ML16007A212
| ML16007A212 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/07/2016 |
| From: | NRC/RGN-II |
| To: | Progress Energy Carolinas |
| References | |
| Download: ML16007A212 (15) | |
Text
ROISRO Question #2 Brunswick Nuclear Plant December 2015 (ILT 2015) Initial License Examination During a startup on Unit Two, control rod 30-39 is desired to be moved continuously from 12 to 48.
Which one of the following completes both statements below?
The minimum number of RMCS control switches needed to accomplish this control rod movement is (1)
During this control rod movement the largest power change will be seen on SRM (2)
A.
(1) one (2)
B B.
(1) one (2) C C.
(1) two (2)
B D.
(1) two (2) C In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b, the wrong answer being selected on the answer key, the facility recommends that the correct answer be changed from 0 to C,.
F+/-+[t1++/-+It+t+
Li,+/-+,+I++/-+/-+/-+/-t+/-
I+I+++I+++++++++
41 ll[+++z
+++++++++++++/-
++++++++++++
++/-+/-+/-t+++/-+/-Y+++/-+/-
C 1+ +/-+ +/-+
1 33 35
25 27 25 23 21
I I
35 27
3 61 Et r1r++m+111J4 fl n
Part 2 of the question identifies the wrong SRM Channel.
It is the B SRM detector, instead of C.
The validation of the question did not identify this error.
FIGURE 09.1-2 IN-Core Instrumentation Location Diagram IRM DETECTOR LOCATION SRM DETECTOR LOCATION CORE SRM LOCATION A
12-33 8
2841 C
36-26 D
20-77 CORE RU LOCATION A
1241 8
3541 C
20-33 O
28-33 CORE IRM LOCATION E
28-25 F
20-25 C
36-09 H
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ROISRO Question #75 In preparation for a valve manipulation in the drywell, the applicable RWP indicates that the highest dose rate in the area is 350 mR/hr. A flashing red light is encountered at the entry location to the valve in the drywell.
Which one of the following completes both statements below?
The flashing red light indicates the area is a (1)
This RWP (2) be used to perform the valve manipulation.
A.
(1) high radiation area (2) can B.
(1) high radiation area (2) can NOT C.
(1) locked high radiation area (2) can D.
(1) locked high radiation area (2) can NOT In accordance with NUREG-1021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from 0 to C.
Part 2 of the question is the item of concern. The stem of the question states that the applicable RWP indicates that the highest dose rate in the area is 350 mR/hr. RWPs used to enter Locked High Radiation Areas routinely indicate radiation alarms and doses below 1 R/Hr. One example is attached.
Based on the attached RWP the operator would enter this Locked High Radiation area.
%r4j4t Brunswick Nuclear Plant INFORMATION RadIation Work Permit USE ONLY
- Koetin. Ptant Op.rx5cn.
RWP #
F Opa41ons.RouUn. Pbnt Op.n.tkm. Rounds. LAtCA Løw Riak ED ALarm SM Pnts Dose A)arm: 80 mrem Dose Rate Alarm: 400 mremlhr IJ(( jj LHRA (1ORIhr
RWP Requirements RPHo4dP&nq, io c tdfriq fci mat*
- u yi4r alv rimo c( Wni from c vnaLad syet.me. Decon may ba nacKeary (K diractad b RP}
P pflfr, r1acg OR.riy ko di. awh..d ( hat a4id above)
- IF.ciimii.d Do.. I t-hqh Thai Ezectad Nify RP hiejAmd pfor to etacir Hh Rarfladcn As F hi.
pnoc to ultndn9 Lod RsaIcn Ames
- Con tkn Proedon (PP) PRIOR TO çr1ndki, cu1ig, uffln cx en othar sss1ve ectiiMlee that may craa airborne eCtJty.
- +3 co arrki.1 5S154fl brei cx arsaairesLve atxk In ocnInaIed aresa cxi diLa low Rk tesk
- Ccr*ott RP Pbr Lo Trispot1Rce Metiai Ut coikt RQw ii a R gtcal Poiing Chne >4 nwwmlw 31J cm)
- Go RP to rema4ng aiy radIvac malaoai from aiy RCMMA cx pwbIo&
- NoevdcokedAphaL*,ra42oLavel3kma ponog boi*idW.s. sldIng, Ieee jt barHrx w*hQA R1 Intn.icfkxia Stay Thn., 4S yRqi*.nianls Speo.d In ih.FmJnb ttflhg Stop Work Cr14.rt.
o M*i-9Iop Wo - Et Atse N+/-ly RP
- Un#tl Co.. atJ Alan, cx1*d Mtldpslad 1)0.. Rat. Alarm - Stcp Wcxk Sl4 i. Ar.a NdiuIy RP or A,tt Contonilnabcn Les &e HItw Tti The Epeclad Leeta Whiten On ThIs RW P TA Slop Worl Et 1AI.x NCPP Wk Sc eLts.s Stop Wcxk Noitty FtP AnCid Not As erI.ad and E.ct.d SInp Work Ncy FtP
- II JCCW do..,aadiie 80% of ED aaqo1-il Stop Work.
ExA die
- Notify RP Expected RsdtoloIcai Con dillon.
