ML18033A716

Forwards Comments Re Operator Licensing Exams Administered on 881212,per NUREG-1021

ML18033A716
Person / Time
Site:	Browns Ferry
Issue date:	12/19/1988
From:	Mason C TENNESSEE VALLEY AUTHORITY
To:	Brockman K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18033A714	List: ML18033A715 ML18033A716
References
RTR-NUREG-1021 NUDOCS 8904260106
Download: ML18033A716 (43)

Text

TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT P. 0.

BOX 2000 DECATUR, ALABAMA 35609-2000 ENCLOSURE 3

i r.I Mr. Ken Brockman, Chief Operator Licensing Section U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, NW Atlanta, Georgia 30323 I

~ ~

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~ >:>i uah.

Dear Mr. Brockman:

In accordance with the provisions of NUREG-1021, "Operator Licensing Examiner Standards,"

Standard ES-201, enclosed are comments by the Browns Ferry Operator Training staff concerning the written examinations administered at Browns Ferry Nuclear Plant, December 12, 1988.

The enclosed comments are offered with the intent of providing assistance to the NRC examiners in establishing the appropriateness of the examination questions.

Also, the comments serve to clarify and expand the answers on the NRC answer key as supported by TVA reference material.

These comments are respectfully submitted, and it is hoped the enclosed comments and proposed resolutions afford the examinees every opportunity to successfully pass the examination based upon'he kndwledge and skills required to safely operate the facility.

Very truly yours, TENNESSEE VALLEY AUTHORITY

~XV C. C. Mason Acting Site Director Enclosures 89py~~ p Qc< psppp

~DR gD P$ 89P~P+

~NV An Equal Opportunity Ernplover

4 4

GENERAL COMMENT

S The terms, "Power Defect, Reactivity Defect, and Margin of Shutdown," are not used in our training material and 'caused some confusion during the examination.

Please modify future questions to delete the use of these terms and use BFN specific terms.

Point values between the same question on the RO and SRO were not consistent through out.

Examples:

3.01(2.0) 3.09(2.0) 2.04(1.5) 2.06(1.5) 6.01(1.0) 6.05(1.5) required more responses 6.09(1.0) 6.10(1.0) required more responses 3 ~

The length of the examination for the allotted time caused' great deal of problems for the SRO's.

Everyone put down a answer for each question; however, all said that they just wrote something down, without having time to analyze on several questions.

The SRO examination contained 97 questions for a point total of 114.0 and the RO examination contained 62 questions for a point total of 108.75.

This is a total of 35 additional questions for the SRO's to address within the same time period.

In addition, Item 2 above shows that the same required responses received less credit on some questions.

We feel that the SRO examination was far too long and that this affected the ability of the people to demonstrate their knowledge.

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f;5

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'I )

[)44 p3 4.

We consider the pre-examination review a very positive effort by NRC to improve the examination process.

We hope.that this will continue since everyone profits from it.

~ ~

5

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4 1

jet l

UES 0

2 Change answer Key to reflect:

D/G running (Mode switch in single unit), as an acceptable answer for full credit.

RESO ZO JUS CA 0

The status'of the Diesel Generator prior to and subsequent to the LOCA/LOP signal is the Diesel Generator running and ready to ~aote t load.

Pith the shutdown board status, the Diesel Generator would accept load in parallel or single unit.

Attachments:

OPL171.038P pg. 18, 19

'4 4

4 4

4

'DA fdA

Page 18 of 29 OPL171.038 03/12/86 Rev.

0 Lesson Outline I

Instructor

',bootes (b)

Local breaker control provided.

(c)

Emergency control of a breaker blocks any automatic transfer.

b.

Shutdown board controls (1)

Similar to shutdown bus controls (2)

In addition, synchronizing equipment is available at the shutdown boards and in control room for all supplies.

NOTE:

Synchronizing switch must be on in order to have manual high speed transfer.

(3)

Emergency control blocks auto-matic transfers.

(4)

Each motor feeder breaker on the

'4160-V shutdown boards has an ECTS, allowing control from the S/D board.

4.

Accident Operation a.

Accident signal received (1)

Signals diesel generators to start.

(2)

Opens diesel output breakers if shut.

b. If normal voltage is available, load will sequence on as follows:

Obj. I

f.esson Outline Page 19 of 29 OPL171.038 03/12/86 Rev.

0 Instructor Notes Time After Accident

~Si nal S/D Board S/D Board S/D Board S/D Board A

C B

D 0 sec.

7 sec

~

14 sec.

2$ sec.

28 sec.

RHR, CS,

RHR, CS RHRSW':

RHRSW-'"

RHR, CS

RHR, CS RHRSW'"

RHRSW"

-RHRSW for EECW

c. If normal power is not available (1)

After 5 second time delay, all 4160-V shutdown board loads, except 4160/480-V transformer breakers, are automatically tripped.

Obj. I (3)

Diesel generator output breaker closes when diesel is at speed.

Loads sequence as indicated below:

Time After Diesel Pwr S/D Board S/D Board S/D Board S/D Board Available A

B C

D 0 sec.

7 sec.

14 sec.

CS RHRSW CS CS CS RHRSW RHRSW RHRSW d.

Certain 480V loads are shed whenever an accident signal is received in conjunction with loss of normal AC power on either unit (1 or 2) and diesel generator has tied to the board.

(1)

The following will automatically restart after 40 seconds time delay:

UES IO 2

CO S'xpand ansver key to accept seal damage as an operational problem encountered vith air in overpiston and underpiston lines.

ESOL 0

JUS lF C

ON The operations personnel with BFH experience have been exposed to control rod drive maintenance problems, specifically graphitar seal maintenance, due to improper venting of drive mechanisims.

~ttached BF 03-85 Rev.

0000 page 30

G. (Continued)

• Page 30 BF OI-85 REv oooo c.

Ensure that the scram accumulator has been properly orechar>>d e" sectica G.2.

d.

