HNP-13-101, 301 Initial Exam Post Exam Comments

301 Initial Exam Post Exam Comments

ML13295A412
Person / Time
Site:	Harris
Issue date:	10/17/2013
From:	Sylvester W Duke Energy Corp
To:	Mark Franke Division of Reactor Safety II
References
50-400/13-301, HNP-13-101
Download: ML13295A412 (27)

Text

Harris Nuclear Plant III) 5413 Shearon Harris Rd ENERGY New Hill NC 27562-9300 October 1, 2013 Serial: HNP-13-101 Mr. Mark E. Franke U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, GA 30303-1257 Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400

Subject:

Reactor and Senior Reactor Operator Initial Examinations 05000400/2013301

Dear Mr. Franke:

Encbsed is the post-examination package for the Reactor and Senior Reactor Operator Initial Examinations given at the Harris Nuclear Plant September 9, 2013, through September 25, 2013.

Included from the administration of the Written Examination are the student cover sheets, answer sheets, master examinations, answer key, log of applicant questions and answers, and the student seating chart. Also, pertaining to the Written Examination, are four post-examination comments (Question #26, #52, #69, and #85).

If you have any questions regarding this submittal, please contact me at (919) 362-3252.

Sincerely, W. Arthur Sylvester Superintendent Operations Training (designee)

Harris Nuclear Plant WAS/mgw Enclosures c: Mr. J. D. Austin (NRC Senior Resident Inspector, HNP) w/o Enclosures Mr. A. Hon (NRC Project Manager, HNP) w/o Enclosures Mr. V. M. McCree (NRC Regional Administrator, Region II) wlo Enclosures

Mr. Mark E. Franke Serial: HNP-13-1O1 bc: (w/o Enclosures)

Mr. D. H. Corlett Mr. J. D. Dufner Mr. D. L. Griffith Mr. J. R. Horton Mr. E. J. Kapopoulos Jr.

Mr. R. J. Kidd Ms. T. M. Midgette Mr. S. Schwindt Mr. M. G. Wallace Mr. F. L. Womack Licensing File(s) (2 copies)

Nuclear Records

2013 HNP Licensed Operator Written Exam question #26 Post Exam Comment On September 26, 2013 the HNP Written Exam was reviewed with all participating candidates.

During the review four questions were identified as inconsistent with the answer key. RO questions 26, 52, 69 and SRO question 85. Based on the review of Harris Plant approved procedures the Harris Training Department and the Harris Operations Department supports post written exam changes.

HNP contends that question #26 has only one correct answer. The correct answer is answer C and not the keyed answer which was answer A.

Answer C is correct for the following reasons. From the information provided in the question stem there are two ORANGE conditions that exist, CORE COOLING and CONTAINMENT.

EOP-USER S GUIDE states that the hierarchy of entering the Functional Restoration Procedures is:

1. Subcriticality (S)

2. Core Cooling (C)

3. Heat Sink (H)

4. Integrity (P)

5. Containment (Z)

6. Inventory (I)

Since CORE COOLING is ranked higher than CONTAINMENT answer C is correct.

CORE COOLING (CSF-2) is ORANGE due to CETs less than 1200°F (given 740°F),

subcooling less than 10°F (Tsat for 240 psia is 397.4°F, given CETs were 740°F), No RCPs running (offsite power has been lost which would render the RCPs powerless), CETs >730°F (given CET s are 740°F), and RVLIS full range greater than 39% (given RVLIS level of 60%).

CORE COOLJNC CSF2 COIE EXIT TC GREA1EA 1HM 200F RED roTc)

RE FRCl GETER THAN TTF GE j

ORAN GE DHTTC j RCSSHCR LESS THAN FLL YELLOW 7F SF H FRC3 ANGE ORANGE I YELLOW FRC.3 ACT SJHCCELhC TAEATER ThAN GREEN

2013 HNP Licensed Operator Written Exam question #26 Post Exam Comment The other ORANGE condition (incorrect answer A) that exists from the questions stem is CONTAINMENT (CSF-5). This is based on Containment pressure less than 45 psig (given 17 psig), Containment pressure >10 psig (given 17 psig), and no Containment spray (CT) pump running (given A CT pump tripped and no power to B CT pump due to B EDO has tripped and offsite power is lost rendering B CT pump powerless). Answer A is incorrect due to the above EOP-USERS GUIDE hierarchy which ranks CONTAINMENT below CORE COOLING.