I3enerai aces dose rstei: i nvar,br - LOCO n,rsnv Hl, contact does r5te 1CIO ntiWly
- 2fl00 nyernInr Colcxilisslsr 1ODO dpnV1O0cfl2
- 5o,VOOdpcn10Ocm
ROISRO Question #75 In preparation for a valve manipulation in the drywell, the applicable RWP indicates that the highest dose rate in the area is 350 mRlhr. A flashing red light is encountered at the entry location to the valve in the drywell.
Which one of the following completes both statements below?
The flashing red light indicates the area is a (1)
This RWP (2) be used to perform the valve manipulation.
A.
(1) high radiation area (2) can B.
(1) high radiation area (2) can NOT C. (1) locked high radiation area (2) can D.
(1) locked high radiation area (2) can NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from 0 to C.
Part 2 of the question is the item of concern. The stem of the question states that the applicable RWP indicates that the highest dose rate in the area is 350 mRlhr. RWPs used to enter Locked High Radiation Areas routinely indicate radiation alarms and doses below 1 RJHr. One example is attached.
Based on the attached RWP the operator would enter this Locked High Radiation area.
This position paper is written to support changing Exam Question #75, which provided the following:
The area in question had a flashing light at the entrance.
The operator had an approved dose rate of 350 mR/hr.
The assumption written during exam constructed was that the operator must know:
That a flashing red light is indicative of a LHRA A LHRA is doses in excess of 1000 mR/Hr That his dose of 350 mR/Hr could be exceeded, therefore he could not perform this job.
Upon further review, it was identified that in fact, the operators at BNP may enter a LHRA with dose rate settings less than 350 mR/Hr. This requires the answer to be changed to reflect this new information.
Per discussions with the Radiation Protection Manager:
A LHRA posted simply means there is exposure rates of 800 mR/hr @30 cm (plant procedures) or 1000 mR/hr @30 cm (10CFR2O requirements) accessible inside the posted area. It does not mean a work area is 800 or 1000 mR/hr general area dose rates. The confusion seems to be related to the dose rate set point for the electronic dosimeter (ED). Most dose rate set points (documented in RWP) are less than the dose rate level where the posting is required. In this case 350 mR/hr is a reasonable dose rate set point for an RWP for work inside the Drywell for any posted LHRA). The ED set points are designed to be used as a tool to maintain workers in the lowest dose rate areas that are expected for that area. We establish ED set points using TE-RP-ALL-2000 (Preparation of Radiation Work Permit). TE-RP-ALL-2000 gives ALARA planners the guidance for establishing RWP ED set points. The entire procedure is encluded for your review, but the critical information can be found in section 5 of Attachment seven:
- 5. Use thefollowingformula as a guide in determining the ED DOSE RATE setpoint:
For TWADR less thanlOO mrem/hr, multiply the TWADR by 1.5 (round to the next highest 10 mrem/hr).
This is your ED Dose Rate set point.
For TWADR greater than 100 mrem/hr, multiply the TWADR by 1.25 (round to the next highest 50 mrem/hr). This is your ED Dose Rate set point.
TWADR stands for typical work area dose rate.
The set point is not tied to the posting its tied to the work area dose rate.
Attached are excerpts from BNP procedures that:
1.
Identifies that LHRA access requires a RWP and RWP Task that specifies allowed Dose Rate Levels (Step 5 of of this document).
2.
Allows the LHRA entry with a requirement to calculate total dose, based on dose rates and time inside the LHRA (Attachment 2 of this document).
3.
Provides guidelines for using flashing lights to identify a LHRA (Attachment 3 of this document).
4.
Shows that routine operator tasks and rounds are permitted in a LHRA. (Attachment 4 of this document). and 2 of this document to validate procedural steps and the checklist to allow entry. of this document supports using a flashing light to identify a LHRA. Risk Assessment Guidelines shows that routine operator tasks and rounds are permitted in a LHRA.
Current RWP Example
- Copy of actual procedure step 5.1 ACCESS CONTROLS FOR HIGH. LOCKED HIGH, AND AD-RP-ALL-2017 VERY HIGH RADIATION AREAS Rev 1 Page8of29 5.0 INSTRUCTIONS 5.1 General Instructions 1.
Weekly verification of wntrols for restricting access to high and very high radiation areas is perfomied by site specific processes. [1.35]
2.
Free egress requirements must be maintained at all times for HRA, LHRA, and VHRAs.
a.
Locking a sng gate or turnstile is not considered preventing an individual from being able to exit the area.
b The use of a padlock oc unique locking device fULD) requires ventng the area is unoccupied prior to locking the area.
3.
II there is no sound operational reason or there is a safety concern, then do not allo access to VHRA.
4 If at any time a HRA. LHRA, or VHRA cannot be secured (e.g., failed bamcade.
broken tock. inoperable flashing light), then guard the area until it can be secured 5.
LHRA access requires an RWP and RWP task that specifies the dose rate levels in the crnrnediate ork area on the RWP.
