ML17081A535
| ML17081A535 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/09/2017 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Energy Northwest |
| GADDY V | |
| References | |
| Download: ML17081A535 (50) | |
Text
N/A N/A CGS 2017 NRC Written Examination Question Analysis (Questions ZLWKSDVVUDWHV
Identified Issues Question % Training Wording Question
- Correct Deficiencies Problems Validity Explanation This question has no correct answer as written. Requested that the RO-9 40% X question be deleted from the examination.
This question has a learning objective tie. Individual knowledge gap. See RO-27 40%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See RO-42 50%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See RO-50 30%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See RO-70 40%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See RO-72 50%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See SRO-78 16.7%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See SRO-84 16.7%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See SRO-86 50%
Note 1 below.
This question has two correct answers. Requested that both answers B SRO-90 33.3% X and C be accepted as correct. This will raise the % correct to 66.7%
This question has a learning objective tie. Individual knowledge gap. See SRO-94 33.3%
Note 1 below.
This question has a learning objective tie. Individual knowledge gap. See SRO-95 33.3%
Note 1 below.
SRO-100 50% This question has a learning objective tie. Individual knowledge gap. See ATTACHMENT 7 (Page 1 of 2)
CGS 2017 NRC Written Examination Question Analysis (Questions ZLWKSDVVUDWHV
Note 1 below.
Notes:
- 1. Any question with at least one missed answer on the RO and SRO written exams were remediated with ILC 22 on 3/10/17. All student comments were captured and addressed as needed elsewhere in this report. Question topics with 50% or greater miss rate will be incorporated into ILC 22 transition training (tracked under AR 344549-08). This training is required prior to transitioning onto shift and into license requalification training.
ATTACHMENT 7 (Page 2 of 2)
CGS ILC-22 Post NRC Written Exam Review Question RO-9 Questions asked by applicants:
55-24106: Would we drain the SFP since the stem states that the plant is in Mode 4?
55-41899: In Mode 4, there is no communication between the SFP and the RPV.
Station Response:
On a loss of SDC, ABN-RHR-SDC-LOSS, Loss of Shutdown Cooling, is entered. Step
4.1.9 reads
Since RPV temperature is slowly rising and normal RHR SDC cannot be restored, the procedures listed in ABN-RHR-SDC-LOSS should be referenced.
Explanation for Question Distractors Distractor A, Restore RHR Loop A to SDC mode with suction from the spent fuel pool per ABN-RHR-SDC-LOSS, Loss of Shutdown Cooling, is not correct since RHR-V-8 is stuck closed and RHR-P-2A cannot take suction from the spent fuel pool.
Distractor B, Shift RHR-P-2B to SDC mode with suction from the spent fuel pool per ABN-RHR-SDC-ALT, Residual Heat Removal Alternate Shutdown Cooling, is not correct due to the conditions given in the question stem.
Aligning RHR-P-2B to take a suction from the spent fuel pool is accomplished by performing ABN-RHR-SDC-ALT, section 7.2, Placing RHR B in Shutdown Cooling With Suction From Fuel Pool Cooling.
This was the proposed answer.
ATTACHMENT 9 (Page 1 of 22)
CGS ILC-22 Post NRC Written Exam Review However, step 7.2.5 and 7.2.6 state:
Steps 7.2.5 and 7.2.6 are verification steps when the vessel cavity is already flooded up and gates removed. With the station in Mode 4, vessel disassembly procedure 10.3.21 would be required. SOP-CAVITY-FILL is performed in conjunction with procedure 10.3.21 to fill the vessel. This would take significant time and require vessel temperature less than 200 degrees per step 6.4.5 of procedure 10.3.21, Verify plant is in Mode 4 prior to loosening Drywell head flange bolts. Therefore, vessel disassembly cant continue unless a SDC method is in service to maintain RPV water temperature LT 200 degrees.