CONTANMENT CSF5 CONTAINMENT PRESSURE GREATEN THAN 45 PUG RED GO TO FRZ.1 NO CONTAINMENT SPRAY PUMPS A1jNHNG ORANGE GO TO CONTAINMENT PRESSURE GREATER THAN TO PUG AT LEAST ONE CONTAINMENT SPRAY PUMP RUNNING 1

YELLOW GO TO ERZ.1 CONTAINMENT PRESONRE AiDE NANTE LESS IHHN 45 PUG CONTAINMENT SWAP LEURL h ORANGE GREATEN IHAN 96 INCHES GCTO FRZ.2 CONTAINMENT PRESSURE 1-1105 RANGE GNAT POST LOGS LESS ThAN IA PSIT RP-IUAT1CN MONITORS GREATER ThAN ALANIA SETTCINT 1 YELLOW GO TO AlOE HENCE CONTAINMENT SOAP LESEL FRZ.3 PESO THAN ISO INCHES HIGH RANGE TOUT PSPT LA p GREEN The recommendation from Harris Nuclear Plant is to accept answer C as the correct answer based upon NUREG 1021 ES-403 D. 1.b page 3 guidance. There is technical information that supports a change in the answer key.

Attached:

HNP 2013 Written Exam question #26

References:

EOP-USERS GUIDE, pages 20-21 (rev. 41)

EOP-CSFST, pages 4-5 (rev. 11)

2013 HNP NRC SRO

26. 2013 NRC RO 026 The crew has transitioned to E-1, Loss of Reactor or Secondary Coolant and is presently evaluating the RHR System capable of Cold Leg Recirculation.

The following conditions exist:

- Offsite Power has been lost

- EDG B has tripped CNMT Pressure is 17 psig and rising

- CNMT High Range Rad Monitors are in alarm

- CNMT Wide Range Sump Level is reading 211 inches

- RVLIS Full Range Level is reading 60%

- RCS Cold Leg Temperature is reading 265°F

- RCS Wide Range Pressure is reading 225 psig

- Core Exit Thermocouples are reading 740°F

- Containment Spray pump A has tripped Which ONE of the following is the procedure that the crew is required to implement at this time?

A FR-Z.1, Response to High Containment Pressure B. FR-Z.2, Response to Containment Flooding C. FR-C.2, Response to Degraded Core Cooling D. FR-P.1, Response to Imminent Pressurized Thermal Shock Thursday, September 05, 2013 7:40:00 PM 75 Rev. FINAL

2013 HNP NRC SRO Plausibility and Answer Analysis Reason the answer is correct:An ORANGE path exists due to containment pressure greater than 10 psig with no CNMT Spray Pump running.

A Correct.

B Incorrect. Plausible because the containment sump level (211 inches) is greater than the 196 inch value for an ORANGE path to exist, but this is not correct due to containment pressure being greater than 10 psig.

C Incorrect. Plausible because the Core exit temperature is above the 730°F value (740°F) for an ORANGE path to exist, but this is not correct due to not having the confirmation of RVLIS Full Range level being less than the 39%.

D Incorrect. Plausible because the RCS Wide Range Pressure is higher than the low temperature overpressure limit, but this is not correct because the RCS Cold Leg temperature is above the RCS integrity PTS minimum temperature of 240°F.

Thursday, September 05, 2013 7:40:00 PM 76 Rev. FINAL

2013 HNP NRC SRO APE: 069 Loss of CNMT Integrity I 5 WEI4 EAI .1 Ability to operate and I or monitor the following as they apply to the (High Containment Pressure): Components, and functions of control and safety systems, including instrumentation, signals, interlocks, failure modes, and automatic and manual features.

(CFR: 41.7 I 45.5 /45.6)

Importance Rating: 3.7 3.7 Technical

Reference:

EOP-CSFST Rev. 9 pg 3 of 3 (side 2)

References to be provided: None Learning Objective: EOP-LP-3.13, Obj I Question origin: NEW Comments: NONE Tier/Group: TIG2 Thursday, September 05, 2013 7:40:00 PM 77 Rev. FINAL

GUI)E USERS 52 Control Room Usage of Status Trees 5.2.1 Desa*3tioo Status Trees are used to evaluate the current state of predetined Critical Safety Functions.

Status Trees ask a series of questions about plant conditions, and in general, each question asked depends on the answer to the previous question. This dependency results in a branching pattern, which is referred to as a ree.

There are six different trees, each one evaluating a separate safety aspect (Critical Safety Function) of the plant A hard copy of the Status Trees is contained in procedlie EOP-CSFST Electronic equivalents are displayed on ERRS using the SPDS functions, At any given time, a Critical Safety Function status is represented by a single path through its tree. Slice each path is unique, it is uniquely labeled at its end pont, or temirvis. This labeling consists of color-coding andlor tee-pattern-coding of the terminus and last branch line, plus a transition to an appropriate FR if required by that safety status. If the status is norreal for a particular Critical Safety Function, no transition is specified, and the condition is clarified by the words CSF SAT.