Open or chec'ven

=he scram pilot a r valve and verify that he sc"

- va)ves are los~ d.

n cc~<<'ected o 35 590

"" = ";.uiator.

When a

s asia

-z -w."=',=:;: s from '5-590 c ose 85-588 and

<< ~

Pl

~

'.' \\ <<

DO NO ALUM ~i-ACC';~u

'0'vR TO BE.=rKSSURIZ& DUE TO LEAKAGE PAST ~5-5d8.. ~cIOD:"~~ I: Oa4ITGR ACCUHULA GR PRESSURE AND

~CK OPEN TH'" l SauT 85 590 A PP"-SSUR"-

&~CREASE IS NORM.

r.A~CR&

r'c'c

. %.: cd~ ',~~~<<~ w~~&acww Open scram c'scharge ser 85-617.

g.

Op " vithdrav r.ser 85-6l h.

Ocen or check open inse t r.'s r 85-612.

CAL-<<OM

~wwa~Art.r<'~M~~w=~ wwM~a~>pA COOLING W.-'~ IS BEL'iG. =STOR=

0 A HOT DRIV:-, CAR ULLY CRACK OPEN.::". COQLIN" WA 5 VZ'V:-,85-596, AND INI IAT COOLING PLOW. VWY SLOWLY TO MIN:SIZE

.ALE LH"-K~AL RANSI:-VT ON THE CRD.

HONITGR CRD

" P~~v.

"- A PAÃ" L 9-47.

Op n or chec':: "pe" co"

= Water rise 85-596.

j.

Ope" Must water "is "85-600.

k.

Open drive water r'sor 85-59".

Refer to section G.~ for vent'."~~ reauirments-and to return the accumulator to ser;".'c w.

D

<e

.nsurr c'e": or '.

. rco=r vent'n=

'.s he b'loess cause for NO

""79"

UES 0

atb Expand the answer key to accept for full credit any two of the following responses:

Manual Fast Start Signal Pre Accident Fast Start Signal (PASA)

Accident Fast Start Signal (CASA)

Undervoltage Fast Start Signal Loss of Control Power (Logic Breaker Off)

ESOL ON JUS ICA ION

~ ~ ~

A' The question elicits (2) conditions that vill automatically place the D/G in 'Single Unit Mode'.

The attached material (pg.

10 6 14, OPL171.038) indicates the automatic fast start signals.

During the exam preview, the ansver key expansion to accept specific 'Fast Start'ignals was discussed and accepted.

Additionally clarification to one candidate, indicated the fast start signals were to be considered separate and independent conditions.

Attached:

pages 10, 14, 14A of OPL171.038

Page 10 of 29 OPL171.038 03/12/86 Rev.

0 Lesson Outline Instructor Notes b.

Indicators for voltage, current, MW, HVAR are provided for each diesel.

c.

Voltage and current loads on each bus, board and breaker are provided.

2.

All control room equipment and controls are duplicated for individual diesels, buses or boards at the respective 4160-V shutdown boards.

3.

Central Information Panel a.

Located in diesel generator building.

b.

Presents diesel loading information.

c.

Communication center to monitor load, dispatch supervision when diesels are on backup control.

4.

Interlocks Diesel generator automatic start signals.

The diesel generators will automatical3y.start on any of the following signals:

(1)

High drywell pressure (2.45 psig, from core spray logic).

(2)

Low-low-low reactor water level

(-114.5", from core spray logic).

(3)

Loss of voltage to 4160-V shutdown board.

(Figure 7)

TP-7 (4)

Degraded voltage on 4160-V shutdown board.

(Figure 7)

TP-7 NOTE:

On (1) and (2), all diesel genera-tors will start.

On (3) and (4),

.only the diesel associated with the board(s) losing voltage will start.

b.

Diesel output breaker will close only if:

Obj.

E 4, ~ *,', ~

Page 14 of 29 OPL171.038 03/12/86 Rev.

0 Lesson Outline In'structor Notes (1)

With the D/G "emergency control transfer switch" in normal, auto-matic start and control room manual starts are provided by the normal bus.

(2)

With the "emergency control transfer switch" in emergency, the diesel can be manually started and controlled from its 4160-V shutdown board; automatic start capability is available.,

Obj.

G b.

Automatic start signals listed in D.4.a.

of this lesson plan.

c.

Remote starting from the control room Obj.

G (1)

All diesels (units 1 6 2) can be simultaneously started from units 1 or 2 panel 9-8 with the diesel start switch.

(2)

Panels 9-23-7 and 8 are provided with individual diesel start,

• stop< synchronizing equipment and emergency stop features.

d.

Remote starting available from 4160-V shutdown boards.

Obj.

G e.

Each of these stations has the following control switches.

(1)

Start-stop switch (a)

Start initiates fast start of diesel generator.

(b)

Stop-neutral position, initiates normal stop sequence (see below) if placed in stop (neutral) and pulled out.

(c)

Reset position to reset auto-matic start lockout.

(2)

Operational mode switch ps~

+ouscu~g insa~w pa~~

l4A a d ling) py.id'bj.

H

l4h Page SSA of 29 OPL171. 038 11/11/87 (2)

Operational Node Switch Sets the mode of operation of the speed and voltage regulators.

<a)

SINGLE UNIT Used when the generator is the only supply to the associated shutdown board.

Speed (frequency) droop

<decrease) from zero load KILOWATTS to full rated load KILOWATTS is less than one percent

<Figure 8A)-

Voltage droop from zero load OUTGOING KILOVARS to full rated load OUTGOING KILOVARS is less than one percent (Figure SB).

Any fast start signal or DC control power loss automatically places the mode of operation to SINGLE UNIT mode, without lighting the indicator above the SINGLE UNIT position.

Regardless of'tart signal type, pulling up the NODE SELECT handle and placing it in the desired position will change the mode of operation and light up the associated indicator above the NODE SELECT switch.

(b)

(c)

UNITS IN PARALLEL Used when two generators are to be-tied altogether.