If the stem of the question was modified to place the reactor in Mode 5, distractor B would be correct.
Distractor C, Initiate shutdown cooling through main steam line drain valves per ABN-ADHR, Alternate Decay Heat Removal, is not correct since the question asked for the actions necessary to restore shutdown cooling. ABN-ADHR provides an alternate decay heat removal method, not a SDC method. It will not maintain RPV temperature LT 200 degrees F. Additionally, entry conditions for ABN-ADHR state:
Entry conditions for ABN-ADHR are not met since an alternate SDC method is not in use.
ATTACHMENT 9 (Page 2 of 22)
CGS ILC-22 Post NRC Written Exam Review Distractor D, Place RHR Loop B in the Fuel Pool Cooling Assist mode per ABN-FPC-ASSIST-ALT, Alternate Fuel Pool Cooling Assist, is not correct since this method requires RHR to be lined up with suction from RHR-V-8 & 9 and RHR-V-8 is stuck closed.
For the conditions given, RPV cooling should be restored by either performing ABN-RHR-SDC-ALT, sections 7.1.1, Discharge Steam to the Main Condenser, or ABN-RHR-SDC-ALT, section 7.1.3, Discharge Water Through the SRV to the Suppression Pool.
These were not given as answer choices.
ABN-RHR-SDC-ALT, section 4.0, Subsequent Operator Actions, reads: .1 (including sections 7.1.1 and 7.1.3) is the preferred method of alternate SDC. The following notes are included at the beginning of Attachment 7.1:
ATTACHMENT 9 (Page 3 of 22)
CGS ILC-22 Post NRC Written Exam Review Section 7.1.1 requires the main condenser to be available with a vacuum established.
Information in the question stem does not preclude this. .1.3 would be performed if it was desired to maintain reactor temperature less than 200qF. This requires suppression pool cooling, which is available via RHR-P-2B.
Note that although ABN-RHR-SDC-LOSS, section 7.1.2, Discharge Steam to the Suppression Pool, could be used to restore RPV cooling, it would only be used if the condenser were not available as a heat sink.
Note at the beginning of section 7.1.2:
ATTACHMENT 9 (Page 4 of 22)
CGS ILC-22 Post NRC Written Exam Review Since there are no correct answers, Columbia Generating Station requests deleting this question.
ATTACHMENT 9 (Page 5 of 22)
CGS ILC-22 Post NRC Written Exam Review References for ABN-RHR-SDC-ALT, section 7.1.1 or 7.1.3:
ATTACHMENT 9 (Page 6 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 7 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 8 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 9 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 10 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 11 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 12 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 13 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 14 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 15 of 22)
CGS ILC-22 Post NRC Written Exam Review ATTACHMENT 9 (Page 16 of 22)
CGS ILC-22 Post NRC Written Exam Review Originally-Submitted question with Question: background references CGS is in Mode 4.
x RHR Loop A is in Shutdown Cooling (SDC) mode.
x RHR Loop B is in Suppression Pool Cooling (SPC) mode.
x OSP-ELEC-M701, DG1 Monthly Operability Test is in progress.
The following indications are observed:
x Annunciator H13-P601.A4.2-3, RHR A PUMP TRIP, is in alarm.
x RHR-V-8, Shutdown Cooling Suction Isolation Valve, is CLOSED.
x Field operators report that RHR-V-8 cannot be manually opened.
x RPV Pressure indicates 2 psig x Reactor coolant temperature is 195qF, up slow.
x Both RRC pumps are secured.
What actions should be taken to restore SDC?
A. Restore RHR Loop A to SDC mode with suction from the spent fuel pool per ABN-RHR-SDC-LOSS, Loss of Shutdown Cooling.
B. Shift RHR-P-2B to SDC mode with suction from the spent fuel pool per ABN-RHR-SDC-ALT, Residual Heat Removal Alternate Shutdown Cooling.