Accessing LHRA Checklist ACCESS CONTROLS FOR HIGH, LOCKED HIGH, AND AD-RP-ALL-201 7 VERY HIGH RADIATION AREAS Rev. 1 Page 23 of 29 Accessing LHRA Checklist ATTACHMENT 6 Page 1 of I Li Obtain RP supervision approval to enter LHRA and issue LHRA key Li < 10 Rem/hour RP Supervisor or RP General Supervisor:
Li 10 Rem/hour RPM (or designee):
U Complete the following general verifications (may be performed in any order):
Li Verify workers are using the correct RWP and RWP Task Li Verify ED setpoints are appropriate for the work area Li Verify radiological briefing (both RWP and ALARA Plan if issued) is completed per AD-RP-ALL-201 1, Radiation Protection Briefings Li Verify operable dosimetry, including ED and telemetry (if required), and device placement as required by the RWP. Conduct immediately prior to LHRA entry Li Verify each worker has a Pocket External Alarm (PEA) or equivalent Li Verify continuous RP coverage is assigned as required by the RWP Li Verify stay time has been determined and timekeeper is assigned if worker is expected to receive> 500 mrem per entry or if work area is > 1.5 Rem/hour, and ensure Attachment 10, Stay Time Calculation and Time Keeper Worksheet, is completed. {7.1.2}
Li Verify communications equipment is operable if used
[J Obtain LHRA key for area Li Ensure area access controls are established, including acceptable locking devices (room lock, padlock, unique locking device, flashing light if approved) and access control guard established if required Li Perform the following upon LHRA exit:
Li Verify all workers have exited the area U Ensure area is secured and locked (or flashing light established if approved)
(signature)
Peer checked by (signature):
Use of Flashing red lights to Establish a LHRA ACCESS CONTROLS FOR HIGH, LOCKED HIGH, AND VERY HIGH RADIATION AREAS AD-RP-ALL-2017 Rev. 1 Page 20 of 29 ATTACHMENT 3 Page 1 of 1 Use Of Flashing Lights To Establish LHRA Checklist Obtain RPM (or designee) approval to establish LHRA th flashing light(s)
RPM:
Date ad Time,__________________
]usblication for alowance of flashing Lights 2.
Estat,4ish UIRA with Tech Spec. flashing tight(s) by perfomiing the fol1oMng:
fl Instat banicades to prevent inadvertent access
[1 U Position flashing light(s) so dearty visible when approached U Activate flashing light(s)
El If using AC powered light(s), then ensure drop cords tagged at each connection and at each receptacle to prevent unauthorized de-enerng of the light(s)
U Using DC (battery) powered lights 3
Fsting Light installed by (signature):
Date and Thie:_________________
4 ANSl-cjalified_RP Technician Peer check signatiire):
Performed by (signature).
Date and Time:_____________________
RP Supervisor verification performed by (signattke):
Date and Thie:________________
Log establishment aid use of flashing tight in electronic RP log Log entry by:___________________________________ Date andTime:_______________
5.
RPM Approvat (signature):_____________________________________
Date and Time:_________________________
Risk Assessment Guidelines This shows that routine operator tasks and rounds are permitted in a LHRA.
TE-RP-ALL-2000 Rev. 0 Page35of4 ATTACHMENT 9 Page 1 of 5 RWP Type and Risk Assessment Guidelines (Information Use)
[RNP. CR3, BNP. HNPJ (9.1.1 SOER 01-1 )(9.
2 JER 11-41 Low Risk Activities GENERAL RWP (CR)
No High Radiation Areas (HRAs) and no Locked High Radiation Areas (LHRAs) other than routine tasks for operations rounds, HP surveillances, inspections, and routine PMs in these areas No Hot Particle Areas (HPAs).
Activities that will NOT change radiological conditions in the plant (for example dose rates. contamination levels, air quality)
No aggressive ork activities in contaminated areas that could change the radiological conditions.
PREPARATION OF RADIATION WORK PERMIT
%FORMATION Brunswick Nuclear Plant INFORMATION USE ONLY Radiation Work Permit USE ONLY OparMione. Routine Plant Operation -Rounds RWP N R.v: *4 Task #5 OpniIons-Routlna Plant Operation. Rounds - LtWMCA. Low Risk ED Alarm Set Paints:
Dose Alarm: 80 mrem Dose Rate Alarm: 400 mrem!hr
[
LHRA <1 DR/hr Entry RWP Requirements RP Hold Points
- HP survey eqrired prior to handling debris or rrolgn malarial HP survoy roqttred alter rerro,sI cd items 1mm contemInasd systems Deco; may be necessary (as dfreded by RP)
NoURPpdcitemachrrgGRenlryMotheawheed(5feetendabove)
- IF Accumulaled Dose Is Higher Than Especled - Natty HF
- HP btiarng recyked prior ta entering High RadbUon Areas
- HP briefing rrqufrrio prior to artering Loched Rsh Radiation Areas
- Contact RadIation Protection jR% PRIOR TO grInding, cuing, buffing a any other abratha actinlias that rney create althcrrra activr:y.