Speed and voltage droop are identical to SINGLE UNIT mode.

Breaker positions are sensed to determine if the unit is operating in parallel with any of the other 7 diesel generators.

If so, feedback occurs between speed regulators

<and voltage regulators) of the paralleled generators so that stable load sharing operation results.

PARALLEL WITH SYSTEN Used when generator is to be paralled with offsite power.

To ensure stable load sharing with grid speed droop from zero load KILOWATTS to full rated load KILOWATTS is approximately five percent

<Figure SC).

Voltage droop from zero load OUTGOING KILOVARS to full rated load OUTGOING KILOVARS is approximately five percent

<Figure SD).

UES ON 4 PART CO cce t e t e a

o 2

am Wednesda as a fu cor ect res onse.

/

RESOL 0

JUST CA ION'n accordance with BFNP SDSP 19.3, pg. 2, a person may work no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in ~an 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

The person has worked a total of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> beginning at 6

am on Monday and therefore this person cannot return to work any earlier than 6

am Wednesday to prevent exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

2 ~

Correct answer is 6 am Wednesday morning.

I If the time clock is assumed to begin at midnight of each day, then the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time frame would be over at midnight on Tuesday and the NRC answer would be correct.

Some candidates used midnight as a reference start-time due to the question reference to "Between 12:00 am and ll:59 pm."

5 Page 2

BF-19.23 REV 0000 T'ennessee Valley Authority Brogans Ferry Nuclear Plant Standard P.actice NUCLEAR STAFF WORK HOURS FOR PERSONNEL P~ORNING S~c.

-RELATED FUNCTIONS (Continued) 5.0 Instruction 5.1 Personnel involved vith operation, maintenance or testing of

...controls, equipment, etc., that could affect the reactivity or core cooling sy'tem of the power plant are subject to the following restrictions on overtime:

r

~

Work not more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight (not including shift turnover time).

I>>

Eave a break of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or more (iacluding shift <urnove time) between all scheduled aon-consecutive 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> work periodsr Work ao more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> ia any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period (all excluding shift turnover).

~

5.2 Personnel engaged in core altera ions are governed by the provisiors of Reference 3.3 regarding ~orkiag hours.

5 5.3 Excepti'ons'may be authorized by the plant manager or plant superiatendeat.

It shall be documented in an appropriate log as to:

Who is i'nvolved Who authorizes the waiver The unusual circumstances requiriag the waiver.

5.4 A reactor operator required to work more than eight hours continuous at the control board, as the persoa's primary job, shall have a

break each four hours.

5.5 When operating personnel are required and authorised to work in access of 12 continuous hours, every reasonable effort vill be made to assign them to tasks that do rot affect core reactivity on operating units.

J ~.

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<<5'~ << ',gy I', '+

h,t<<J<<"JI r',~ r J>>,J>>.J'55<',, >> 'r g<<w tr, '<<" r <<$,5<<rr>>J, 5 /, r '~,

>>,'+ '>>5<<,>,," 55 5 JJ rt,'

wt

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UES 0

TV CO Change answer key to state:

Drywell Spray is secured when pressure drops below 2.4 psig to help preclude going negative in pressure.

A RESO ON JUS FICA 0

See Pages 84 an 85 (Attached) of EOI Training Supplement, Appendix B.

Page 84 7/11/86 hppendix B

Rev.

1 3'3 IF Drywell sprays have been initiated aad drywell pcessuce drops below 2.4 ysig, (17 ysia),

Thea termiaate-dc'ywell sprays.

BPIL 3-2.BEFORE suppression pool eater level reaches lp rt B.BY O!KY lp adequate core coolint is

assucsd, terminate injection into the Rx from souc'ces extecnal to the pcimacy containmeat, except from SLC aad CRD.

1.

Shen suppression pool watsc level reaches 18 ft. BUT OMLT IF suppression chamber temperature (TR-64-52 Black pen) and, drywell prsssuc's ars within the Drywell Spray dcywell Initiation Limits, Then:

vai (1) Shutdown recirculation pumps.

(2) Shutdown drywell Cooling faas (3) Initiate drywell sprays (using oaly those RHR pumps not required to assure adequate core cooling by continuous operation in the LPCI mode).

Page 85 7/11/86 hppendiz B

Rev.

1 Discussion:

The suppression chamber-to-dryvell vacuum breakers are located inside the torus and cannot be relied upon to adequately control suppression chamber t

d 11 differential pressure if eater is present on either side of'hese devices.

Spraying the dr~e11 results in condensation of steam an 0

d depressurixation of the dryvell, under which conditions the vacuum breakers will open and permit noncondensibles to return to the dryvell.

Thus before these vacuum breakers become inoperable, the drywell is sprayed so that they can perform their intended function.

The previously identified condition and restrictions regarding initiation and operation of dryvell sprays remain applicable.

Orywell spray is secure shen pressure drops below 2.45 psig to help preclude going negative in pressure.

CO Delete T.S. 3.9.A.l.a as a required answer for full credit.

A RESO UTION JUSTZ C T ON The plant status as given does not imply that we are getting ready to start up since we are maintaining temperature at >100'F.

Tech Spec.

3.9A.lA is required when we are starting up (make critical) from the cold condition.

For the conditions given, Tech Spec 3.9C apply and are satisfied.

(T.S. 3.9.A.l.a and T.S.

3.9C attached).

AU8 19!983 LIMITIHG COHDITIOHS FOR OPERATIOH 3.9 SURVEILLAHCE REQUIRENEHTS 4,9 Applies to all the auxiliary electrical pover system.

hyylies to the periodic testiag requirements of the auxiliary electrical system.

To assure aa adequate supply of electrical pover for operation of those systems required for safety.

Verify the operability of the auxiliary electrical system.

A.

A.

8 S

t~

1.

The reactor shall not be started uy (made critical) from -the cold coadition ualess the folloving are satisfied:

a.

Diesel gcaerators A,

B, C~ aad D OPERABLE.

b.