C. Initiate shutdown cooling through main steam line drain valves per ABN-ADHR, Alternate Decay Heat Removal.
D. Place RHR Loop B in the Fuel Pool Cooling Assist mode per ABN-FPC-ASSIST-ALT, Alternate Fuel Pool Cooling Assist.
Original Answer: B ATTACHMENT 9 (Page 17 of 22)
CGS ILC-22 Post NRC Written Exam Review Applicant Performance Pass Rate: 60%
A selected: 0%
B selected: 60%
C selected: 40%
D selected: 0%
ATTACHMENT 9 (Page 18 of 22)
CGS ILC-22 Post NRC Written Exam Review
References:
Comments /
Reference:
ABN-RHR-SDC-LOSS Revision: 6 ATTACHMENT 9 (Page 19 of 22)
CGS ILC-22 Post NRC Written Exam Review Comments /
Reference:
ABN-RHR-SDC-ALT Revision: 13 ATTACHMENT 9 (Page 20 of 22)
CGS ILC-22 Post NRC Written Exam Review Comments /
Reference:
ABN-ADHR Revision: 0 ATTACHMENT 9 (Page 21 of 22)
CGS ILC-22 Post NRC Written Exam Review Comments /
Reference:
SOP-FPC-ASSIST-ALT Revision: 010 ATTACHMENT 9 (Page 22 of 22)
RO Q#29 In-Exam Justification for Modifying Question RO-29 During the Examination.Modification Question Number: RO-29 Original question:
CGS is operating in Mode1.
A LOCA has occurred, requiring the crew to scram the reactor and enter the EOPs.
Current plant conditions:
x RPV level is -135 inches, up slow.
x RPV pressure is 320 psig, down slow.
x Drywell pressure peaked at 1.60 psig. Current pressure is 1.55 psig, down slow.
x RHR-P-2B failed to automatically start.
x All other automatic actuations were successful.
What is the status of RHR Loop B if the operator ARMS and DEPRESSES RHR-RMS-S60 (RHR B and C MANUAL INITIATION pushbutton)?
RHR-V-64B (RHR Loop B Minimum Flow Bypass valve) is (1) and RHR Loop B is (2) into the RPV.
A. (1) open (2) injecting B. (1) closed (2) not injecting C. (1) closed (2) injecting D. (1) open (2) not injecting ATTACHMENT 10 (Page 1 of 5)
Justification for Modifying Question RO-29 During the Examination.
References:
Comments /
Reference:
SOP-RHRA-INJECTION Revision: Major 003 Minor 002 ATTACHMENT 10 (Page 2 of 5)
Justification for Modifying Question RO-29 During the Examination.
Question 55-42915: After Arm & Depress What is the status? Does this mean immediately, 1 second later, 15 seconds later?
Station Response RHR-V-64B has an eight second delay prior to opening on an automatic open signal.
The original question stem did not specify a time for checking system status after the automatic initiation signal from operating the RHR A and B Manual Initiation pushbutton.
After consulting with the chief examiner, the question stem was modified, as described below.
The change was communicated to all applicants during the examination.
Modification discussed and approved by Chief Examiner during examination administration.
No post-exam NRC review required. -TJF ATTACHMENT 10 (Page 3 of 5)
Justification for Modifying Question RO-29 During the Examination.
Modified Question:
CGS is operating in Mode1.
A LOCA has occurred, requiring the crew to scram the reactor and enter the EOPs.
Current plant conditions:
x RPV level is -135 inches, up slow.
x RPV pressure is 320 psig, down slow.
x Drywell pressure peaked at 1.60 psig. Current pressure is 1.55 psig, down slow.
x RHR-P-2B failed to automatically start.
x All other automatic actuations were successful.
What is the status of RHR Loop B if one minute after the operator ARMS and DEPRESSES RHR-RMS-S60 (RHR B and C MANUAL INITIATION pushbutton)?