Color-coding can be either RED, ORANGE, YELLOW, or GREEN, with GREEN representing a satisfied safety status. Each non-green color represents an action level that should be ad&essed according to the rules of implementation as discussed in Section 523.

522 Priority of Status Trees The six Critical Safety Functions and their associated Status Trees are prioritized as Iolsws:

1. Suticriticality(S)

2. Core Cooling (C)

I Heat Sink (H) 4 Integrity (P)

5. Containment (7)

6. Inventory (I)

The Status Trees are arranged in EOP-CSFST and on SPDS consistent with their priority to facibtate monitoring and proper implementation. When pronouncing the status tree name or the FR ixocedlies to which it is linked, the letter designating the function protected should be pronounced. For example, FR-C2 should be pronounced FR-G-Twe.

EOP-USERS GUIDE I Rev. 41 Page 20 of 66

GUIDE UsERS 5.23 General Usage The Status Trees are always evaluated in order of their pflority. When manually monitoring the Status Trees, questions are answered based on plant conditions at the time, and the appropriate branch line followed to the next question. An individual Status Tree evaluation is complete when the user amves at a color-coded or line pattern-coded terminus. ERFIS continually updates the status of each Status Tree.

Since the initial actions of E-O should be effective in dealing with any non-satisfied CSFST condition, instructions to begin monitoring the CSFST are not given in E-O until the initial actions are completed. My time E-O is exited to transition to another EOP, FRs are to be implemented as dictated by the status of the CSFSTs.

Exceptions to this are transitions made ot of E-O early due to an A1WS. loss of secondary heatsink,orlossofallACpower. lnthesecases,monitonngofCSFSTsisperfonnedas directed by steps within these procedures. For exanWle, an ATWS with a loss of all AFW occurs and a transition is made from E-0 to FR-Si. At the end of this FR, the operator is directed to RETURN TO procedure and step in effect AND monitor the CSFSTs. The operator transitions back to E-O, and notes that the Heat Sink status tree indicates a valid RED condition. He then must transition to FR-Ri to address the less of secondary heat sink.

Once the operator is directed to monitor the CSFST5, the rules of implementation apply during all subsequent EOP Network actions, including EOPs that may not have the step Monitor CSFSTs.

The foUoNing conventions apply when reviewing the RED and ORANGE CSFSTs for FR implementation:

• It any RED terminus is encountered, the operator is required to immediately stop any Optimal Recovery procedure (E, ES, ECA) in pioess and to perform the FR required by the terminus.

• It, during the performance of any RED-Condition FR, a RED condition of higher priority anses, then the higher priority condition should be addressed first, and the lower priority RED-condition FR suspended. Otherwise, the FR must be performed to the point of a defined transition regardless of whether the RED condition has been cleared during performance of the FR.

• If any ORANGE terminus is encountered, the operator is expected to monitor afl of the remaining trees, and then, if no RED is encountered, suspend any Optimal Recover procedure in progress and perfomi the FR requWed by the ORANGE terminus.

• If during the pertonnance of a ORANGE-condition FR, any RED condition or higher priority ORANGE condition arises, then the RED or higher priority ORANGE condition is to be addressed first, and the orignal ORANGE-Condition FR is suspended. Otherwise, the FR must be performed to the point of a defined transition regardless of whether the ORANGE condition has been cleared during the performance of the FR.

There are FR5 that may be entered due to either a ORANGE or RED terminus. In applying the above rule for these FR5, if a ORANGE condition deteriorates into a RED condition, the operator should continue with implementation of the procedure. He should not stop and then re-enter the procedure at Step 1. The FR that can be entered from either a ORANGE or RED terminus are EOP-FR-S.1, EOP-FR-P.l and EOP-FR-Z,1. (References 222.20 and 22326)

EOP-USERS GUIDE I Rev. 41 I Page 21 of 68

CORE COOLiNG CSP2 CORE EXIT TC GREA1ER THAN 12OOF RED GD TO FC.1 RVLIS FUIi RANGE LESS ]NAN 39 I

CORE EXIT TC GREATE? THAN )iDF 4 r RVLIS FULL RANGE GREATER THAN 39%

ND RCP RLNNING vLIS FULL RANGE LESS THAN 39%

OR AN CORE EXIT TC LESS THAN 73DF RCS SJDCOOLING LESS THAN RVLIS FULL RANGE 1OF [4ODFJ_ C GREATER THAN 39%

2OF [F] U RVLJS DYNAMIC HEA) RANGE LESS THAN TALE

,- ORANCE GO TO 6D% 3 RC CORE EXIT TC AT LEAST ONE RP R,JNNING 3Z 2 RC W FC,2 2Z I LESS THAN I2OOF RVUS DYNAMIC HEAG RANGE GREATER THAN TARLE YE L LC v GO TO FC.3 RCS SUSCOGLING GREATER ThAN 1CF [4Ofl C OREEN C

