ML15173A440

VC Summer 2015-301 Initial Exam Post Exam Comments

ML15173A440
Person / Time
Site:	Summer
Issue date:	06/26/2015
From:	Gerald Mccoy Division of Reactor Safety II
To:	Constance N South Carolina Electric & Gas Co
References
50-395/15-301, CR-14-01708, RC-15-0076
Download: ML15173A440 (16)

Text

FOR OFFICIAL USE ONLY Neil E. Constance Manager; Nuclear Training 803.345.4028 E SCE&6 A SCANA COMPANY May 26,2015 Mr. Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety U. S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Ave. N.E., Suite 1200 Atlanta, GA 30303-1257

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 INITIAL OPERATOR LICENSE EXAMINATION POST EXAMINATION SUBMITTAL The V. C. Summer Initial Operator License Examination was administered in the weeks of May 4, 2015 and May 18, 2015. The VCSNS Initial License Written Examination was administered on May 20, 2015. VCSNS is enclosing the following as required by Revision 10, of NUREG 1021, Operator Licensing Examination Standards for Power Reactors:

1. Each applicants original answer and examination cover sheets plus two clean copies of each applicants answer sheet;

2. The master examinations and answer keys;

3. Questions asked by and answers given to the applicants during the written examination;

4. Written examination seating chart;

5. Post-examination comments and facility responses; and

6. Written examination performance analysis.

As agreed, the examination security agreement will be sent via email at a later date.

If you require any additional information or have any questions, please contact Robert Johnston at (803)931-5173.

Very truly yours QccA Neil E. Constance TS/N EC/dr Enclosures c: (Without Enclosure unless noted)

V. M. McCree RTS (CR-14-01708)

M. K. Meeks (NRC e-mail notification) File (814.04, RR 1050)

NRC Resident Inspector PRSF (RC-15-0076)

V. C. Summer Nudear Station . P.O. Box 88. Jenkinsville, SC .29065. F (803) 941-9776

Mr. Gerald J. McCoy USNRC, Region II CR-14-O1 708 RC-1 5-0076 ENCLOSURE 5 Post-examination comments and facility responses

Question 96 requires the candidate to recall information contained in SAP-205, STATUS CONTROL AND REMOVAL AND RESTORATION. Section 6.10.5 in SAP-205 states that an evaluation is not required for Outage R&Rs that have been in effect for 30 days. Since the component that is being tagged, as posed in question 96, has an LCO that is only applicable in Modes 1 through 4, this is an Outage R&R. The approved answer D is based on this information.

A conflicting statement, however, was presented by candidates during the examination review.

The following statement also exists in SAP-205:

5.3 Operations Administrative Clerical Support shall complete Attachment IXfor any R&R which has been in effect for greater than 30 days and forward to the Operations Supervisor for review.

Thus, since the wording of section 5.3 specifies a review using Attachment IX for jy R&R, answer C could be construed as the correct answer.

V.C. Summer requests that Question 96 be removed from the exam.

SAP-205 REVISION 10 5.0 RESPONSIBILITIES 5.1 The Manager, Operations is responsible for implementing this procedure and ensuring compliance by conducting informal monitoring.

5.2 The Operations Supervisor or his designee is responsible for ensuring System Status Controls are maintained by conducting monthly audits per Attachment IV.

Operations Administrative Clerical Support shall complete Attachment IX for any R&R which has been in effect for greater than 30 days and forward to thea Operations Supervisor for review.

5.4 The Shift Supervisor is responsible for:

5.4.1 Declaring systems or components inoperable.

5.4.2 Approving requests to remove systems or components from service or placing in a restricted service status.

5.4.3 Ensuring the System Status Controls are maintained through frequent checks of the BISI Status and Removal and Restoration Log.

5.4.4 Ensuring the required checks of Attachment I are completed prior to approving the removal of equipment from service.

5.4.5 Verifying the required Technical Specification actions are taken when a system or component is declared inoperable.

5.4.6 Initiating and maintaining Attachment I.

5.4.7 Maintaining the Index (Attachment II) and reviewing it as part of shift relief.

5.4.8 Ensuring all required testing is satisfactorily completed prior to declaring the equipment operable and restoring it to service.