RHR-V-64B (RHR Loop B Minimum Flow Bypass valve) is (1) and RHR Loop B is (2) into the RPV.
A. (1) open (2) injecting B. (1) closed (2) not injecting C. (1) closed (2) injecting D. (1) open (2) not injecting ATTACHMENT 10 (Page 4 of 5)
Justification for Modifying Question RO-29 During the Examination.
References:
DWG-9E-057, Revision 20 QC1 Time Delay Relay Settings, E514-30, SH 7 of 8 ATTACHMENT 10 (Page 5 of 5)
CGS ILC-22 Post NRC Written Exam Review Question SRO-90 Questions asked by applicants:
There were no questions asked by any of the applicants during administration of the examination.
Post - Exam analysis indicated a second possible correct answer.
Station Response:
In accordance with ABN-RCC, Loss of RCC, answer B is correct. Step 4.2.6 states:
However, per ABN-FPC-LOSS, Loss of Fuel Pool Cooling, step 4.1.5:
Although the order of step performance within an ABN is delineated, CRS discretion is used to determine the order of steps performed from multiple applicable ABNs.
Therefore, the CRS may elect to perform either step next to address station priorities.
This makes distractor C a correct answer also.
Columbia Generating Station requests accepting B and C as correct answers.
During initial question development, the actions of abnormal procedures beyond ABN-RCC were not considered. When considering actions of ABN-RCC only, addressing the issue of the CRD pump would be the priority since the CRD pump meets the conditions required to take actions per ABN-RCC, step 4.2.6. Although FPC temperature is slowly rising, it is below 125qF, which is the maximum temperature that would be allowed prior to transferring FPC cooling to SW per ABN-RCC, step 4.2.11.
During post-exam question analysis, it was determined that conditions exist for concurrent entry into ABN-FPC-LOSS:
ATTACHMENT 11 (Page 1 of 13)
CGS ILC-22 Post NRC Written Exam Review The CRS may enter ABN-FPC-LOSS concurrent with ABN-RCC.
ABN-FPC-LOSS, step 4.1.5 states:
This step is different from ABN-RCC, step 4.2.11. It is not dependent on reaching a specified temperature. Therefore, the CRS may direct operators to line-up SW independent of FP temperature, once it is determined that an unplanned loss of cooling has occurred and RCC cannot be restored to the fuel pool cooling heat exchangers.
ATTACHMENT 11 (Page 2 of 13)
CGS ILC-22 Post NRC Written Exam Review The following is given in OI-09, Operations Standards and Expectation:
The CRS has discretion to take actions, per applicable procedures, to restore equipment or systems to their normal controlled status.
ATTACHMENT 11 (Page 3 of 13)
CGS ILC-22 Post NRC Written Exam Review Original Question Question:
CGS is operating in Mode 1.
x RCC-P-1A and RCC-P-1B are running.
RCC-P-1B tripped.
x RCC-P-1B and RCC-P-1C cannot be started.
x Troubleshooting activities are in progress on both pumps.
Current plant conditions:
x RRC-P-1A stator temperature is 190qF, up slow.
x Fuel Pool Cooling (FPC) HX outlet temperature is 100qF, up slow.
x Drywell pressure is 0.26 psig, up slow.
x Field operators report that CRD-P-1A (running CRD pump), lube oil housing is hot to the touch.
What is the next action that should be taken?
The CRS should direct the crew to A. trip RRC-P-1A and enter ABN-RRC, Loss of Reactor Recirculation Flow.
B. start CRD-P-1B and secure CRD-P-1A per SOP-CRD-PUMPS, Control Rod Drive System Pump Operations.
C. transfer the FPC system cooling to Service Water per SOP-FPC-OPS, Fuel Pool Cooling and Cleanup Operations.
D. vent the drywell per SOP-CN-CONT-VENT, Containment Vent, Deinert, Purge, and Ventilating.
Original Answer: B Explanation:
A. Incorrect. Plausible since ABN-RCC, step 4.2.4 directs operators to monitor RRC pump parameters, RRC-P-1A stator temperature has risen approximately 50qF, and if the temperature continues to rise, the pump should be tripped per Alarm Response Procedure 602.A6.6-6. However, the pump is not required to be tripped until stator temperature reaches 266qF, and the CRD pump is a more immediate issue.
