions.

C.

1. 8112J08
2. Minimal affect prier to ice melt but significant affect later in the accident sequence when the ice has been depleted.

D.

1. 8112J08
2. Minimal mpact. during the entire ac.cident sequence since lake temperature ts sm below the design basts accident assumptions.

o applicants chose answer A 1 applicant chose answer B 2 applicants chose answer C 4 applicants chose answer D Answer C was designated as the correct answer for the following reasons:

During the first stage of a LOCA the ice condenser is the major heat sink for cooling the containment atmosphere. Mter the ice has melted then NS becomes the major heat sink. RN flow rate to the NS heat exchangers is a constant value; therefore, the temperature of NS is directly related to RN temperature. Once the ice has melted containment pressure will be related to the NS temperature, and if NS temperature is higher, then containment pressure will be higher.

Page 1 of 4

Post Exam Comment 9 The higher NS temperature would have little to no affect on containment pressure before the ice melts because the ice is the major heat sink:, but pressure would be affected after the ice was melted. (See attached excerpt from Tech Spec 3.7.9 bases.) The developer included the word significant in the second part of the answer because the difference in NS temperature will be observable to the operator in the control room.

If the Lake Wylie temperature reaches the SLC limit, the remedial action is to align at least one train of RN to the Standby Nuclear Service Water Pond (SNSWP). The Tech Spec basis for the (SNSWP) states, "NSWS (Nuclear Service Water System) temperature influences containment pressure following a Loss of Coolant Accident and offsite dose following a Main Steam Line Break. The containment peak pressure analysis can accommodate NSWS temperatures up to lOO<lp." Since the Lake Wylie temperature, thus NSWS temperature had not exceeded lOO<lp the applicants who chose answer D determined that the elevated RN temperature would not have a "significant" affect on containment temperature. Therefore, they rejected answer C and selected answer D as the most correct for the given conditions.

Question 2 asked the applicant to compare the affect of the higher lake temperature, but it doesn't ask which higher temperature to use, the last observed or the SLC limit, or what temperature it should be compared to. In reference to answer C for question 2, the first part of the answer is correct, but statement that the affect would be significant cannot be supported since question didn't imply how big a temperature difference to consider. Consequently, answer C cannot be supported as correct.

Answer D is a correct answer since all of the temperatures given for comparison are below the analyzed value of lOO<lp. Thus, the impact or consequence would be minimal throughout the entire sequence of the accident.

We request that the correct answer be changed to D.

Page 2 of 4

Post Exam Comment 9 Tech Spec 3.7.9 Standby Nuclear Service Water Pond basis states the following:

APPLICABLE The SNSWP is the seismically-assured sink for heat removed from the SAFETY ANALYSES reactor core following all accidents and anticipated operational occurrences in which the unit is cooled down and placed on residual heat removal (RHR) operation.

The Main Steam Line Break dose analysis assumes an activity release from the steam generators for the time required to cool the Reactor Coolant System (RCS) to 210°F. The NSWS temperature assumed in the current analysis is 95.5°F. This assumption prevents the RCS cool down time from exceeding that assumed in the current Main Steam Line Break dose analysis. Therefore, the Main Steam Line Break is limiting with respect to the assumed NSWS temperature.APPLICABLE SAFETY ANALYSES (continued)

To ensure that the assumptions related to NSWS temperature in the safety analyses remain valid and to ensure that long term NSWS temperature does not exceed the 100°F design basis of the NSWS components, a limit of 95°F is observed for the initial temperature of the SNSWP. This temperature is important in that it, in part, determines the capacity for energy removal from containment incorporated into the peak containment pressure analysis. NSWS temperature is also important in determining the time required to cool the RCS of a nuclear unit after the occurrence of an accident. This in turn determines the extent of releases of radioactivity to the environment following a Main Steam Line Break.

The peak containment pressure occurs when energy addition to containment (core decay heat) is balanced by energy removal from the Containment Spray and Component Cooling Water heat exchangers.

This balance is reached after the transition from

  • ection to cold recirculation and after ice melt.

Page 3 of 4

Post Exam Comment 9 16.9 AUXILIARY SYSTEMS 16.9-14 Lake Wylie Water Temperature COMMITMENT The water temperature of Lake Wylie shall be ~ 95.5°F when aligned to the Nuclear Service Water System (NSWS).

APPLICABILITY:

MODES 1, 2, 3, and 4.