2OF T5OF1 M CSFSAT

CONTAINMENT CSE5 CONTAINMENT PNESSJRE GREATER THAN 45 P510 RED CO TO FRZ.i CANC[

j NO CONTAINMENT RAY PUMPS RUMMNG C-C TO CONTAINMENT PRESSJRE FRZ.1 GREATER THAN 10 P510 AT LEAST ONE CONTAINMENT SPRAY PUMP RUNNINC YELLOA CO TO FR Z. 1 CONTAINMENT PRESSJRE AIDE RANCE LESS THAN 45 P510 CONTAINMENT SUMP LEVEL CR A N C j

GREATER THAN 196 INCHES CO TO FRZ,2 CONTAINMENT PRESSURE pj- RANGE CNI.IT POST LOCA LESS THAN O P510 RAOIA11ON MONITORS GREATER ThAN ALARM SEflNT YELLCV.

AIDE RANGE CO TO CONTAINMENT SUMP LENEL FRZ.3 INlSSINCH_

RANE CNHT PPST L CR EEN C5FSAT

2013 HNP Licensed Operator Written Exam question #52 Post Exam Comment On September 26, 2013 the HNP Written Exam was reviewed with all participating candidates.

During the review four questions were identified as inconsistent with the answer key. RO questions 26, 52, 69 and SRO question 85. Based on the review of Harris Plant approved procedures the Harris Training Department and the Harris Operations Department supports post written exam changes.

HNP contends that question #52 should be deleted from the exam based on newly discovered technical information that supports that the question does not contain a correct answer.

The Recycle Evaporator Valve Gallery Radiation Monitor (keyed answer A) will not go into HIGH alarm due to high RCS activity. None of the remaining distracter choice radiation monitors for this question require entry into AOP-032, High RCS Activity when a valid HIGH alarm is received. Since none of the radiation monitors listed in the question would go into a valid HIGH alarm due to high RCS activity the question is no longer operationally valid.

Based on ACTUAL plant conditions the Recycle Evaporator Area Radiation monitor will not see a valid HIGH alarm condition due to high RCS activity. The Boron Recycle system has not been in operation since 1989 and will not be restored until a System Engineering and 1ST Engineering reviews are complete (Reference OP-109 section 5.3, BRS Evaporator Startup, note prior to initial conditions below).

5.3. BRS Evaporator Startup 5.3.1. Initial Conditions NOTE: The BRS Evaporator has not been operated since 1989 and PMs on much of the equipment have been canceled. Check calibration dates on equipment before restarting the BRS Evaporator. The BRS can not be operated clue to the isolation of Component Cooling Water and Auxiliary Steam to the system as directed by ESR 9800219. Restoration of CCW will require a System Engineering and 1ST Engineering review.

A procedure change has been generated (PRR 00631821) to revise AOP-032, Table 1, requesting the removal of Recycle Evap Vlv Gal monitor RM-1RR-3600 from the Fuel Breach Area Monitor table.

The recommendation from Harris Nuclear Plant is to remove question #52from the exam due to no correct answer based upon NUREG 1021 ES-403 D.1.b page 3 guidance. There is technical information that supports a change in the answer key.

Attached:

HNP 2013 Written Exam question #52

References:

AOP-032, High RCS Activity entry conditions including Table 1 Fuel Breach Area Monitors, OP-109, section 5.3.1 and PRR 00631821

2013 HNP NRC SRO

52. 2013 NRC RO 052 Which ONE of the following identifies an RAB radiation monitor that requires entry into AOP-032, High RCS Activity, when a valid HIGH alarm condition exists?

A RM-1 RR-3600, Recycle Evaporator Valve Gallery B. RM-21CR-3578A, Recycle Monitor Tank IA & 2A C. RM-1RR-3605A, Sample Room 1A Elev. 236 D. RM-1 RR-361 1, Recycle Holdup Tank Area Plausibility and Answer Analysis Reason answer is correct: Entry into AOP-032 is based on 2 conditions: the first is notification from Chemistry of an abnormal rise in RCS Dose Equivalent Iodine 1-131 activity or gross activity and the second entry is higher than normal raidation levels on ANY of the Fuel Breach Area Monitors. The Recycle Evaporator Valve Gallery radiation monitor RR-1 RR-3600 is one of the monitors that is found in Table 1 under AOP-032 entry condition radiation monitors.

A. Correct.

B. Incorrect. Plausible since this rad monitor is in the RAB and monitors the RCS inventory as part of the boron recycle system, however this is not correct because the tanks store boric acid for transfer to the Boric Acid tank. This boric acid will be blended with the reactor water make system to maintain the proper reactivity within the Reactor which makes the Rad monitor for that area unable to consistently predict the RCS activity levels.

