ML15007A529
| ML15007A529 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/17/2014 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Union Electric Co |
| laura hurley | |
| References | |
| Download: ML15007A529 (7) | |
Text
CW-2014-12 Post-Exam Challenges Question #83:
The plant is at 100% power.
Irradiated Fuel moves are in progress in the Spent Fuel Pool.
An Earthquake is felt at the site and results in the following:
ANN 98E, Seismic Recorder On, is LIT HI HI RAD alarms are received on Fuel Building Process Radiation Monitors, GG-RE-27 and GG-RE-28, gas channels ANN 76D, SFP LEV HILO, is LIT ANN 62B, AREA RAD HI, is LIT Normal makeup to the SFP is initiated and level stabilizes at -20.0.
A report from the Fuel Building indicates that a fuel move was in progress when the earthquake occurred resulting in several pieces of fuel handling equipment and the assembly being moved, falling and damaging other fuel assemblies.
Area Radiation Monitors readings are as follows:
SDRE0033, CTRL RM RAD MONITOR, is 1mr/hr and constant SDRE0037, FUEL POOL BRIDGE CRANE RAD MONITOR, is 35 mr/hr and rising slowly SDRE0038, SPENT FUEL POOL AREA RAD MONITOR, is 32 mr/hr and rising slowly Which of the following describes the HIGHEST Emergency Plan Action Level that applies to this situation and why?
Answer: D) Alert due to Damage to Irradiated Fuel Assemblies Distractors: A) Unusual Event due to the Seismic Event B) Unusual Event due to Spent Fuel Pool Low Level C) Alert due to Area Dose Rates Licensee Analysis Reference for question is EIP-ZZ-00101 ADD1, Emergency Action Level Classification Matrix, REV 3.
The Answer [D] is correct based on EAL classification RA2.1 with Fuel Building Exhaust Radiation Monitors in HI HI alarm with damage to irradiated fuel assemblies.
The Distractor [C], Alert due to Area Dose Rates is also correct based on the following:
EAL RA2.1 states: Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel resulting in raised readings on any of the following radiation monitors:
Hi-Hi Alarm on Fuel Building exhaust monitors (GG-RE-27 or 28).
Manipulator crane radiation monitor (SD-RE-41) >100 mR/hr.
Fuel Building East or West Wall area radiation monitor (SD-RE-37 or 38) >30 mR/hr.
The Basis for RA2.1 states the following:
This EAL addresses specific events that have resulted, or may result, in unexpected rises in radiation dose rates within plant buildings and may be a precursor to a radioactivity release to the environment. These events represent a loss of control over radioactive material and degradation in the level of safety of the plant.
This distractor does not provide enough distinguishing information to determine which specific EAL classification it is referring to, EAL RA2.1 or RA3.1 (which is NOT met). Due to the Area Radiation Monitors in the Fuel Building (SD-RE-37 and 38) indicating >30 mR/hr (35 mR/hr and 32 mR/hr respectively) the condition of RA2.1 to declare an ALERT based on ANY of the following radiation monitors, then Alert due to Area Dose Rates is also correct.
NRC Response to Question 83 The initiating condition for entering RA2.1 is Damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel outside the Reactor Vessel. While Fuel Building area radiation monitors (ARM) reading > 30 mR/hr is a symptom of damaged fuel, elevated area dose rates are not in themselves the reason to enter an Alert. Lacking damaged irradiated fuel, unexpected elevated area dose rates would more appropriately be evaluated under Unusual Events RU2.2 (Unplanned valid area radiation monitor reading rises by a factor of 1000 over normal levels) or RU2.1 (Valid low water level or alarm with all irradiated fuel assemblies remaining covered by water AND Unplanned valid area radiation monitor reading rises in Containment Building or Fuel Building), as applicable.