5.5 The Control Room Supervisor is responsible for:

5.5.1 Maintaining BISI in agreement with existing system or component operability.

PAGE 7 OF 14

SAP-205 REVISION 10 6.9 System Status Controls Audit Sheet, Attachment IV:

6.9.1 The night shift Control Room Supervisor shall perform a daily audit.

This audit shall verify:

A. R&R Log Book, BISI, and Main Control Board Orange Tags are in agreement as to safety system status.

B. R&R Checksheets accurately reflect current system or component conditions as to R&R type and status.

C. Inoperable Containment Penetrations on the first day of the month, verify each inoperable containment penetration is isolated per appropriate GTP 702 Attachment VI GG for that penetration.

6.9.2 Completed daily audits shall be forwarded to the Operations Supervisor for review and disposition.

6.9.3 The Operations Supervisor shall:

A. Perform periodic audits of the R&R Log to ensure it accurately reflects current system or component conditions and that the operating staff is aware of current conditions.

B. Perform a monthly audit of the Status Control and Removal and Restoration program to ensure it is being complied with and that the records are being properly maintained in accordance with this procedure and the Records Accumulation and Retention Chart.

6.10 Evaluation of non-outage R&Rs in effect for an extended period:

6.10.1 When a non-outage R&R has been in effect for greater than 30 days, it shall be evaluated per Attachment IX.

6.10.2 The evaluation should document the reason why the equipment has not been restored to operable status and what the final disposition is to be.

6.10.3 A reevaluation shall be completed per Attachment IX for each subsequent 30 days that the R&R remains in effect.

6.10.4 The most current evaluation, or a copy, should be attached to the Removal and Restoration Checksheet until the equipment is restored to operable status.

6.10.5 This evaluation is not required for Outage R&Rs.

PAGE 13 OF 14

Q98 Question 98 requires the candidate to recall that the release using Reactor Building Purge must begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of sampling.

HPP-0709, SAMPLING AND RELEASE OF RADIOACTIVE GASEOUS EFFLUENTS, section 5.1.2.B is as follows:

B. A full set of grab samples (Gas, Particulate, Iodine, and Tritium) are required to initiate a Main Plant Vent or Reactor Building Purge (Attachment VI) permit.

Thus, the release permit is initiated after samples are taken. Further actions are as follows:

• Results are analyzed and Radiation Monitor setpoints are calculated in follow on steps.

• Data is recorded and then pre-release approval by the HP organization is entered on the release permit per section 5.1.2.K.

• The permit is forwarded to the control room in step 5.1.2.L.3.

• When the shift is ready to begin the actual release, the permit will be approved in section II. Of the release permit entitled ACTUAL RELEASE DATA (Operations).

Candidates expressed that since the sequence prior to beginning of the release requires sampling first, with approval for release by the Shift Supervisor after, then D can be construed as an additional correct answer.

Additionally, Section 5.1.2.L.8 states the following:

8. COMMENCE releases from the Reactor Building within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of sample.

In accordance with the conditions posed in question 98, the following items are true:

• Operations approval of the Release Permit occurred after samples were taken.

• 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 30 minutes have passed since the Operations Approval of the permit.

• The release had not been previously begun and interrupted.

It can be logically assumed that if more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since approval of the permit, then more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since sampling occurred; therefore, a release is prohibited.

V.C. Summer requests that answer D also be accepted as a correct answer.

HPP-0709 REVISION 12

2. FORWARD the approved GWRP to the Control Room, where Operations will make the release.

H. Permit Termination:

1. ENSURE the Main Plant Vent and/or Reactor Building Purge hourly flow rate files are updated beyond the end of the release period prior to updating the permit with the actual release data.

2. UPDATE the computer files with the actual release data after completing the release; or if the current authorization expires, the permit may be left open and edited with new sample results.

3. REVIEW the updated information and resulting calculations.

Review the cumulative dose totals for compliance with the Gaseous Effluent Dose Limits table in Enclosure A. If limits were exceeded, promptly notify the Shift Supervisor and the Manager, Health Physics and Safety Services 5.1 .2 Reactor Building Purge, Main Plant Vent, and RM-A Cabinets COl + A. Normal continuous release paths are the Main Plant Vent and the 6-inch and 36-inch Reactor Building Purge. Attachment VI is used to initiate and track continuous 6-inch or 36-inch purge releases.