REMEDIAL ACTIONS A.

CONDITION REQUIRED ACTION COMMITMENT not met.

A.1 Align at least one NSWS loop to the Standby Nuclear Service Water Pond (SNSWP).

COMPLETION TIME Immediately Page 4 of 4

Post Exam Comment 10 Question 89 Unit 1 is operating at 100% power. Given the fcllOW'ing:

1A DJG was manuai¥ started by NlOs for monthly surveiliam:::e tes#:ng A grid instability and relay failures caused all Unit 1 Switc:hyam PCBs to open 1B DJG failed to start Annunciator DIG 1A Panel, Al4 "TRIP lOW PRESS LUBE OIL" - UT The ensuing transient resull:ed n a 16 SlG tube rupture Which procedure will be used to isolate the ruptured SlG in this situation, and what procedural guidance is given regarding isolation of the ruptured steam generator?

A EP/1JA/50001E-3 (Steam GeneramrTube Rupture) is used to isolate the ruptured SIG as soon as it is identified B.

EP/1/A/50001E-3 {Steam Generator Tube Rupture} is used to isolate the ruptured SIG only ifSlG NR level is greater than 11%.

C.

EP/11A/50ooIECA-O.O {loss of AI AC Power} is used to isolate the ruptured SIG as soon as it is idemifled D.

EP/lIA/50ooIECA-O.O (loss of A~ AC Power) is used to isolate the ruptured SIG only if SJG NR level is greater than 11%.

4 applicants chose answer A 2 applicants chose answer B o applicants chose answer C 1 applicant chose answer D Answer B was designated as the correct answer based on the following:

The developer was considering that to isolate a ruptured S/G (RSG) a level of> 11 % is a precondition that must be satisfied. However, to completely isolate a RSG steps 3 - 6 within EP/E-3 must be performed, and step 6 which completes the isolation can only be performed if RSG level is > 11 %.

The question didn't differentiate between initiating the isolation of an RSG and completely isolating an RSG.

Page 1 of 4

Post Exam Comment 10 Answer A is correct because, once steps 3, 4, & 5 are reached, the operator is required to perform these actions as soon as the RSG is identified. There are no preconditions to performing these steps.

Answer B is correct because it is part of the guidance which completes the isolation of the RSG by isolating the auxiliary feedwater supply when level is > 11 %.

If the question had asked for the guidance to completely isolate the RSG, then there would be no correct answer to the question; however, the question asked for the procedural guidance regarding isolation which is found in both answers A & B, so both answers A and B are correct.

We request that both answers A and B be accepted as correct.

Page 2 of 4

Post Exam Comment 10 eNS EPI1JAl5OOOIE-3 STEAM GENERATOR TUBE RUPTURE PAGENG 3 of 100 Revision:!

ACTIONiEXPECTEO ~SPONSE

3.

Vemy at least one intact SIG -

AVAIlABLE FOR NC SYSTEM COOlOOM.

I

4.

IsOOlte steamOow from ruptured S!G(s}

as follows:

d. Verny all ruptured SfG(s) PORV -

CLOSED.

c. Isolate bfawOOwn and steam drain 00 all rupmred SfG{s} as foi!aivs:
5.

Close the following valves on all ruptured. SJG(s):

.. MSlV

=.. MSIV byp;lIss '113M!.

6.

Control ruptured. SlG(s) level as follows:

a. Verny ruptured SfG(s) N!R ~

GREATER THAN 1:1% (29%, ACe).

Maintain one SJG availaible for NC System cooldown in subsequent steps.

a. Peiform the following:
1).IE any rupmred S/G is also faLdted" THEN 00 not establish feed now to tile rupmredl SIG unless needed for NC System coolOO'wn.
2) IF any ruptured SlO{s) is ootfaLdted OR is required for cooldown, !I::IS!t:

<I) Establish and maintain feed now to affeded SfG{s),

1:1) m:IEK aft'ected SfG(s) N!R level greaterthan 11% (29% ACC),

IHfK peoorm steps 6.b and 15.c.

Page 3 of 4

Post Exam Comment 10

6. (Continued)
b. Isolate feed flow to all ruptured SIG(s) as follows:
6. (Continued)
c. IF AT ANY TillE flIiPWred S!G(s) NIH level is less than 11'% (29% ACC}.

llWt perform. step fl.

Page 4 of 4