- No contarnhwrad system breach a aggree>saflaahe wuk hi cartndn&md seas on thS tIM Risk task
- Contact HP Prior to Transpodirrg Racioacbw t.tatsial that could Re?ufl in a RcçlcaI Posting Change (>4 rnrrThr @30cm)
Contact RP odor to removing any radloactba material iron any RCNRMA or poarblocL
- NokonthateaknveflfredMpheLeel2orLavel3Area
- Do not alter Radidogicat boundattes. shatdhig. laces ci barriers without HP prtvM
- Adhere to Work lnslniclicns, Stay Times, hsst &nay Reqrirwnonts Spediad hi The Pre.Job Driofin; Slop Work Criteria
- DoseMsrn-SlopWok-EiatAsea-NctilyRP
- Unanticipated Dose Rate Air; or Thtd Mtldp$ed Dose Rate Mann - Stop Work-Ed the Ares - Nr$liy HP fActual Sala-Gatrena a Alpha Ctntsmlnaiai Levels Are Highs Than The Eçecled Levels Written On Uris RWP Task - Slop Worir
- Lit thoAroa-NcdfyRP
- Work Scapo Chsos - Slop Work
- Hotly HP
- AnyCce4itionsNotAs Gilded end Expected-Slop Work-NotifyRP
- liaccurrndaladdosareaches8t%ofED seipoini-Slopwak-ExittheAraa-NoUfyRP Expected Radiologiaal Condulione General ares dose rates: ci mrenhr - t000 mrenriw High contact dose rates: 100 nvemthr -2000 nvennr Cor*amlnn levat dOUG dprrVio0cn2 -<50.000 dprnlDOcml
SRO Question #83 Unit One is in MODE3, performing a reactor shutdown lAW GP-05, Unit Shutdown, in preparation for a refueling outage.
Which one of the following completes both statements below?
lAW TS3.4.9 RCS Pressure and Temperature Limits, the maximum cooldown rate is limited to _(1)_
change in any one hour period.
If the cooldown rate is exceeded, the NRC __(2)_ required to be notified lAW 10CFR5O.72, Immediate Notification Requirements for Operating Nuclear Power Reactors.
A.
(1) 50°F (2)is B.
(1) 50°F (2)Is NOT C.
(1) 100°F (2)is D.
(1) 100°F (2) is NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that this question be removed due to there being two opposing correct answers C and D.
Concerning part 2 of the question, the condition in the stem states that the cooldown rate has been exceeded. However, this statement is not bounded by a magnitude of violation.
In addition, this statement is not bounded by a duration of the violation.
The tech spec 3.4.9 basis states, Violation of the limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCS components. The consequences depend on several factors, as follows:
a.
The severity of the departure from the allowable operating pressure temperature regime or the severity of the rate of change of temperature; b.
The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced)
Therefore, based on the absence of specific information in the stem of the question it calls into question whether a principal safety barrier would or would not have been degraded. See NUREG 1022 Rev 3 page 25. It is the position of Site Licensing that, because the question does not provide the magnitude and length of time the limits were violated during the cooldown event, there is insufficient information to determine reportability. Additionally, engineering input would likely be necessary to determine if a significant cooldown event resulted in the plant being seriously degraded (i.e., reportable to the NRC per 10 CFR 50.72(b)(3)(ii)). Therefore, reportability in accordance 10CFR5O.72 is indeterminate.
SRO Question #88 Unit One is performing a shutdown with the following plant conditions:
Reactor mode switch Shutdown Reactor water level 195 inches Shutdown Cooling B Loop RHR In Service RCS Intact RHR Hx Inlet Temperature 214°F RHR Hx Outlet Temperature 210°F A loss of Off-Site power occurs with all 4 DGs starting and loading.
Thirty minutes later, Shutdown Cooling has been returned to service with the following plant conditions:
Reactor water level 225 inches RHR Hx Inlet Temperature 244°F RHR Hx Outlet Temperature 241°F Which one of the following completes the statements below?
(reference provided)
A MODE change _(1)_ occurred.
The highest EAL classification for this event is an (2).
A.
(1) has (2) Unusual Event B.
(1) has (2) Alert C.
(1) has NOT (2) Unusual Event D.
(2) has NOT (2) Alert In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from D to C.
The initial conditions, prior to the loss of offsite power, state that the Mode switch is in Shutdown, and that the RHR Hx Inlet Temperature is 214°F. According to T.S. Table 1.1-1, this places Unit One in MODE 3 due to the mode switch position and average reactor coolant temperature >212°F.
The EAL chart for MODE 3 does not contain a classification for an ALERT based on the conditions given. The only applicable classification is an UNUSAL EVENT based on the Loss of Offsite Power for >15 minutes. There are no other conditions that apply.
Based on the choices given, C is the Correct answer. There is no MODE change, and an Unusual Event is the highest EAL classification.
SRO Question 96 Which one of the following completes both statements below lAW AD-WC-ALL-0200, On-Line Work Management?
The work week schedule is locked/frozen at the (1)
Schedule Freeze Meeting.
After the work week is frozen, if FIN team work is required, an On-line/Outage Scope Change Request j required.
A.
(1) T-3 (2) is B.
(1) T-3 (2) is NOT C.
(1) T-10 (2) is D.
(1) T-1O (2) is NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b, the facility recommends that the question be deleted from the exam, as it is NOT SRO Level Knowledge. This question does not contain a direct tie to the licensing duties of an SRO and is performed outside of the control room. This process is not specific to SRO and is performed by several different members of the organization including Maintenance and Work Control team members.