B. A full set of grab samples (Gas, Particulate, Iodine, and Tritium) are required to initiate a Main Plant Vent or Reactor Building Purge (Attachment VI) permit.

C. Pre-release samples for the Reactor Building Purge shall be obtained from RM-A2 or directly from containment. Samples taken during the release, and post release samples, are obtained from RM-A4. In the event samples cannot be obtained from RM-A4, Reactor Building samples may be substituted. Samples for the Main Plant Vent are taken from RM-A3.

D. Charcoal and filter replacements are performed by the following method:

1. NOTIFY the Control Room prior to changing filters.

Page 9 of 21

HPP-0709 REVISION 12 H. PERFORM manual calculations in accordance with Reference 3.2 if the Effluent Management permit processing software is inoperable.

NOTE: 5.1.2. I The calculated Radiation Monitor Setpoint generated by the Effluent Management permit processing software must be verified to be greater than the setpoints identified below. If not, immediately notify the HP Supervisor, Count Room! Designee.

ESTABLISH Main Plant Vent and RB Purge Monitor Gas Channel High Radiation Setpoints.

1. RMA-3 Gas Channel High Radiation Setpoint is established at 300 cpm using the Alternative Methodology for Establishing Conservative Setpoints in the ODCM.

2. RM-A4 Gas Channel High Radiation setpoint is established at 3000 cpm using the Alternative Methodology for Establishing Conservative Setpoints in the ODCM.

3. The Manager, Health Physics and Safety Services, or designee must authorize any release using setpoints greater than those identified above and calculated using the methodology establish in the ODCM.

4. During shutdown conditions when the 36-inch purge is in operations, the high range gas setpoint on RM-A2 shall be set to the same value as specified by the high range gas setpoint on RM-A4. It shall not be raised for discharges in modes 1-4, when the 6 inch purge will be used.

J. REVIEW the release data and permit information for compliance with release requirements and NOTIFY the Shift Supervisor of the problem areas and possible course of action if the release cannot be made as planned.

K. SIGN and date the approval portion and store the pre-release data on the computer files (as applicable) if the release is acceptable as proposed.

L. For an approved release:

1. STORE the particulate sample for compositing.

Page 13 of 21

H PP-0709 REVISION 12

2. COPY the GWRP and attach the corresponding computer analysis printout or manual calculation sheet(s). Place in the active GWRP file.

3 FORWARD the approved GWRP to the Control Room, where Operations will make the release. (The Main Plant Vent does snot have a GWRP that goes to the Control Room.),

4. CHANGE out RM-A4 particulate filter and charcoal/silver zeolite cartridge or ensure that RM-A4 filters/cartridge are clean prior to initiating a 6-inch or 36-inch purge. Operations should ensure that a satisfactory RM-A4 source check is performed.

5. The Reactor Building purge ventilation discharge is equipped with two sets of isokinetic sampling nozzles, one set for the 6-inch purge, and one set for the 36-inch purge. Prior to the release, Operations will ensure that the appropriate nozzles are lined up for proper sampling of the effluent stream per SOP-i 14, Reactor Building Ventilation System.

C01 6. Releases from the Reactor Building purge, 6-inch or 36-inch, are tracked as continuous releases. The purge must be stopped while changing RM-A4 particulate and iodine filters.

7. Reactor Building Purge Flow Rates

a. DETERMINE the maximum allowable release flow rate and compare to the following:

1) 6 inch purge: 0-1,500 cfm (variable).

2) 36 inch purge: 15,000 cfm (1 fan); 30,000 cfm (2 fans).

3) These are the only flow rates available; therefore, the maximum allowable rate must be rounded down to nearest available rate (e.g. 16,000 cfm allowable must be reduced to 15,000 cfm permissible).

b. RM-A4 sample flow rate is set in accordance with Reference 3.16.

Page 14 of 21

HPP-0709 REVISION 12 COMMENCE releases from the Reactor Building within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of sample.

a. New Reactor Building samples are required within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period if:

1) RM-A2 shows a significant increase on the gas channel; or

2) A plant trip or thermal power change exceeding 15% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> occurs; or

3) Grab samples collected during a shutdown show a significant increase in activity.

b. If above criteria impacts the permit in effect, then a new release permit shall be generated.