C. Incorrect. Plausible since this rad monitor is in the RAB and the sample system is used to collect the RCS inventory used to determine the RCS activity and the sample station is shielded and designed to delayed the sample flow to allow the individual obtaining the RCS activity sample to be ALARA.

D. Incorrect. Plausible since this rad monitor is in the RAB and RCS inventory from the letdown system is collected in the RHT when placing Demin beds in seivice, but RCS inventor, is not continuously sent to the RHT which makes the Rad monitor for that area unable to consistently predict the RCS activity levels.

Thursday, September 05, 2013 7:40:02 PM 148 Rev. FINAL

2013 HNP NRC SRO 073 Process Radiation Monitoring (PRM) System 073 A4.02 Ability to manually operate and/or monitor in the control room: Radiation monitoring system control panel (CFR: 41.7 I 45.5 to 45.8)

Importance Rating: 3.7 3.7 Technical

Reference:

AOP-032, Entry conditions, page 3, Rev. 19 References to be provided: None Learning Objective: AOP-032 Objective 1 Question Origin: Bank Comments: None Tier/Group: T2GI Thursday, September 05, 2013 7:40:02 PM 149 Rev. FINAL

5.3. BRS Evaporator Startup 5.3.1. Initial Conditions NOTE: The BRS Evaporator has not been operated since 1989 and PMs on much of the equipment have been canceled. Check calibration dates on equipment before restarting the BRS Evaporator. The BRS can not be operated due to the isolation of Component Cooling Water and Auxiliary Steam to the system as directed by ESR 9800219. Restoration of CCW will require a System Engineering and 1ST Engineering review.

1. BRS Evaporator Feed System in service per Section 5.2.

2. Component Cooling Water available to Recycle Evaporator Package per OP-145.

3. Auxiliary Steam and Condensate System available per OP-i 30.01.

4. Waste Gas Processing available per OP-120.07.

5. A Waste Evaporator Condensate Tank has sufficient capacity to receive BR distillate, or permission of the CRS has been obtained to proceed without meeting this condition.

6. The BR Local Control Panel is in service and the controls listed below are in the position described:

• VENT COND VENT 3BR-189 switch is SHUT.

• PIK-316 EVAP PRESS CONT is in MAN with valve position indicator reading less than 3.

• BORIC ACID 3BR-200 switch is in RECYC.

• DISTILLATE CONTROL 3BR-40513BR-406 switch is in RECYCLE.

• EVAPORATOR CONDENSER VENT 3BR-419 switch is OPEN.

[OP-109 Rev. 55 I Page i2of 176J

PRR 00631821

SUBJECT:

REMOVE RM-3600 AS AN ENTRY CONDITION TO AOP-032 DESCRIPTION:

BASED ON ACTUAL PLANT CONDITIONS THE RECYCLE EVAPORATOR AREA RADIATION MONITOR WILL NOT SEE A VALID HIGH ALARM CONDITION EXIST DUE TO HIGH RCS ACTIVITY. THE BORON RECYCLE SYSTEM HAS NOT BEEN IN OPERATION SINCE 1989 AND WILL NOT BE RESTORED UNTIL SYSTEM ENGINEERING AND 1ST ENGINEERING REVIEWS ARE COMPLETE (REFERENCE OP-109 SECTION 5.3, BRS EVAPORATOR STARTUP, NOTE PRIOR TO INITIAL CONDITIONS (BELOW)). REFERENCE ESR 9800219.

2013 HNP Licensed Operator Written Exam question #69 Post Exam Comment On September 26, 2013 the HNP Written Exam was reviewed with all participating candidates.

During the review four questions were identified as inconsistent with the answer key. RO questions 26, 52, 69 and SRO question 85. Based on the review of Harris Plant approved procedures the Harris Training Department and the Harris Operations Department supports post written exam changes.

HNP contends that question #69 has two correct answers and answers B and D should be accepted as correct for final written exam grading. Answer B was keyed as the correct answer and answer D should also be accepted as correct based on newly discovered technical information that supports a change in the answer key.

Answer choice B is correct as keyed. Definition 3.0.2 for Troubleshooting in AP-929, Troubleshooting Guide, clearly includes pulling an annunciator card.

Answer choice D is also correct. Also included in the definition for Troubleshooting is Extended M&TE connections with reference to section 5.3.2.

Section 5.3.2 allows temporary M&TE Test point/jack connections in extended troubleshooting. This makes choice D correct. Further clarification of extended troubleshooting is also provided in definition 3.0.15 which is consistent with section 5.3.2.

The given plausibility analysis for answer D is not correct. The answer key plausibility statement is below.

D. Incorrect Plausible because extended M&TE connections are troubleshooting activities, however the use of test point/jack connections is not considered troubleshooting.