ROISRO Question #2 Brunswick Nuclear Plant December 2015 (ILT 2015) Initial License Examination During a startup on Unit Two, control rod 30-39 is desired to be moved continuously from 12 to 48.
Which one of the following completes both statements below?
The minimum number of RMCS control switches needed to accomplish this control rod movement is (1)
During this control rod movement the largest power change will be seen on SRM (2)
A.
(1) one (2)
B B.
(1) one (2) C C.
(1) two (2)
B D.
(1) two (2) C In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b, the wrong answer being selected on the answer key, the facility recommends that the correct answer be changed from 0 to C,.
F+/-+[t1++/-+It+t+
Li,+/-+,+I++/-+/-+/-+/-t+/-
I+I+++I+++++++++
41 ll[+++z
+++++++++++++/-
++++++++++++
++/-+/-+/-t+++/-+/-Y+++/-+/-
C 1+ +/-+ +/-+
1 33 35
25 27 25 23 21
I I
35 27
3 61 Et r1r++m+111J4 fl n
Part 2 of the question identifies the wrong SRM Channel.
It is the B SRM detector, instead of C.
The validation of the question did not identify this error.
FIGURE 09.1-2 IN-Core Instrumentation Location Diagram IRM DETECTOR LOCATION SRM DETECTOR LOCATION CORE SRM LOCATION A
12-33 8
2841 C
36-26 D
20-77 CORE RU LOCATION A
1241 8
3541 C
20-33 O
28-33 CORE IRM LOCATION E
28-25 F
20-25 C
36-09 H
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ROISRO Question #75 In preparation for a valve manipulation in the drywell, the applicable RWP indicates that the highest dose rate in the area is 350 mR/hr. A flashing red light is encountered at the entry location to the valve in the drywell.
Which one of the following completes both statements below?
The flashing red light indicates the area is a (1)
This RWP (2) be used to perform the valve manipulation.
A.
(1) high radiation area (2) can B.
(1) high radiation area (2) can NOT C.
(1) locked high radiation area (2) can D.
(1) locked high radiation area (2) can NOT In accordance with NUREG-1021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from 0 to C.
Part 2 of the question is the item of concern. The stem of the question states that the applicable RWP indicates that the highest dose rate in the area is 350 mR/hr. RWPs used to enter Locked High Radiation Areas routinely indicate radiation alarms and doses below 1 R/Hr. One example is attached.
Based on the attached RWP the operator would enter this Locked High Radiation area.
%r4j4t Brunswick Nuclear Plant INFORMATION RadIation Work Permit USE ONLY
- Koetin. Ptant Op.rx5cn.
RWP #
F Opa41ons.RouUn. Pbnt Op.n.tkm. Rounds. LAtCA Løw Riak ED ALarm SM Pnts Dose A)arm: 80 mrem Dose Rate Alarm: 400 mremlhr IJ(( jj LHRA (1ORIhr
RWP Requirements RPHo4dP&nq, io c tdfriq fci mat*
- u yi4r alv rimo c( Wni from c vnaLad syet.me. Decon may ba nacKeary (K diractad b RP}
P pflfr, r1acg OR.riy ko di. awh..d ( hat a4id above)
- IF.ciimii.d Do.. I t-hqh Thai Ezectad Nify RP hiejAmd pfor to etacir Hh Rarfladcn As F hi.
pnoc to ultndn9 Lod RsaIcn Ames
- Con tkn Proedon (PP) PRIOR TO çr1ndki, cu1ig, uffln cx en othar sss1ve ectiiMlee that may craa airborne eCtJty.
- +3 co arrki.1 5S154fl brei cx arsaairesLve atxk In ocnInaIed aresa cxi diLa low Rk tesk
- Ccr*ott RP Pbr Lo Trispot1Rce Metiai Ut coikt RQw ii a R gtcal Poiing Chne >4 nwwmlw 31J cm)
- Go RP to rema4ng aiy radIvac malaoai from aiy RCMMA cx pwbIo&
- NoevdcokedAphaL*,ra42oLavel3kma ponog boi*idW.s. sldIng, Ieee jt barHrx w*hQA R1 Intn.icfkxia Stay Thn., 4S yRqi*.nianls Speo.d In ih.FmJnb ttflhg Stop Work Cr14.rt.
o M*i-9Iop Wo - Et Atse N+/-ly RP
- Un#tl Co.. atJ Alan, cx1*d Mtldpslad 1)0.. Rat. Alarm - Stcp Wcxk Sl4 i. Ar.a NdiuIy RP or A,tt Contonilnabcn Les &e HItw Tti The Epeclad Leeta Whiten On ThIs RW P TA Slop Worl Et 1AI.x NCPP Wk Sc eLts.s Stop Wcxk Noitty FtP AnCid Not As erI.ad and E.ct.d SInp Work Ncy FtP
- II JCCW do..,aadiie 80% of ED aaqo1-il Stop Work.
ExA die
- Notify RP Expected RsdtoloIcai Con dillon.