M. Permit Termination:

1. ENSURE the Main Plant Vent and/or Reactor Building Purge hourly flow rate files are updated beyond the end of the release period prior to updating the permit with the actual release data.

2. UPDATE the computer files with the actual release data after completing the release; or if the current authorization expires, the permit may be left open and edited with new sample results.

3. REVIEW the updated information and resulting calculations.

Review the cumulative dose totals for compliance with the Gaseous Effluent Dose Limits table in Enclosure A. If limits were exceeded, promptly notify the Shift Supervisor and the Manager, Health Physics and Safety Services.

5.1.3 Sampling the WGDTs for Daily Curie Content.

A. COLLECT the daily sample as in Step 5.1 .1 .C utilizing the daily reusable 25ml Marinelli beaker.

B. Daily samples may also be collected using syringe / septum sampling:

1. Have Operations lineup the tank for sampling.

Page 15 of 21

HPP-0709 GWRP No. ATTACHMENT VI PAGE 1 OF 1 REVISION 12 REACTOR BUILDING PURGE RELEASE PERMIT D 6-INCH (any mode) L136-INCH (modes 5, 6 or defueled)

I. RELEASE AUTHORIZATION (Count Room)

Estimated release Duration, From: To:

(date/time)

Maximum release rate (cfm)

RM-A2 gas channel, (cpm) BKG. *Alarm Setpoint RM-A4 gas channel, (cpm) BKG. Alarm Setpoint Do not adjust when in modes 1-4. RMA-2 is part of the Leak Detection System.

Comments:

Count Room:_______________________________________ Date/Time:___________________

II. ACTUAL RELEASE DATA (Operations)

Release Approved, SSICRS:___________________________ Date/Time:___________________

Release START, Date/Time:_________________________

RM-A2 (cpm) RM-A4 (cpm) INITIALS Alarm Set Point (cpm)

Source Check Sat/Unsat Reading @ Release Start (cpm)

Reading @ End of Release (cpm)

Alarm Set Point returned to 2 x ni Daily Verification of High Radiation Alarm Setpoint:

Date/Time RM-A2 gas channel (cpm)

RM-A4 gas channel (cpm)

• Release Rate, (cfm)

Comment:

Release TERMINATED, Date/Time:

Reason: LiRelease Completed UAuthorization Expired LJM-A4 High Radiation Alarm, (cpm):

U Release Continued on New Permit EPther Operations Review: Date/Time:

Updated by:. Date/Time:

Count Room

FOR OFFICIAL USE ONLY Neil E. Constance Manager; Nuclear Training 803.345.4028 June4, 2015 A SCANA COMPANY Mr. Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety U. S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Ave. N.E., Suite 1200 Atlanta, GA 30303-1257

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 INITIAL OPERATOR LICENSE EXAMINATION POST EXAMINATION SUBMITTAL ADDENDUMS

Reference:

SCE&G Letter from Neil E. Constance to Gerald J. McCoy (NRC), Initial Operator License Examination Post Examination Submittal, dated May 26, 2015 The enclosures that accompany this letter are addendums to the post examination package (Reference) that was submitted to the NRC on May 26, 2015. This submittals enclosures are as follows:

1. One additional post examination comment for the Operating Test that was given during the week of May 4, 2015.

2. Signed forms ES-201-3, Examination Security Agreement.

If you require any additional information or have any questions, please contact Robert Johnston at (803)931-5173.

Very truly yours, Neil E. Constance TS/N EC/sr Enclosures (2) c: (Without Enclosure unless noted)

V. M. McCree M. K. Meeks (NRC e-mail notification)

NRC Resident Inspector RTS (CR-14-01708)

File (814.04, RR 1050)

PRSF (RC-15-0094)

V. C. Summer Nuclear Station. P.O. Box 88. ienkinsville, Sc. 29065. F (803) 941-9776

Mr. Gerald J. McCoy USNRC, Region II CR-14-O1 708 RC-1 5-0094 ENCLOSURE I Additional post examination comment for Operating Test

NRC JPM Sim g NJPS-084 1PM 2015 NRC Sim g, NJPS-084 required candidates to respond to a decreasing level in the spent fuel pool in accordance with AOP-123.1.