Extended M&TE connections ARE considered troubleshooting but the use of test point/jack connections IS considered troubleshooting as previously supported.

The recommendation from Harris Nuclear Plant is to accept two answers (B and D)for this question based upon NUREG 1021 ES-403 D.1.b page 3 guidance. This question should be accepted with two correct answers based on newly discovered technical information that supports a change in the answer key.

Attached:

I{NP 2013 Written Exam Question #69

Reference:

AP-929 Definition 3.0.2 (rev. 17)

AP-929 Definition 3.0.15 (rev. 17)

AP-929 Section 5.3.2 (rev. 17)

2013 HNP NRC SRO

69. 2013 NRC RO 069 Which ONE of the following identifies an ACCEPTABLE example of a troubleshooting activity in accordance with AP-929, Troubleshooting Guide?

A. Installing gags on valves B Pulling an annunciator card C. Replacing failed components on circuit boards D. Temporary M&TE Test point /jack connections Plausibility and Answer Analysis Reason answer is correct: Because AP-929, defines the following as examples of troubleshooting activities:

• Lifting or repositioning leads to confirm or identify a faulty component

• Pulling an annunciator card

• Repositioning valves or breakers to verify or confirm a malfunctioning component that cannot otherwise be checked while blocked out or removed from service

• Installation of instrument or air tubing for functional testing of equipment

• Extended M&TE connections A. Incorrect Plausible because gagging valves reduces leakage, however this is not considered troubleshooting because the cause of the leakage is not corrected.

B. Correct C. Incorrect Plausible because the removal of annunciator cards is troubleshooting, however the repair of the components on the circuit board is considered maintainance and must be performed under the work order process.

D. Incorrect Plausible because extended M&TE connections are troubleshooting activities, however the use of test point/jack connections is not considered troubleshooting.

Thursday, September 05, 2013 7:40:03 PM 194 Rev. FINAL

2013 HNP NRC SRO 2.2 Equipment Control G2.2.20 Knowledge of the process for managing troubleshooting activities.

(CFR: 41.10 I 43.5 / 45.13)

Importance Rating: 2.6 3.8 Technical

Reference:

AP-929, Page 15, P&L #7, Rev. 17 References to be provided: None Learning Objective: LP-2.0/3.0, Conduct of Operations, Objective 2.f, rev. 13 Question Origin: Bank Comments: None Tier/Group: T3 Thursday, September 05, 2013 7:40:03 PM 195 Rev. FINAL

2.2. Implementing

1. ADM-NGGC-01C4: Work Implementation and Completion

2. ADM44GGC-01 17 Minor Maintenance

3. OPS-NGGC-1303: Independent Venfication

4. CAP-NGGCD2O5; Condition Evaluation and Corrective Action Process

5. MNT-NGGC-1000; Conduct of Maintenance

6. OMM-OD 1: Operations Conduct of Operations

7. OPS-NGGC-1308, Plant Status Control 3.0 DEFIIIflONSIABBREVIATIONS I. One WorkShrft The duration of time during which a task is being continuously *ortce-d by an ndniduaI or crew which includes normal breaks for meals. One work shift terminates at the end of the Operations work shift

2. Troubleshoot rig:

An activity not governed by a specific approved procedure. used o diagnose plant or equipment sympomns for the purpose of identiing or quafr a degraded parameter or corrponent or obtaining infomaticn required to verify the operability of a component per OPS-NGGC- 305. 3ue to the nature of the synçtoms, or in order to rnnirnze mpac on plant availabilry, troubleshooting may require the affected system or equipment io be in an energized or pressurized stale during all or part of the Iroubleshooting activity.

The fdlowing are exampes of what ARE troubleshooting activities:

• Lifting or repositioning leads to oonirm or identify a auliy component

• Pulling an annunoator card

• Repositioning valves or breakers to verify or confirrr a malfunctioning corrçonent that cannot cthenMse be checked while blocked out or removed from sennoe

• I nstallatiori of instrument or air tubing for functional testing of equipment

• EiIended M&TE oorinections see Section 5.3.2 The folLowing are examp4es of what ARE NOT troubleshooting activities:

• Instalng gags on valves to reduce leakage

• Replacing failed components on cirajit boards; these are repars and are performed under a WIO

• Temporary M&TE hands on leads connections isee Section 5.3.2)

AP-g29 Rev. 17 Page8of36

3.0 DEF1PITIONSIABBREVIATIONS (ocntinued)

14. Troubleshooting Database:

The location on the Y: drive where active and completed troubleshooting plans are stored for reference by site personnel. Defined as Y:iaredMaintenanoeTroubeshooting Control Forms.

• Save the file using 3 description of troubleshooting performed (such as system.

corr,onent, etc. :.