I3enerai aces dose rstei: i nvar,br - LOCO n,rsnv Hl, contact does r5te 1CIO ntiWly
- 2fl00 nyernInr Colcxilisslsr 1ODO dpnV1O0cfl2
- 5o,VOOdpcn10Ocm
ROISRO Question #75 In preparation for a valve manipulation in the drywell, the applicable RWP indicates that the highest dose rate in the area is 350 mRlhr. A flashing red light is encountered at the entry location to the valve in the drywell.
Which one of the following completes both statements below?
The flashing red light indicates the area is a (1)
This RWP (2) be used to perform the valve manipulation.
A.
(1) high radiation area (2) can B.
(1) high radiation area (2) can NOT C. (1) locked high radiation area (2) can D.
(1) locked high radiation area (2) can NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from 0 to C.
Part 2 of the question is the item of concern. The stem of the question states that the applicable RWP indicates that the highest dose rate in the area is 350 mRlhr. RWPs used to enter Locked High Radiation Areas routinely indicate radiation alarms and doses below 1 RJHr. One example is attached.
Based on the attached RWP the operator would enter this Locked High Radiation area.
This position paper is written to support changing Exam Question #75, which provided the following:
The area in question had a flashing light at the entrance.
The operator had an approved dose rate of 350 mR/hr.
The assumption written during exam constructed was that the operator must know:
That a flashing red light is indicative of a LHRA A LHRA is doses in excess of 1000 mR/Hr That his dose of 350 mR/Hr could be exceeded, therefore he could not perform this job.
Upon further review, it was identified that in fact, the operators at BNP may enter a LHRA with dose rate settings less than 350 mR/Hr. This requires the answer to be changed to reflect this new information.
Per discussions with the Radiation Protection Manager:
A LHRA posted simply means there is exposure rates of 800 mR/hr @30 cm (plant procedures) or 1000 mR/hr @30 cm (10CFR2O requirements) accessible inside the posted area. It does not mean a work area is 800 or 1000 mR/hr general area dose rates. The confusion seems to be related to the dose rate set point for the electronic dosimeter (ED). Most dose rate set points (documented in RWP) are less than the dose rate level where the posting is required. In this case 350 mR/hr is a reasonable dose rate set point for an RWP for work inside the Drywell for any posted LHRA). The ED set points are designed to be used as a tool to maintain workers in the lowest dose rate areas that are expected for that area. We establish ED set points using TE-RP-ALL-2000 (Preparation of Radiation Work Permit). TE-RP-ALL-2000 gives ALARA planners the guidance for establishing RWP ED set points. The entire procedure is encluded for your review, but the critical information can be found in section 5 of Attachment seven:
- 5. Use thefollowingformula as a guide in determining the ED DOSE RATE setpoint:
For TWADR less thanlOO mrem/hr, multiply the TWADR by 1.5 (round to the next highest 10 mrem/hr).
This is your ED Dose Rate set point.
For TWADR greater than 100 mrem/hr, multiply the TWADR by 1.25 (round to the next highest 50 mrem/hr). This is your ED Dose Rate set point.
TWADR stands for typical work area dose rate.
The set point is not tied to the posting its tied to the work area dose rate.
Attached are excerpts from BNP procedures that:
1.
Identifies that LHRA access requires a RWP and RWP Task that specifies allowed Dose Rate Levels (Step 5 of of this document).
2.
Allows the LHRA entry with a requirement to calculate total dose, based on dose rates and time inside the LHRA (Attachment 2 of this document).
3.
Provides guidelines for using flashing lights to identify a LHRA (Attachment 3 of this document).
4.
Shows that routine operator tasks and rounds are permitted in a LHRA. (Attachment 4 of this document). and 2 of this document to validate procedural steps and the checklist to allow entry. of this document supports using a flashing light to identify a LHRA. Risk Assessment Guidelines shows that routine operator tasks and rounds are permitted in a LHRA.
Current RWP Example
- Copy of actual procedure step 5.1 ACCESS CONTROLS FOR HIGH. LOCKED HIGH, AND AD-RP-ALL-2017 VERY HIGH RADIATION AREAS Rev 1 Page8of29 5.0 INSTRUCTIONS 5.1 General Instructions 1.
Weekly verification of wntrols for restricting access to high and very high radiation areas is perfomied by site specific processes. [1.35]
2.
Free egress requirements must be maintained at all times for HRA, LHRA, and VHRAs.
a.
Locking a sng gate or turnstile is not considered preventing an individual from being able to exit the area.
b The use of a padlock oc unique locking device fULD) requires ventng the area is unoccupied prior to locking the area.
3.
II there is no sound operational reason or there is a safety concern, then do not allo access to VHRA.
4 If at any time a HRA. LHRA, or VHRA cannot be secured (e.g., failed bamcade.
broken tock. inoperable flashing light), then guard the area until it can be secured 5.
LHRA access requires an RWP and RWP task that specifies the dose rate levels in the crnrnediate ork area on the RWP.