Requirements 3.9.A.3 through 3.9.A.6 are met ~

c.

At least tvo of the folloving offsite pover sources are available:

{1) The 500-kV system is available to the units 1 and 2 shut-dovn boards through the uait 1 station-service transformer TUSS 1B vith no credit taken for the tvo 500-kV Trinity lines. If the unit 2 statiou-serv'ice

~'transformer is the second source, a minimum of tvo 500-kV 1ines must be available.

l.

Diesel Generators Each diesel generator shall be manually started and loaded to demonst.at operational readiness accordance vith the frequency specifi'cd in Table 4.9.A on a staggered

.test basis.

The test, sha continue for at least a one hour period at 75" of rat load or greater and he oycratioa of the diese fuel oil transfer pumps shall be demonstrated.

Also, the diesel generator starting air compressor shall be checked for operation and its abil: ty to recharge air receivers.

The diesel generator fas" starts (10 seconds) from standby conditions shal'erformed once per 184 days in these surveillance tests.

All other engine starts for the purpose oi this test, may be preceede by an engine idle start.

BFH Uait 2 3.9/4.9-1 AM+OMITzO. >4 9

.9/4.9 A

(

LDlITIMQ CONDITIONS FOR OPERATION SURVEILUWCE RHtIIIUIRBHESTS 3.9.C.

eratlon in Cold Shutdown Vhenever the reactor is in Cold Shutdown condition with irradiated fuel in the reactor.

the availability of electric power shall be as specified ln Section 3.9.A except as specified herein.

l.

At least two units 1 and 2

diesel generators and th'eir associated 4-kV shutdown boards shall be OPERABLE.

2.

An additional source of power energized and capable of supplying power to'he units 1 and 2

shutdown boards consisting of at least one of the following:

a.

One of the offslte, power sources specified in 3.9.A.l.c.

b.

A third OPERABLE diesel generator.

3.

At least one 480-V shutdown board for each unit must be OPERABLE.

4.

One 480-V RN7V board mg set is required for each ~

RNaV board (2D or 2E) required to support operation of the RHR systea 1n accordance with 3.5.8.9.

BPN Unit 2 3.9/4.9-15

UESTION 8.20 TVA COMMENT:

Change answer key to accept "A" for full credit.

TVA RESOLUTION/JUSTIFICATION Since the question stated that there was "No estimated repair time,"

the decision to shutdown due to the inop pump cannot be made yet.

In

practice, we WILL get a estimated repair time and make our decision based on that.

This would not violate the "intent" of Tech Spec since we are allowed to operate for 7 days with this equipment out-of-service (Ref; Tech Spec 3.5.A).

Therefore, based on the fact that an estimated repair time is yet to be determined we conclude the answer "A" is correct for. this question.

06120 J

l C.'

~

UESTION 22 Expand answer key to accept the following as correct answers:

Protective Action Recommendation Review and approval of personnel radiation exposures which exceed dose limits RESOL 0

JUSTIF C

0 ONP-REP, page 14 (attached) provides justification for our comments.

EPIP-1 classification logic directs the SED to make the protective action recommendations:to state and local authorities when a general emergency is classified and declared.

For purposes of clarifying event classification, the reference to ONP-REP, appendix A has been added to EPIP-1.

- This reference and increased emphasis during classroom and simulator training has been mandated by plant and corporate management.

Following EPIP-1 classification logic, when a general emergency is classified prior to CECC being staffed, attachment'-1 must be completed.

Attachment 1 directs the use of attachment 4 to make the mandated protective action recommendations to state and local civil authorities.

Classroom and simulator training emphasis is placed upon this responsibility and is considered an SED action.

A~ttac ed ONP-REP-pg.

14, A-24, A-25 BFH-EPIP-1-pg.

5 BFN-EPIP-5, pg. 1, 4, 7

OPL171.075-pg.

1, 6, 9

ONP-REP Page 14 Rev.

0 the NRC; makes final decision on personnel entrance to radiologically hazardous areas when the RadCon Manager recommends against the entry; and initiating long-term 24-hour per day accident mitigation operations.

The SED makes recommendations for protective actions (if necessary) to the State and local agencies through the ODS prior to the CECC being staffed (this can be delegated only to the CECC Director).

The SED is also responsible for determining the emergency classification as well as the review and approval of personnel radiation exposures which exceed dose limits (these responsibilities cannot be delegated).

~

0 erations Hang er The Operations Manager is responsible for onsite operational

'activities; keeps the SED informed on plant status and operational problems; performs damage assessment as necessary; and recommends solutions and mitigating actions for operational problems.

Technical Assessment Mana er The Technical Assessment Hanager is responsible for providing information, evaluations, and projections to the SED; coordinating assessment activities with the CECC; keeping the assessment team informed of plant status; assessing effluents; directing the technical assessment team; and projecting future plant status based on'resent conditions.

Maintenance Hang er The Maintenance Hanager is responsible for directing the repairs and corrective actions; performing damage assessment; coordinating repair activities with the CECC; coordinating maintenance teams and ensuring proper briefings and accompaniment by RadCon.

CECC Communicator The CECC Communicator performs principal communications with the CECC.

Radiolo ical Control (RadCon)

Kana er The RadCon Hanager is responsible for assessing inplant and onsite radiological conditions; directing the onsi te RadCon activities; coordinating additional RadCon support with the CECC; recommending protective actions for onsite personnel to the SED; maintaining the offsite radiological conditions status information; coordinating assessment of radiological conditions with the CECC; maintaining the inplant radiological status boards; assisting the Maintenance Manager in briefIng maintenance teams; assigning appropriate RadCon support to maintenance teams; and maki ng final recommendation to the SED for personnel entry to radiologically hazardous environments.

0682e/COC4

ONP-REP Appendix A Page A-24 Revision 0

(-

A.2 SITE EMERGENCY ORGANIZATION BFN maintains an organization capable of responding to a radiological emergency.