5 E:tended Troubleshooting:

Installation of test equipment in order to mcnitor or trend performance of a sysiem or component for a pencd of me usually nct to e::oeed 30 days. The foIIng applies:

• A TCF and WO tracks the ac1ties

• Tesi equipment is installed foe greater than shift

• The test equipment is not ccntini..iouslv attended

• The actii4ty has been prevousiy evaluated (see Attachment 4) or the activity is non-intrusive referto ADM-NGGC..0106 section for Intrusive Changer 4.0 RESPONSIBIIJTIES Troubleshooting Lead (TL):

NOTE: The TL can be a representative of Maintenanoe. Operations or Engineenrig L (reference Section 3.0)

a. Initiates the TCF, Attachment 1.

b. Ensures technical and procedural aspects of the troubleshooting to be performed are correct This includes, but is not lirrited to:

• Assuring that information related to equipment problem symptoms is obtained and recorded

• Appropriate procedures are used as troubleshooting is pursued in the field

• Equpment responselbehavior during troubleshooting activities is recorded

• Troubleshooting status is convnunicated to site management to ensure additional support and resource needs are available.

AP-Q2Q Rev. 17 Page 11 of 36

5.32. Extended Troubleshooting, M&TE, Jumpers. Lifted Leads, Test Gauges

• The fc4iQwing are not oorisidered Extended Trcbeshcoting:

• Temporary M&TE ands on Leads oorinections

• Ternpcary M&TE 7est pc4ntjaclC conneeboris, provided the test eqLipren: is ccntnuously monitored and the test eqiJipn.em is nc instailed more than one

2. Refer to the ohar behow to determine if the actwity is oonsidered Extended Trou bleshooling:

a. Refer to At!thment 4 for a ltst c previously evaluated troubleshooting aCtT%llteS.

3. If the acMty is determined to be Extended Troubleshooting:

a. Indicate on TCF that Extended Troubleshooting is being performed, include any affected draWngs, and an es atedoompletion date on the TCF.

b. After installation, place the TCF (oroopy behind the Extended Troubleshooting Reoord Tab of the Operations TroubleshootingiAclion Plan Book.

c. Ensure adivthes are doomented and verifications cxxnpleted per OPS-NGGC-1303 or OPS-NGGC-1308.

d. After oonleqion of Extended Troubleshooting, notify Operations of oompetion. docunent renoval on the TCF. and remove the TCF from the Operations Troube hootingIActon Plan Book.

e. Ensure aivities are dooumented and verifications oompleted per OPS-NGGC-1303 or OPS-NGGC-1308 AP-2 Rev. 17 Page 18 of 36

2013 HNP Licensed Operator Written Exam question #85 Post Exam Comment On September 26, 2013 the HNP Written Exam was reviewed with all participating candidates.

During the review four questions were identified as inconsistent with the answer key. RO questions 26, 52, 69 and SRO question 85. Based on the review of Harris Plant approved procedures the Harris Training Department and the Harris Operations Department supports post written exam changes.

HNP contends that question #85 has only one correct answer. The correct answer is choice D and not the keyed answer C. Question #85 had an unclear stem that confused the applicants and did not provide all the necessary information which caused a candidate to submit a question requesting clarification during the administration of the written examination.

The keyed answer was answer C. Without making any assumptions about the work in Containment, work on non-technical specification I non-vital equipment would not be allowed, making answer choice D correct. Amplifying information was provided during the exam administration and provided to all candidates with the NRC Lead Examiner concurrence, based on a question from a candidate during the exam.

The Candidates question was Is the second part asking if we can enter for the çiç purpose of non-tech spec, non-vital repairs, or if we can do that work if entered for other repairs?

The response provided to all candidates was to change the second part of the question to add the word ONLY twice in the statement. The second part of the question was revised to read:

. . . use of the airlock to perform ONLY non-Technical Specification required activities or repairs ONLY on non-vital plant equipment...

The basis for Technical Specification 3.6.1.3 states the provision to enter Containment with an inoperable door on each airlock is based performing work on Technical Specification related or vital equipment.

The amplifying information provided supports answer C being incorrect and answer D being correct.

The recommen dation from Harris Nuclear Plant is to accept answer Dfor this question based upon NUREG 1021 ES-403 D. 1.b page 3 guidance. TI,is question was written with an unclear stem that did not provide all the necessary information to distinguish a correct answer.

Attached:

HNP 2013 Written Exam Question #85

Reference:

Basis for Technical Specification 3.6.1.3

2013 HNP NRC SRO

85. 2013 NRC SRO 010 Given the following plant conditions:

- The plant is operating in Mode 3

- At 0900 on Sept 1 st, the Personnel Air Lock (PAL), Inner door seal fails

- At 0800 on Sept 3 rd, the Emergency Air Lock (EAL), Outer door seal fails Which ONE of the following completes the statements below in accordance with Technical Specification 3.6.1.3, Containment Air Locks, and its Bases?