Accessing LHRA Checklist ACCESS CONTROLS FOR HIGH, LOCKED HIGH, AND AD-RP-ALL-201 7 VERY HIGH RADIATION AREAS Rev. 1 Page 23 of 29 Accessing LHRA Checklist ATTACHMENT 6 Page 1 of I Li Obtain RP supervision approval to enter LHRA and issue LHRA key Li < 10 Rem/hour RP Supervisor or RP General Supervisor:
Li 10 Rem/hour RPM (or designee):
U Complete the following general verifications (may be performed in any order):
Li Verify workers are using the correct RWP and RWP Task Li Verify ED setpoints are appropriate for the work area Li Verify radiological briefing (both RWP and ALARA Plan if issued) is completed per AD-RP-ALL-201 1, Radiation Protection Briefings Li Verify operable dosimetry, including ED and telemetry (if required), and device placement as required by the RWP. Conduct immediately prior to LHRA entry Li Verify each worker has a Pocket External Alarm (PEA) or equivalent Li Verify continuous RP coverage is assigned as required by the RWP Li Verify stay time has been determined and timekeeper is assigned if worker is expected to receive> 500 mrem per entry or if work area is > 1.5 Rem/hour, and ensure Attachment 10, Stay Time Calculation and Time Keeper Worksheet, is completed. {7.1.2}
Li Verify communications equipment is operable if used
[J Obtain LHRA key for area Li Ensure area access controls are established, including acceptable locking devices (room lock, padlock, unique locking device, flashing light if approved) and access control guard established if required Li Perform the following upon LHRA exit:
Li Verify all workers have exited the area U Ensure area is secured and locked (or flashing light established if approved)
(signature)
Peer checked by (signature):
Use of Flashing red lights to Establish a LHRA ACCESS CONTROLS FOR HIGH, LOCKED HIGH, AND VERY HIGH RADIATION AREAS AD-RP-ALL-2017 Rev. 1 Page 20 of 29 ATTACHMENT 3 Page 1 of 1 Use Of Flashing Lights To Establish LHRA Checklist Obtain RPM (or designee) approval to establish LHRA th flashing light(s)
RPM:
Date ad Time,__________________
]usblication for alowance of flashing Lights 2.
Estat,4ish UIRA with Tech Spec. flashing tight(s) by perfomiing the fol1oMng:
fl Instat banicades to prevent inadvertent access
[1 U Position flashing light(s) so dearty visible when approached U Activate flashing light(s)
El If using AC powered light(s), then ensure drop cords tagged at each connection and at each receptacle to prevent unauthorized de-enerng of the light(s)
U Using DC (battery) powered lights 3
Fsting Light installed by (signature):
Date and Thie:_________________
4 ANSl-cjalified_RP Technician Peer check signatiire):
Performed by (signature).
Date and Time:_____________________
RP Supervisor verification performed by (signattke):
Date and Thie:________________
Log establishment aid use of flashing tight in electronic RP log Log entry by:___________________________________ Date andTime:_______________
5.
RPM Approvat (signature):_____________________________________
Date and Time:_________________________
Risk Assessment Guidelines This shows that routine operator tasks and rounds are permitted in a LHRA.
TE-RP-ALL-2000 Rev. 0 Page35of4 ATTACHMENT 9 Page 1 of 5 RWP Type and Risk Assessment Guidelines (Information Use)
[RNP. CR3, BNP. HNPJ (9.1.1 SOER 01-1 )(9.
2 JER 11-41 Low Risk Activities GENERAL RWP (CR)
No High Radiation Areas (HRAs) and no Locked High Radiation Areas (LHRAs) other than routine tasks for operations rounds, HP surveillances, inspections, and routine PMs in these areas No Hot Particle Areas (HPAs).
Activities that will NOT change radiological conditions in the plant (for example dose rates. contamination levels, air quality)
No aggressive ork activities in contaminated areas that could change the radiological conditions.
PREPARATION OF RADIATION WORK PERMIT
%FORMATION Brunswick Nuclear Plant INFORMATION USE ONLY Radiation Work Permit USE ONLY OparMione. Routine Plant Operation -Rounds RWP N R.v: *4 Task #5 OpniIons-Routlna Plant Operation. Rounds - LtWMCA. Low Risk ED Alarm Set Paints:
Dose Alarm: 80 mrem Dose Rate Alarm: 400 mrem!hr
[
LHRA <1 DR/hr Entry RWP Requirements RP Hold Points
- HP survey eqrired prior to handling debris or rrolgn malarial HP survoy roqttred alter rerro,sI cd items 1mm contemInasd systems Deco; may be necessary (as dfreded by RP)
NoURPpdcitemachrrgGRenlryMotheawheed(5feetendabove)
- IF Accumulaled Dose Is Higher Than Especled - Natty HF
- HP btiarng recyked prior ta entering High RadbUon Areas
- HP briefing rrqufrrio prior to artering Loched Rsh Radiation Areas
- Contact RadIation Protection jR% PRIOR TO grInding, cuing, buffing a any other abratha actinlias that rney create althcrrra activr:y.