The TSC,

OSC, and Control Room staffing for response to emergencies is shown in figure A-l.

The minimum onshift emergency response staffing is found in figure A-2.

A.2.1 Site Director The Site Director serves as a corporate interface for the

SED, relieving him from duties which could distract from the SED's primary purpose of plant operations and accident mitigation activities.

The Site Director shall provide assistance in the following areas:

1.

Provides TVA policy direction to the Site Emergency Director.

2.

Directs the site resources to support the Site Emergency Director in the accident mitigation activities.

3.

Provides direct interface on overall site response activities with:

a.'

NRC,'EMA, or'other'Federal organiza~'on's responding-to the site.

b.

CECC Directo'r. " "

c.

Onsite media.

4.

At his discretion, may provide interface at the appropriate offsite location on the overall site response activities with:

a.

State and local agencies.

b.

NRC region/corporate.

c.

Joint Information Center.

5.

Provides support to other emergency operation centers as neces'sary.

'As applicable, designates an alternate to provide direction and/or support for the overall site response and support to the Site Emergency Director.

A.2.'ite Emer enc Director 1.

Directs onsite emergency accident mitigation activities.

2.

Consults with CECC Director and Site Director on significant events and their related impacts.

ONP-REP - APPENDIX A

ONP-REP Appendix A

Page A-25 Revisio 0

3.

Initiates onsite protective actions.

4.

Coordinates accident mitigation actions with NRC.

~

~

Tnitiates long-term 24-hour accident mitigation operations.

b.

Prior to th>:

CECC bein

staffed, makes recommendations for protect

~ ve actions (if necessary) to State and local agencies through the Operations Duty Specialist.

This responsibility cannot be delegated except to the CECC Director after the CECC is operational.

7.

Responsible for determining the emergency classification.

This responsibility

cannot, be delegated.

8.

Hakes final decision on personnel entrance to radiologically hazardous areas when RadCon recommends against the entry.

A.2.3 0 erations Su erintendent 1.

Directs operational activities.

2.

Informs Site Emergency Director of plant status and operational problems.

3.

Performs damage assessment as necessary.

4.

Recommends solutions and mitigating action for operational problems.

I A.2.4 Technical Su ort, Services Mana er 1.

Directs onsite effluent assessment.

2.

Directs activities of technical assessment team..

hh 3,

Projects future plant status based on present plant conditions.

4.

Keeps assessment team informed of plant status.

5.

Provides information, evaluations, and projections to Site Emergency Director.

6.

Coordinates assessment

~ctivit.ies with the CECC >Lant assessment team.

A.2.5 Maintenance Mana er h>>>

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1.

Directs repairs and corrective actions.

2.

Performs damage assessment.

ONP-REP - APPENDIX A

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NOTE:

The ONP-REP, Appendix A, contains information or detail action levels:

Notification of Unusual Event - A.l.l Alert

- A.1.2 Site Area Emergency

- A.l.3 General Emergency A.l.4 Page 5

BFN-EPIP-1 Qgp 000 3 ATTACHHENT 1 (Page 3 of 19) related to emergency classifications or emergency ECCS INITIATIONHITH DISCHARGE TO VESSEL (NPCI; RCIC, LPCI, CSS, OR ADS)

UNLESS PART OF A PLANNED SEQUENCE DURING TESTING OR HAINTENANCE.

NOTIFICATION OF UNUSUAL EVENT.

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4% 1 EQUI PHENT PRI GMLANT BREAK (LOCA)

HAIN STEAH LINE BREAK OUTSIDE CONTAINHENT HITHOUT ISOLATION REACTOR HATER LEVEL CANNOT BE

'AINTAINED

>-150 INCHES ECCS FAILURE (PUHPS NOT RUNNING OR UNABLE TO HAINTAIN REACTOR HATER LEVEL LEADING TO FUEL HELT)

SITE AREA EHERGENCY.

SITE AREA EHERGENCY.

GENERAL EHERGENCY.

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Page 1

gp 0 0 Og BFN-EP IP-5 GENERAL ENERGENCY 1.0 PURPOSE To provide for timely notification of appropriate indivi.duals and organizations when the Shift Operations Supervisor/Site Emergency Director (SOS/SED) has determined by EPIP-1 that an incident has occurred which is classified as a

GENERAL ENERGENCY.

1.2 To provide for periodic reanalysis of the current situation by the (SOS/SED) to determine whether the General Emergency should be cancelled, downgraded, or continued.

2.0

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This procedure applies to emergency events that are classified as a General Emergency by EPIP-1, Emergency Plan Classi,fication Logic.

3.0 INSTRUCTIONS NOTE: If al'1 Emergency Centers Are Staffed, Steps 3.1 and 3.2 do noa app1y.

3;I Notifi'cations of The 'Operations Duty Specialist (ODS)

NOTE:

The ODS shall be notified within 5 minutes after the event is declared.

DATE INITIATED Initials:Time 3.1.1 Complete Attachment=1 (Notification Information).

3.1.2 Notify the ODS and provide the information from Attachment l.

o9-1<<751-0700 o9 1 751 2495 3.1.3 Received confirmation &11 from the ODS (to verify notification of the State of Alabama).

3.2 Noti.fication of Site Personnel Direct the SOS '

Clerk to make notifications from Attachment 2 (SOS's Clerk Notification).

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BFN-EPIP-5 ATTACHMENT 1 NOTIFICATION INFORMATION (Page 1 of 1) ae Name b.

Browns Ferry Nuclear Plant c.

GENERAL ENERGENCY-d.

Time Event Declared'.

Briefly Describe Event:

f.

Plant Condition:

g.

The reactor (did/did not) shut h.

The Emergency Situation:

Stable Deteriorating dawn at CRT/CDT oa Date (l)

Does not involve a radiation release from the plant.

(2) lnvalves a radiation release from the plant.

(3)

Radiation release infosoation i.s not known.

i.

The Radi,ation Release is:

O.)