The latest day/time that either of the air locks can be use for entry/exit under administrative controls is (1)

In accordance with the Technical Specification 3.6.1.3, Bases, during this period of time, the use of the air lock to perform non-Technical Specification required activites or repairs on non-vital plant equipment is (2) in Containment.

(Reference provided)

A. (1) 0900 on September 8 th (2) allowed B. (1) 0900 on September 8 th (2) not allowed C (1) 0800 on September 10 th (2) allowed D. (1) 0800 on September 10 th (2) not allowed Thursday, September 05, 2013 7:40:04 PM 239 Rev. FINAL

2013 HNP NRC SRO Plausibility and Answer Analysis Reason the answer is correct: PerT.S. 3.6.1.3, action a is applicable because one door in each air lock is inoperable and the airlock is entered separately for each airlock.

The EAL may be entered under administrative controls for 7 days if BOTH air locks are inoperable per the note (3.6.1 .3.a.#.2). The basis section of 3.6.1.3 states that the note is not intended to preclude performing other activities (i.e. non-TS required activies or repairs on non-vital plant equipment.)

A. Incorrect. The first part is plausible if the candidate believes that entry and exit is permissible for 7 days based on the inoperability of the PAL inner door.

The second part is correct.

B. Incorrect. The first part is plausible if the candidate believes that entry and exit is permissible for 7 days based on the inoporability of the PAL inner door.

The second part is plausible if the candidate believes that entry and exit is only permissible to perform repairs on the affected air lock.

C. Correct.

D. Incorrect. The first part is correct. The second part is plausible if the candidate believes that entry and exit is only permissible to perform repairs on the affected air lock.

Thursday, September 05, 2013 7:40:04 PM 240 Rev. FINAL

2013 HNP NRC SRO APE: 069 Loss of Containment Integrity 069 AG2.2.25 Knowledge of the bases in Technical Specifications for limiting conditions for operations and safety limits.

(CFR: 41.5 /41.7 / 43.2)

Importance Rating: 3.2 4.2 Technical

Reference:

Technical Specification 3.6.1 References to be provided: Technical Specification 3.6.1.3 Learning Objective: CONT Student Text Obj 13.f Question Origin: New Comments: None Tier/Group: TI G2 SRO Justification: 10 CFR Part 55 Content 43.2 because application of Technical Specification below the line application of required actions considered to be SRO knowledge level Technical Specification items and the basis for the actions.

Thursday, September 05, 2013 7:40:04 PM 241 Rev. FINAL

3/4 6 CONTAINMENT SYSTEMS BASES 3/4,6,1 PRIMARY CONTAINMENT 3/4.6.1.: CONTAINMENT INTEGRiTY Primary CONTAINMENT 1NT[tRITY ensures t.hit the release of radioactive inatcrials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. this restriction, in conjunction with the leakage rate limitation, will limit the ShE BOUNDARY radiation doses to within the dose gudeline values of 10 CFR Part 100 during accident conditions.

3/4.6.1 2 CONTA1NMENLjjF The 1 imitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the safety analyses at the peak eiccIdent pressure. As an added conservatism, the measured overall integrated leakage rate is further limited to less than or equal to 0 75 L.

during performance of the periodic test, to account for possible degradation of the containment leakage barriers between leakage tests.

The surveillance testing for measuring leakage rates is consistent with tne requirements of Appendix 3 of 10 CER Part 50. Option A for Type 13 and C tests, and the Containment I eakaqe Rat.e Testing Prnqrarn for Type A tests 3/4,6.1.3 CONTAINMENT AIR LOCKS rhe limitations on closure and leak rate for the containment air locks are required to meet the restrictions on CONTAINMENT INTEGRITY and containment leak rate. Surveillance testing of the air lock seals provides assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between air lock leakage tests.

Action statement a has been modified by a note The note allows use of the air lock for entry and exit for seven days under administrative controls if both air locks have an inoperable door. This seven day restriction begins when a door in the second air lock is discovered to be inoperable.

Containment entry may be required to perform Technical Specification surveillances and actions, as well as other activities on equipment inside containment that are required by Technical Specifications (TS) or other activities that support TS required equipment. In addition, containment entry may be required to perform repairs on vital plant equipment, which if not repaired, could lead to a plant transient or a reactor trip. Ihis note is not intended to preclude performing other activities i.e., non-TS required activities or repairs on non-vital Itant equipment) if the containment is entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize containment during the short tirr that an OPERABLE door is expected to be open SHARON HARRIS - UNIT I B 314 6-1 Amendment No. 91