The RA2.1 technical basis states that The bases for the SFP ventilation radiation Hi-Hi alarm and the SFP and containment area radiation readings are a spent fuel handling accident (EIP-ZZ-00101 Add. 2, Rev. 008, page 45 of 233). This shows that the reason for entering an Alert is not the area dose rate itself, but the damaged fuel which causes an elevated area dose rate.
This section further states, Interpretation of these EAL thresholds requires some understanding of the actual radiological conditions present in the vicinity of the monitors. In this case, the actual radiological conditions include a report of irradiated fuel damage, the factor which drives the Alert.
The Region therefore maintains that the only correct answer to the question, Which of the following describes the HIGHEST Emergency Plan Action Level that applies to this situation and why? is D. Alert due to Damage to Irradiated Fuel Assemblies. That being said, the Region acknowledges that the question is psychometrically flawed in that the difference between the
correct answer D and the incorrect distractor C could be considered minutia; choosing either answer based on the aforementioned reasons would result in a declaration of the same EAL.
Additionally, the intent of distractor C was to test the applicants knowledge of EAL RA3.1 related to Control Room area radiation levels, however the wording of the distractor was ambiguous enough to assume it could refer to either RA3.1 or RA2.1. Because of these psychometric flaws, the Region has determined that Question 83 should be deleted from the SRO exam.
Question #97:
Who has the authority to APPROVE or REJECT a proposed design change to safety related systems, structures or components (SSCs)?
Answer: C) Director, Nuclear Operations Distractors: A) Vice President, Nuclear B) Senior Plant Director [aka Senior Director, Nuclear Operations (clarified during exam administration)]
D) Shift Manager Licensee Analysis Reference for question is APA-ZZ-00600, Design Change Control, Revision 53 Answer [C] is referring to section 4.0 of APA-ZZ-00600 which states:
4.1. Requesting an Engineering Change Director, Nuclear Operations AND Director, Engineering Design or Director, Engineering Projects: APPROVE or REJECT the proposed design change to safety related SSCs.
[B] Senior Director, Nuclear Operations is also an acceptable answer based on the following:
In APA-ZZ-00600 the following information is found under Duties and Responsibilities:
3.0 RESPONSIBILITIES 3.1. Senior Director, Nuclear Operations Approves Engineering Changes prior to implementation as required by T/S 5.1.1 and OQAM 3.18.
T/S 5.1.1 states the following 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager [synonymous with Senior Director, Nuclear Operations] shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety and are not addressed in the Final Safety Analysis Report (FSAR) or Technical Specifications.
The [Operating Quality Assurance Manual] OQAM states the following:
3.18 Independent of the responsibilities of the design organization, the requirements of the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB) as defined in OQAM Section 1.0 shall be satisfied.
Safety Related Design changes shall be reviewed by the ORC and approved by the Senior Director, Nuclear Operations. In addition, design/configuration changes, that require a change in the Callaway Plant Technical Specifications or a License Amendment per 10CFR50.59 require review by the NSRB. (NRC approval of the License Amendment is required prior to implementation of the design/configuration change.)
When design is performed by an outside organization, Ameren Missouri shall perform or coordinate a review of the design for operability, maintainability, inspectability, FSAR commitment compatibility, test and inspection acceptance criteria acceptability, and design requirements imposed by Plant generating equipment.
The Stem of the question does not provide enough information to determine what stage of the process the design change is in. The Senior Director, Nuclear Operations has the authority to approve or reject the design change up to the point of implementation. Although the stem matches step 4.1.7 of APA-ZZ-00600 there is no frame of reference provided and if the student applies knowledge from Technical specification 5.1.1, then Senior Director, Nuclear Operations is also correct.
NRC Response to Question 97 The Region agrees with the licensees analysis. A review of the above-referenced procedures clarifies that implementation of a safety-related design change must have the approval of both the Director, Nuclear Operations [C] and the Senior Director, Nuclear Operations [B], who is the final approval authority.
SRO Question 97 shall be modified to accept both answers B and C.