(3)

Ground level - Airborne Elevated Vent - Airborne Stack - Airborne Waterborne Other j.

The Radiation Release Rate Is:

(a)

(3)

(e)

Nicrocuries/Second None Unknown k.

Mind Direction Is From:

1.

Mind Speed Is:

m.

Recommended Protective Action:

'(Degrees)

(mph)

NOTE: Ini.tial recoamendation for protective action is to be determined from Logi.c Diagram on Attachment 4.

Recon)endation is:

Recolmendation No.

1 Recoam)endation No.

2 Recomaendation No.

3 Recommendation No.

4 Recoamendation No.

5 Recoamendation No.

6 a.

Raarsenoy, Aatiaas Underway Cnsite Are:

(e.dt.t, plant evaonation) o.

Onsite Support Needed From Offsite Organizations's:

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Page 1 of 22 OPL171.075 Revision 1

I.

PROGRAH:

BFN Licensed Operator Training II.

SUBJECT:

Hot License Training III.

TITLE:

Office of Nuclear Power (ONP) Radiological Emergency Plan (REP)

IV.

V.

LENGTH OF LESSON:

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> TRAINING OBJECTIVES A.

Terminal Ob)ective Upon completion of this lesson, the operator will demonstrate satisfactory knowledge of-the Radiologica'1 Emergency Plan by scoring at least 80% on a written exam.

B.

Enabling Ob]ectives State the purpose of the Radiological Emergency Plan.

2.

3.

4 ~

Define the four event classes as defined in this lesson plan.

Describe the onsite emergency response organization, as presented in this lesson plan.

Describe the offsite emergency response organization, as presented in this lesson plan.

State the responsibilities of the Site Emergency Director which may not be delegated to another person.

Describe the process by which authority for emergency direction and control is transferred in an emergency, as discussed in this lesson plan.

7.

Explain the sequence of events which must occur to activate the emergency

response, as discussed in this lesson plan.

8.

9.

Describe the procedures for conducting assembly and evacuation, as stated in this lesson plan.

Explain the respective roles of the Site Emergency Director and the CECC staff in making protective action recommendations, as discussed in this lesson plan.

O449W

I Page 6 of 22 OPL171.075 Revision 1

r;: LESSON OUTLINE INSTRUCTOR NOTES 2.

Offsite Emergency Organization a ~

The offsite organization is designated as the Central Emergency Control Center (CECC). staff.

The CECC staff is composed of a CECC Director, a

supporting group of technical assistants, and representatives of other organizations within TVA.

TP-3 b.

The purpose of the CECC and the associated stafF is to provide the facilities and manpower for evaluating, coordinating, and directing the overall activities involved in coping with the radiological emergency.

c.

The CECC (located in Chattanooga) is designated to serve as the central point for information collection, assessment, and transfer during an emergency.

TP-4 C.

Emergency Notification and Activation of the Plan 1.

Emergencies can be caused by natural disasters such as tornadoes or floods, hazards such as aircraft crashes, releases of toxic gases, or breaches of plant

security, as well as by conditions involving plant systems directly.

2.

Recognition of the emergency class is primarily a judgement matter.

The initiating conditions used for recognizing and declaring the emergency class are based on specific measurable values or observable conditions defined as Emergency Action Levels (EALs).

3.

Upon detection of an emergency, the Shift Onerations Supervisor

{SOS) will determine the proper event classification using Emergency Plan Implementing Procedure (EPIP)-l.

(This responsibility may not be delegated.)

He then acts as the Site Emergency Director and If more informat i or is needed, the SOS should refer to Appendix A of ONP-REP.

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Page 9 of 22 OPL')71.075 Revision 1

..- LESSON OUTLINE INSTRUCTOR NOTES F.

Site Area Emergency This classification assures that response centers are staffed, monitoring teams are dispatched, personnel required for evacuation of near-site areas are at duty stations if the situation becomes more

serious, and provides current information for, and consultation with, offsite authorities and the public.

EPIP-4 contains the directions for activating the emerg'ency response for the Site Area Emergency.

2.

Upon declaration of this class, the actions described in E.2. are performed.

In addition:

a.

A precautionary evacuation of nonessential personnel is initiated in

.accordance with EPIP-8.

3.

b.

Any appropriate protective actions for the public are rec'oIINIended to State agencies by the CECC.

The initiating conditions and emergency action levels which require the Site Area Emergency are explained in Appendix A of the Radiological Emergency Plan, section A.l".3.

EPIP-4 directs that the event be reevaluated at least every two hours.

TP-6 G.

General Emergency This classification initiates predetermined protective action for the public, provides continuous assessment of information, and initiates additional measures as required by releases of radioactivity.

EPIP-5 contains the directions for activating the emergency response for the General Emergency and the guidance for ma~ing protective action recommendations.

The Site Emergency Oirector must make any required recommendations until the CECC is staffed.

(This responsibility cannot be delegated.)

TP-7 2.

If this is the initial classification, the OOS notifies the local governmental agencies within 15 minutes, and recoranends protective actions.

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UESTIO 4

A COMME Delete "RHR-TS1.C.1" as a required answer for full credit.

ESO ON JUSTI CA ION'

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I With the unit in start-up, Tech Spec 1.C.2 applies.

Diesel Generator "3B" has been started for testing which means that they are using an SI (3-SI-4.9.A.la(3B) attached) to control this operation.

Step 3.4 of the attached SI addresses the condition of the equipment associated with this SI.

Since the equipment associated with an D/G being inop during testing are considered

operable, U3 will not have any inoperable RHR pumps.

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1. 0 DEFINITIONS (Cont')

>"!y 20 1S87 2.

When a system, subsystem,

train, component, or device is

determined to be inoperable solely because its onsite power source is inoperable, or solely because its offsite povec source is inoperable, it may be considered operable for the purpose of satisfying the requirements of its applicable Limiting Condition For Operation, provided:

(1) its corresponding ofisite or diesel pover source is operable; and {2) all of its redundant system(s),

subsystem(s),

train{s), component(s),

and device(s) are operable, or likewise satisfy these requirements.

Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least Hot Standby vithin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least Cold Shutdown within the folloving 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

This definition is not applicable in Cold Shutdown or Refueling.

This provision describes what additional conditions must be satisfied to permit operation to continue consistent vith the specifications for power sources, vhen an offsite or onsite power source is not operable.

It specifically prohibits operation when one division is inoperable because its offsite or diesel power source is inoperable and a system, subsystem,

train, component, or device in another division is inoperable for another reason.

This provision. permits the requirements associated vith individual systems, subsystems,

trains, components, or devices to be consistent vith the requirements of the associated electrical pover source.

It allows operation to be governed by the time limit of the requirements associated vith the Limiting Condition For Operation ior the offsite or diesel power source, aot the individual requirements for each

system, subsystem,

train, component, or device that is determined to be inoperable solely because of the inoperabili'ty of its offsite or diesel pover source.

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Deleted E.

0 erable - 0 erabilit

- h system, subsystem,

train, component, or device shall be operable or have operability vhen it is capable of performing its specified function(s).

Implicit in this definition shall be the assumption that all necessary attendant instrumentation,

coatrols, normal and emergency electrical pover

sources, cooling or seal vater, lubrication or other auxiliary equipment that are required for the system, subsystem,

train, component, or device to perform its function(s) are also capable of performing their related support function(s).

F.

~0 erotic

- Operating means that a system or component is pergorming its intended functions i~ its required manner.

G.

Immediate - Immediate means that the required action vill be initiated as soon as practi'cable considering, the safe operation of the unit and the importance of the required action.

s BFN Unit 3 1.0-2 hmendment No.

106

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TITLE:

DIESEL GENERATOR 3B MONTHLY OPERABILITY TEST

/

CLASS:

SAFETY RELATED UNIT 3 3-SI-4.9.A. l.a(3B)

KEY 511 c-.e

1.0 INTRODUCTION

1.1

~Pur aee axe <<0~

This monthly operability test is performed to determine the operability of Diesel Generator 3B in conformance with requirements specified in Technical Specification 4.9.A.l.a.

1.2

~Sco e

1.2.1 'This instruction will provide information as to the condition of the diesel engine, the generator, and associated equipment.

Included in this surveillance is the operability of the starting air system, the fuel oil system, the diesel generator starting circuitry, the diesel generator load control circuitry, and the automatic start of the RHRSW Pumps assigned to supply the EECW Headers.

1.2.2 SI-4.9.A.3.a, Common Accident Signal Logic Test, and SI-4.9.A.4.b, 4kV Shutdown Boards Undervoltage Start of the Diesel Generators

Test, may be incorporated into this test to provide starting signals to the diesel generator.

This will help to minimire excessive starting of the diesel generators.

1.2.3 This instruction fully satisfies Technical Specification 4.9.A.l.a and partially satxsfies Technical Specification 4.5.C;l.a.

1.2.4 This instruction may be performed as a post maintenance test when Diesel Gen'erator'3B 'is returned'o'ervice fcill'owcing maintenance.

1.3

~Fre ueuc Once each month.

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TITLE:

DIESEL GENERATOR 3B MONTHLY OPERABILITY TEST CLASS:

SAFETY RELATED UNIT 3 3-SI-4.9.A.l.a(3B)

KEY 511

2.0 REFERENCES

2.1 TechnicsT' ecifications REV DQDS'.1.1

. Section 4.5.C, RHR Service Water and Emergency Equipment Cooling Water Systems 2.1.2 Section 4.9.A, Auxiliary Electrical System 2.2 FSAR Section 8.5, Standby A-C Power Supply and Distribution 2.3 Plant Inst'ructions 2.3.1 EPI-0-082-DGZ001, Diesel Generator Brush/Collector Ring, Bearing, and Electrical Control Cabinet Roof Fan Inspection 2.3.2 MMI-6, Scheduled Maintenance - Diesel Generator Units 2.3.3 0-OI-67> Emergency Equipment Cooling Water System 2.3.4 3-OI-82(U3), Standby Diesel Generator 2.3.5 PMI-17.1, Conduct of Testing 2.3.6 PMI-12.12, Conduct of Operations

2. 3. 7 PMI-2.5, Surveillance Ins true tions

. Writers 'uide 2.3.8 PMI-8. 1, Temporary Alterations

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2.4.1 3-15E500-3, Key Diagram of Standby Auxiliary Power System 2.4.2 3-47E610-.18-2, Mechanical Control'Diagram Fuel Oil System 2.4.3 3-45E724-7, Wiring Diagram 4160V Shutdown Board 3EB Single Line 2.4.4 2.4.5 45N766-3,4,11,12,23,29-32, Wiring Diagrams 4160V Shutdown Auxiliary Power Schematic Diagrams 45N767-5,6,7,8, Wiring Diagrams Diesel Generators Schematic Diagrams 2.4.6 45N768-3,4,9, Emergency Equipment Schematic Diagrams 2.4.7 0-47E840-3, Fuel Oil System 0514o Page 2 of 27 3-SI-4.9.A.l.a(3B)

TITLE:

DIESEL GENERATOR 3B MONTHLY OPERABILITY TEST

/

CLASS:

SAFETY RELATED UNIT 3 3-SI-4.9.A.l.a(3B)

KEY 511 SEV OOOS 2.4.8 3-47E861-2, Diesel Starting Air System Diesel Generators 2.4.9 3-47E861-6, Cooling System and Lubricating Oil System Standby Diesel Generator 3B 2.5 Vendor Manuals 2.5.1 Instruction/Parts Manual for 2800kW Diesel Gen. Unit for Browns

,,'erry (Book One),

DCC;5C.'Rev D, Contract Number 73C61-.84256, VTM-F318-0010,'VM fP55.'.0 PRECAUTIONS AND LIMITATIONS 3.1 Fast starts during the time period of 15 minutes to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after shutdown should be avoided except in.an emergency condition.