ATTACHMENT 11 (Page 4 of 13)
CGS ILC-22 Post NRC Written Exam Review B. Correct. With reduced RCC flow, ABN-RCC, step 4.2.6 directs CRD pump cooling be transferred to the Condensate Transfer header OR CRD pumps be periodically shifted if CRD pump lube oil housing temperature is hot to the touch.
C. Incorrect. Plausible since a FP temperature has risen approximately 10qF. However, ABN-RCC, step 4.2.11 directs transferring FPC cooling to SW is FP temperature cannot be maintained 125qF, and the CRD pump is a more immediate issue.
D. Incorrect. Plausible since ABN-RCC, step 4.2.8 directs the drywell to be vented if pressure is rising due to inadequate RCC cooling. However, ABN subsequent operator actions should be performed in order and addressing the CRD pumps is in step 4.2.6. Additionally, drywell pressure is still within the normal band of 0.25 psig to 0.75 psig (see SOP-CN-CONT-VENT, 4.16), with pressure slowly rising. The CRD pump is a more immediate concern.
Applicant Performance Correct Response: 33%
A selected: 33%
B selected: 33%
C selected: 33%
D selected: 0%
ATTACHMENT 11 (Page 5 of 13)
CGS ILC-22 Post NRC Written Exam Review Procedural reference for Correct answer B
References:
Comments /
Reference:
ABN-RCC, Loss of RCC Revision: Major 006 Minor 003 ATTACHMENT 11 (Page 6 of 13)
Procedural reference for CGS ILC-22 Post NRC Written Exam Review Correct answer B (CONT.)
Comments /
Reference:
ABN-RCC - Bases Revision: Major 006 Minor 003 ATTACHMENT 11 (Page 7 of 13)
CGS ILC-22 Post NRC Written Exam Review Comments /
Reference:
SOP-CN-CONT-VENT Revision: 025 Procedural reference for why distractor D is incorrect.
ATTACHMENT 11 (Page 8 of 13)
Procedural Reference for CGS ILC-22 Post NRC Written Exam Review Distractor A Comments /
Reference:
Alarm Response Procedure Revision: 032 4.602.A6.6-6 ATTACHMENT 11 (Page 9 of 13)
Procedural Reference for CGS ILC-22 Post NRC Written Exam Review Distractor A (CONT.)
Comments /
Reference:
OI-09 Revision: 064 Comments /
Reference:
PPM 1.3.1 Revision: 120 mr 005 ATTACHMENT 11 (Page 10 of 13)
Procedural reference for CGS ILC-22 Post NRC Written Exam Review why D is incorrect ATTACHMENT 11 (Page 11 of 13)
Procedural reference for CGS ILC-22 Post NRC Written Exam Review why D is incorrect Comments /
Reference:
SWP-PRO-01 Revision: 030 ATTACHMENT 11 (Page 12 of 13)
Procedural reference for CGS ILC-22 Post NRC Written Exam Review accepting C as additional correct answer.
Comments /
Reference:
ABN-FPC-LOSS Revision: 014 mr001 ATTACHMENT 11 (Page 13 of 13)
ES-401 CG-2017-02 32 Form ES-401-9
- 1. 2. 3. Psychometric Flaws 4. Job Content Flaws 5. Other 6. 7. 8.
Q# LOK LOD (F/H) (1-5) Stem Cues T/F Cred. Partial Job- Minutia #/ Back- Q= SRO B/M/N U/E/S Explanation Focus Dist. Link units ward K/A Only RO knowledge. Pump trips, standby doesnt start, start standby. Systems knowledge that RCC-V-6 closes on LT two RCC pump breakers closed.