This JPM was discussed during the exam week between V.C. Summer staff and the NRC examiners; specifically, step 6 was discussed with regard to whether it was appropriate to have this step indicated as a critical step. Step 6 of the JPM evaluates the performance of step 10.f of AOP-123.1, DECREASING LEVEL IN THE SPENT FUEL POOL OR REFUELING CAVITY DURING REFUELING.

The simulator was set up for this JPM with FCV-605A in a position that did not require adjustment to allow flow from the RHR train to the RCS, therefore no adjustment was necessary to complete the JPM.

V.C. Summer requests that the evaluator note for NRC JPM Sim g, NJPS-084, step 6 be revised as follows:

Evaluator note: FCV-605A must remain open in order to assure a discharge flow path from the RHR pump to the refueling cavity/spent fuel pool. Adjustment of FCV-605A is not required; however, it is critical that FCV-605A be left in a position that provides flow that is sufficient to raise spent fuel level. This is evaluated in step 10 of this 1PM.

CRITICAL: No SEQUENCED: Yes SAT UNSA T TEP: 5 Step 10 e: Close HCV-603A(B), A(B) OUTLET.

STEP STANDARD:

Closes HCV-603A, A OUTLET, by turning potentiometer to zero (0).

CUES:

COMMENTS:

CRITICAL: Yes SEQUENCED: Yes SAT UNSA T L,iEP: 6 Step 10 f: Adjust FCV-605A(B), A(B) BYP, as necessary to establish the desired refueling water level.

STEP STANDARD:

Takes manual control of FCV-605A and controls flow to raise SEP level.

UES: -

Evaluator note: This step is critical because FCV-605A must remain open in order to assure a discharge flow path from the RHR pump to the refueling cavity/spent fuel pool.

Evaluator note: FCV-605A must remain open in order to assure a discharge flow path from the RHR pump to the refueling cavity/spent fuel pooL. Adjustment of FCV-605A is not required; however, it is critical that FCV-605A be left in a position that provides flow that is sufficient to raise spent fuel level This is evaluated in step 10 of this JPM.

COMMENTS:

Monday, January 26. 2015 Page 6 of 10

AOP1?3. 1 REVISION 4 DECREASING LEVEL IN THE SPENT FUEL POOL OR REFUELING CAVITY DURING REFUELING ACTION/EXPECTED RESPONSE ALTERNATIVE ACTION 10 Align the operating RHR train for 10 Align the standby RHR train for makeup from the RWST: makeup from the RWST:

a. Check if the operating RHR a) Stop the operating RHR Pump.

train is intact.

b) Open MVG88O9A(B), RWST TO RHR LI

b. Open MVG8809A(B), PP A(B), on the standby train.

RWST TO RHR PP A(B).

c) Close all of the following:

c. Close MVG87O1A(B),

RCS LP A(C) TO PUMP A(B).

• MVG8701A(B),

RCS [P A(C) TO PUMP A(B).

d. Close MVG87O2A(B),

RCS LP A(C) TO PUMP A(B).

• MVG8702A(B).

RCS LP A(C) TO PUMP A(B).

e. Close HCV603A(B), A(B) OUTLET. El HCV603A(B), A(B) OUTLET.

f. Adjust FCV6O5A(B). A(B) BYP.

as necessary to establish the d) Start the standby RHR Pump, desired refueling water level. XPPOO31A(B), PUMP A(B).

g. Ensure the associated Component LI e) Adjust FCV6O5A(B), A(B) BYP, Cooling train is operating, as necessary to establish the REFER TO SOP118, COMPONENT desired refueling water level.

COOLING WATER.

f) Ensure the associated Component

h. Verify CCW flow through the RHR Cooling train is operating.

Pump A(B) Seal Cooler: REFER TO SOP118, COMPONENT COOLING WATER.

• FM7245, A RHR PP (IUR14400, M3/SW 53). g) Verify CCW flow through the RHR Pump A(B) Seal Cooler:

• FM7255, B RHR PP (IUR144O1, M4/SW 53).

• FM7245, A RHR PP (IUR14400, M3/SW 53).

FM7255, B RHR PP (IUR144O1, M4/SW 53).

IF the RWST is NOT available, THEN LI fill the Refueling Cavity and the Spent Fuel Pool from Recycle Holdup Tank A(B). REFER TO SOP123, SPENT FUEL COOLING SYSTEM.

PAGE 6 OF 9