- No contarnhwrad system breach a aggree>saflaahe wuk hi cartndn&md seas on thS tIM Risk task
- Contact HP Prior to Transpodirrg Racioacbw t.tatsial that could Re?ufl in a RcçlcaI Posting Change (>4 rnrrThr @30cm)
Contact RP odor to removing any radloactba material iron any RCNRMA or poarblocL
- NokonthateaknveflfredMpheLeel2orLavel3Area
- Do not alter Radidogicat boundattes. shatdhig. laces ci barriers without HP prtvM
- Adhere to Work lnslniclicns, Stay Times, hsst &nay Reqrirwnonts Spediad hi The Pre.Job Driofin; Slop Work Criteria
- DoseMsrn-SlopWok-EiatAsea-NctilyRP
- Unanticipated Dose Rate Air; or Thtd Mtldp$ed Dose Rate Mann - Stop Work-Ed the Ares - Nr$liy HP fActual Sala-Gatrena a Alpha Ctntsmlnaiai Levels Are Highs Than The Eçecled Levels Written On Uris RWP Task - Slop Worir
- Lit thoAroa-NcdfyRP
- Work Scapo Chsos - Slop Work
- Hotly HP
- AnyCce4itionsNotAs Gilded end Expected-Slop Work-NotifyRP
- liaccurrndaladdosareaches8t%ofED seipoini-Slopwak-ExittheAraa-NoUfyRP Expected Radiologiaal Condulione General ares dose rates: ci mrenhr - t000 mrenriw High contact dose rates: 100 nvemthr -2000 nvennr Cor*amlnn levat dOUG dprrVio0cn2 -<50.000 dprnlDOcml
SRO Question #83 Unit One is in MODE3, performing a reactor shutdown lAW GP-05, Unit Shutdown, in preparation for a refueling outage.
Which one of the following completes both statements below?
lAW TS3.4.9 RCS Pressure and Temperature Limits, the maximum cooldown rate is limited to _(1)_
change in any one hour period.
If the cooldown rate is exceeded, the NRC __(2)_ required to be notified lAW 10CFR5O.72, Immediate Notification Requirements for Operating Nuclear Power Reactors.
A.
(1) 50°F (2)is B.
(1) 50°F (2)Is NOT C.
(1) 100°F (2)is D.
(1) 100°F (2) is NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that this question be removed due to there being two opposing correct answers C and D.
Concerning part 2 of the question, the condition in the stem states that the cooldown rate has been exceeded. However, this statement is not bounded by a magnitude of violation.
In addition, this statement is not bounded by a duration of the violation.
The tech spec 3.4.9 basis states, Violation of the limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCS components. The consequences depend on several factors, as follows:
a.
The severity of the departure from the allowable operating pressure temperature regime or the severity of the rate of change of temperature; b.
The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced)
Therefore, based on the absence of specific information in the stem of the question it calls into question whether a principal safety barrier would or would not have been degraded. See NUREG 1022 Rev 3 page 25. It is the position of Site Licensing that, because the question does not provide the magnitude and length of time the limits were violated during the cooldown event, there is insufficient information to determine reportability. Additionally, engineering input would likely be necessary to determine if a significant cooldown event resulted in the plant being seriously degraded (i.e., reportable to the NRC per 10 CFR 50.72(b)(3)(ii)). Therefore, reportability in accordance 10CFR5O.72 is indeterminate.
SRO Question #88 Unit One is performing a shutdown with the following plant conditions:
Reactor mode switch Shutdown Reactor water level 195 inches Shutdown Cooling B Loop RHR In Service RCS Intact RHR Hx Inlet Temperature 214°F RHR Hx Outlet Temperature 210°F A loss of Off-Site power occurs with all 4 DGs starting and loading.
Thirty minutes later, Shutdown Cooling has been returned to service with the following plant conditions:
Reactor water level 225 inches RHR Hx Inlet Temperature 244°F RHR Hx Outlet Temperature 241°F Which one of the following completes the statements below?
(reference provided)
A MODE change _(1)_ occurred.
The highest EAL classification for this event is an (2).
A.
(1) has (2) Unusual Event B.
(1) has (2) Alert C.
(1) has NOT (2) Unusual Event D.
(2) has NOT (2) Alert In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b and c, the facility recommends that the correct answer be changed from D to C.
The initial conditions, prior to the loss of offsite power, state that the Mode switch is in Shutdown, and that the RHR Hx Inlet Temperature is 214°F. According to T.S. Table 1.1-1, this places Unit One in MODE 3 due to the mode switch position and average reactor coolant temperature >212°F.
The EAL chart for MODE 3 does not contain a classification for an ALERT based on the conditions given. The only applicable classification is an UNUSAL EVENT based on the Loss of Offsite Power for >15 minutes. There are no other conditions that apply.
Based on the choices given, C is the Correct answer. There is no MODE change, and an Unusual Event is the highest EAL classification.
SRO Question 96 Which one of the following completes both statements below lAW AD-WC-ALL-0200, On-Line Work Management?
The work week schedule is locked/frozen at the (1)
Schedule Freeze Meeting.
After the work week is frozen, if FIN team work is required, an On-line/Outage Scope Change Request j required.
A.
(1) T-3 (2) is B.
(1) T-3 (2) is NOT C.
(1) T-10 (2) is D.
(1) T-1O (2) is NOT In accordance with NUREG-1 021, Operator Licensing Examination Standards for Power Reactors, ES-403, Section D.1.b, the facility recommends that the question be deleted from the exam, as it is NOT SRO Level Knowledge. This question does not contain a direct tie to the licensing duties of an SRO and is performed outside of the control room. This process is not specific to SRO and is performed by several different members of the organization including Maintenance and Work Control team members.