No CFR reference provided. You need to pick the CFR reference that closest fits for every question. 43.6 CGS:
Replaced question Revised 10CFR55 part to 43.6
[NRC - Two correct answers, B and D. ABN-RCC 4.2.8 doesnt say to vent primary containment if Drywell Pressure rises outside of normal band, it just says to vent it if Drywell pressure is rising due to inadequate RCC cooling, which it is. However, U swapping CRD pumps is step 4.2.6 and venting Drywell is step 4.2.8; if the station procedure usage guide (I cant locate) directs that for an ABN the lower-numbered 90 H 2 X X N E step is a higher priority and should be performed first, then the question is acceptable.
S Explicitly state that in the explanation if so, or provide other procedure usage guidance.]
CGS:
ABN numbered steps are performed in order. The following references are attached to the question:
x OI-09, Operations Standards and Expectation, section 7.1 x PPM 1.3.1, Operating Policies, Programs and Practices, step 4.8.4.c x SWP-PRO-01, Procedure and Work Instruction Use and Adherence, step 4.10.3 Revised drywell pressure to .26 psig; lower in band, but still up slow.
[NRC OK] _Rev 1 Page 32 of 37 OBDI 202 - IOLE Process
ES-401 CGS NRC 2017 SRO Written Exam Worksheet Form ES-401-5 Examination Outline Cross-reference: Level RO SRO Rev. 2 Date: 2/9/2017 Tier 2 Group 1 K/A 400000.A2.01 Level of Difficulty: Importance Rating 3.4 Component Cooling Water: Ability to (a) predict the impacts of the following on the CCWS and (b) based on those predictions, use procedures to correct, control, or mitigate the consequences of those abnormal operation: Loss of CCW pump.
Question # 90 CGS is operating in Mode 1.
x RCC-P-1A and RCC-P-1B are running.
RCC-P-1B tripped.
x RCC-P-1B and RCC-P-1C cannot be started.
x Troubleshooting activities are in progress on both pumps.
Current plant conditions:
x RRC-P-1A stator temperature is 190qF, up slow.
x Fuel Pool Cooling (FPC) HX outlet temperature is 100qF, up slow.
x Drywell pressure is 0.26 psig, up slow.
x Field operators report that CRD-P-1A (running CRD pump), lube oil housing is hot to the touch.
What is the next action that should be taken?
The CRS should direct the crew to A. trip RRC-P-1A and enter ABN-RRC, Loss of Reactor Recirculation Flow.
B. start CRD-P-1B and secure CRD-P-1A per SOP-CRD-PUMPS, Control Rod Drive System Pump Operations.
C. transfer the FPC system cooling to Service Water per SOP-FPC-OPS, Fuel Pool Cooling and Cleanup Operations.
D. vent the drywell per SOP-CN-CONT-VENT, Containment Vent, Deinert, Purge, and Ventilating.
Answer: B K/A Match:
This question requires the candidate to demonstrate knowledge of procedures and actions that should be implemented to address abnormal plant parameters following a partial loss of RCC.
Page 1 of 9
ES-401 CGS NRC 2017 SRO Written Exam Worksheet Form ES-401-5 Explanation:
A. Incorrect. Plausible since ABN-RCC, step 4.2.4 directs operators to monitor RRC pump parameters, RRC-P-1A stator temperature has risen approximately 50qF, and if the temperature continues to rise, the pump should be tripped per Alarm Response Procedure 602.A6.6-6.
However, the pump is not required to be tripped until stator temperature reaches 266qF, and the CRD pump is a more immediate issue.
B. Correct. With reduced RCC flow, ABN-RCC, step 4.2.6 directs CRD pump cooling be transferred to the Condensate Transfer header OR CRD pumps be periodically shifted if CRD pump lube oil housing temperature is hot to the touch.
C. Incorrect. Plausible since a FP temperature has risen approximately 10qF. However, ABN-RCC, step 4.2.11 directs transferring FPC cooling to SW is FP temperature cannot be maintained 125qF, and the CRD pump is a more immediate issue.
D. Incorrect. Plausible since ABN-RCC, step 4.2.8 directs the drywell to be vented if pressure is rising due to inadequate RCC cooling. However, ABN subsequent operator actions should be performed in order and addressing the CRD pumps is in step 4.2.6. Additionally, drywell pressure is still within the normal band of 0.25 psig to 0.75 psig (see SOP-CN-CONT-VENT, 4.16), with pressure slowly rising. The CRD pump is a more immediate concern.
Technical Reference(s)
ABN-RCC, Loss of RCC Alarm Response Procedure 4.602.A6.6-6 SOP-CN-CONT-VENT, Containment Vent, Deinert, Purge, and Attached w/ Revision # See Ventilating Comments / Reference PPM 1.3.1, Operating Policies, Programs and Practices OI-09, Operations Standards and Expectation SWP-PRO-01, Procedure and Work Instruction Use and Adherence Proposed references to be provided during examination: None Learning Objective: LO5706 - Explain the interlocks associated with the following components or system conditions, including setpoints: a. RCC pump auto start, b. RCC Pump trips.
Question Source: Bank #
Modified Bank # (Note changes or attach parent)
New X Question History: Last NRC Exam N/A Question Cognitive Level: Memory or Fundamental Knowledge Comprehension or Analysis X 10 CFR Part 55 Content: 55.41 55.43 43.6 Page 3 of 9
CGS 2017-02 Post-Exam Comments: NRC Resolution A panel of three Region IV examiners was convened on March 20, 2017 to resolve two post-exam comments submitted by Columbia Generating Station. All three examiners were independent of the exam team. The following recommendation are submitted for branch chief review.
Question RO-9 The question presents a plausible abnormal operating condition and requires the applicants to apply knowledge of the SDC system and its associated abnormal operating procedures to determine the best course of action for the crew to take. Because it is a plausible condition, it follows that there exists some sequence of actions that would be required to respond to the event and ultimately restore SDC. In this particular case, it appears that a return to Mode 3 would be unavoidable. Temperature is 195 degrees and going up, and SDC cannot be immediately restored via ABN-RHR-SDC-LOSS. Distractors A and D are clearly incorrect due to the unavailability of RHR-V-8, Shutdown Cooling Suction Isolation Valve, and the inability of RHR-P-2A to take suction from the Spent Fuel Pool. The originally-proposed answer, B, is incorrect under the given plant conditions, due to the imminent entry into Mode 3 and the time-consuming need to perform vessel disassembly and equalization between the Spent Fuel Pool and Reactor Cavity levels. The panel determined that distractor C, Initiate shutdown cooling through main steam line drain valves per ABN-ADHR, Alternate Decay Heat Removal, could plausibly be performed once the reactor entered Mode 3, however the entry conditions for this procedure require that an Alternate Shutdown Cooling method already be in use, which it is not.
Additionally, the question stem specifically asks about restoring Shutdown Cooling, not Decay Heat Removal; the method described by distractor C is not considered a method of Shutdown Cooling, semantically.
ABN-RHR-SDC-ALT, Residual Heat Removal Alternate Shutdown Cooling, section 4.0 NOTE states, in part, The alternate methods are listed in order of preference, provided no core damage has occurred. There are no indications of core damage, and the first preferred method is found in step 4.2, If normal Shutdown Cooling is tripped and cannot be restored, THEN PERFORM Attachment 7.1. In section 7.1, Alternate Shutdown Cooling (Mode 3, 4, or 5), the first preferred method is section 7.1.1, Discharge Steam to the Main Condenser. This method would be used until Normal Shutdown Cooling was restored or RPV pressure was reduced to 0 psig; it cannot maintain RPV temperature less than 200F, therefore if entry into Mode 4 were required, step 7.1.3 would need to be used: Discharge Water through the SRV to Suppression Pool. Neither of these methods are given as one of the four answer choices of Question 9.
Therefore, the panel unanimously determined that RO Question 9 has no correct answer choice, and that the question should therefore be deleted from the exam. The panel also determined that this question was written at the SRO level. While the K/A does ask for knowledge of abnormal operating procedures, this question goes beyond procedure knowledge and presents a complicated abnormal operating condition that requires the applicant to analyze the situation and select the correct procedure sub-path in the ABN network. Per NUREG 1021,
ES-403.D.1.b, a question at the wrong license level is most likely to result in post-examination changes agreeable to the NRC.
Question SRO-90 The question presents a series of adverse conditions associated with the loss of cooling to multiple systems and then asks the applicant to determine what action should be taken next.
It is clear that the actions associated with all four answer choices would likely need to eventually be taken, therefore the applicant must determine which condition is a) required to be addressed first by procedure, and b) presents the most immediate operating concern. The licensee contends in their post-examination comments that both ABN-FPC-LOSS and ABN-RCC can be implemented concurrently, and that ABN-FPC-LOSS directs restoration of fuel pool cooling using the SW system, If RCC cannot be restored. Therefore, the licensee contends that this action should be accepted as a second correct answer.
While it is true that both procedures can be entered concurrently, the CRS still needs to prioritize the next action that should be taken. While ABN-FPC-LOSS provides a viable procedure path for addressing a loss of cooling to the fuel pool prior to temperature exceeding 125 degrees, this is a secondary effect of the primary malfunction, a loss of RCC, which is addressed by ABN-RCC. ABN-RCC determines the priority of actions that should be taken for this event. ABN-RCC addresses the fuel pool cooling concern after the CRD pump cooling concern and establishes a critical parameter value of 125 degrees for when action must be taken to transfer fuel pool cooling to the SW system (a value that is not yet met). As such, ABN-RCC effectively designates the swapping of CRD pumps as the next action to be taken in this particular scenario. It is true that, if no other concerns were ongoing, ABN-FPC-LOSS could be used to restore fuel pool cooling prior to exceeding 125 degrees. However, in this case, multiple systems are threatened by the loss of a common cooling system, and that cooling systems abnormal operating procedure sets the priority of response actions to this scenario.
Fuel pool temperature is well below the critical value of 125 degrees F, and is increasing only slowly, whereas CRD Pump 1A is already demonstrating signs of impending degradation.
In line with that point, on the originally-submitted question worksheet the licensee explicitly stated that the CRD pump is a more immediate issue in its justification for why transferring Fuel Pool Cooling to Service Water was incorrect.
NUREG 1021, ES-403.D.1.c states, If it is determined that there are two correct answers, both answers will be accepted as correct. If, however, both answers contain conflicting information, the question will likely be deleted. Considering that the CRS cannot physically direct both of the actions associated with answer choices B and C simultaneously, and that the question asks for the next action, then two correct answers cannot be accepted. Therefore, the NRC must determine if the question should be deleted or left unchanged. The question stem presents a plausible scenario and lacks any ambiguity as to the choice the applicant is expected to make.
Delaying actions to address CRD pump cooling, in order to address fuel pool cooling when it has not yet reached a critical value and is far from doing so, would be the wrong course of action both procedurally and from a command and control perspective. As an additional
reference point, given the same conditions on the operating test, an applicant who chose not to address a degrading CRD pump in favor of a slowly rising fuel pool temperature could be downgraded in rating factor 1(a), which requires that SRO applicants recognize and attend to off-normal trends and status in order of their importance and severity.
Because of the above, the panel unanimously determined that no change to SRO Question #90 was warranted.
[Branch Chief Approved, 3/21/17]