However, manual slow starts from the Engine Control Cabinet are.allowed during this time frame.

This minimizes the possibility. of damage to the turbocharger thrust bearing.

3.2 3.3 3.4 Continuous operation of diesel generator at loads below 520kW should be avoided to prevent oil and soot accumulation in exhaust system, air box, cylinders, and injection nozzles.

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G.E. Magna-Bl'ast circuit 'breakers should be visually inspected following each breaker operation.to check closing, springs are fully charged.

Both the amber light and mechanical flag should be checked to indicate a

charged spring.

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Diesel Generator 3B will be made inoperable during the'erformance of this instr'uction.

Whenever Diesel Generator 3B is made inoperable as a

result of performance of this instruction and the unit is not in cold shutdown or refueling, the other systems or loops that are required to be operable will be considered operable if they are within the required surveillance~te ting frequency and there is no reason to suspect that they are inoperable.

3.5 A temporary jumper will be installed to complete the control circuit of the Right Bank Air Compressor (B),

250VDC Backup Motor.

3.6 This Surveillance instruction may be performed in any plant condition providing, 4KV Shutdown Board 3EB is being supplied from an offsite power source.

3.7 Diesel Generator operating parameters shall be recorded in accordance with Attachment 26 of PMI-12.12, Conduct of Operations.

0514o Page 3 of 27 3-SI-4.9.A.l.a(3B)

TITLE:

DIESEL GENERATOR 3B MONTHLY OPERABILITY TEST CLASS:

SAFETY RELATED UNIT 3 3-SI-4.9.A. l.a(3B)

.KEY 511 INITIALS 4.1 A copy of form PMI-36 is attached to this instruction and all steps required for SI start are completed.

4.2 Three operators (one for Panel 9-23 operations and two for D/G Room operations/checks) are available to perform this supreillance.'nstruction..

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- Diesel Generator. 3B,is in Standby Readiness in accordance with OI-82(U3), Standby Diesel Generator.

4.4 Shutdown Board 3EB is being supplied power from an offsite power source.

4.5 Electrical Maintenance Supervisor is informed that this Surveillance Instruction is to be performed in order that EPI-0-082-DGZ001 operation of the D.C. Backuo Air Compressor

Motors, may be performed.

4.6 Mechanical Maintenance Supervisor is informed that this Surveillance Instruction is to be performed in order that "applicable sectioni of MMI-'6 -'Scheduled'aintenance-Die's'e1 Generator Units, may be performed.

4.7 Mechanical Test personnel are informed that this Surveillance Instruction is to be performed in order that MRI-413 (Vibration Mon~ting-ECCS) may be performed.

This notification required for scheduled runs of this SI in January, April, July, and October. only, NA otherwise.

0514o Page 4 of 27 3-SI-4.9.A.l.a(3B)

ENCLOSURE 4 NRC RESOLUTION OF FACILITY COMMENTS Generic Comments 1.

Comment noted.

During the pre-examination review, it was noted that the term "Margin to Shutdown" was not used at Browns Ferry.

When asked for substitute terminology, the facility reviewers suggested the term "Margin of Shutdown".

No mention of concern for the terms "Power Defect" or "Reactivity Defect" was made.

It is not felt this was detrimental to the examination since all candidates were specifi-cally instructed to question any terms that were confusing or not plant specific.

No candidate questioned the use of these terms during the examination.

2.

Comment noted.

3; Comment noted with exception.

The typical Region II BWR exam contains between 105. and 115 points.

The Browns Ferry exams fell within this range.

The reason for the difference in the number of questions between the RO and SRO examinations is that the RO examination contained more multi-part questions than did the SRO examination.

When the number of required'esponses is compared, the length of the two examinations is almost the same -

153 responses required of the 'RO exam'inati'on versus 152'esPonses required of the SRO examination.

Additionally, the proctors monitored the progress of the SROs and noted that several spent an excessive amount of time on Sections 6 and 7.

As a result, these candidates had only a short period of time to complete Section 8 let alone time to perform any problem analysis.

Since the other SRO and RO candidates had no trouble with the exam, it is suggested that the Training Department's exam taking techniques be reviewed.

4.

Comment noted.

The intent of the pre-examination review is to ensure the technical accuracy and operational relevancy of the written and simulator examinations.

Additional benefits of this process are a

reduced number of interruptions during the examination for clarifica-tion of questions and a reduced number of post-examination facility comments.

The facility should ensure that the highest quality personnel are provided to guarantee the future success of this review process.

SRO Examination guestion 6.10/2.06 NRC resolution:

Comment noted.

The supporting reference material provided by the facility does not address seal damage.

Instead, it addresses increased drive maintenance.

Therefore, the answer key has been expanded to accept answers indicating increased CROM maintenance.

guestion 7.22 NRC resolution:

Comment accepted.

The answer key has been changed as recommended by the facility.-

guestion 8.05 NRC resolution:

Comment accepted.

The'nswer key has been changed as recommended by the facility.

guestion 8.20 NRC resolution:

Comment accepted.

The answer key has been changed as recommended by the facility.

guestion 8.22 NRC resolution:

Comment partially accepted.

The additional reference material supplied by the facility clearly states that classification of the event and recommendation of protective action cannot be delegated.

These answers will be accepted as alternative correct responses.

The additional reference material,

however, does not support the response of "determining radiation dose limits" as an acceptable response.

guestion 8.24 NRC resolution:

Comment partially accepted.

-The facility justification states that TS 1.C.2 applies.

Therefore, simply deleting the incorrect response as recommended by the facility is inappropriate.

The answer key has been changed to require TS 1.C.2 as a full credit answer.

RO Examination guestion 2.11 NRC resolution:

Comment accepted.

The answer key has been expanded to accept "D/G continues to run" as an alternative response.

It should be noted that following the pre-review of the examination the answer key was

changed, as recommended by the facility, to substitute "shifts to the single unit mode" for "continues to run unloaded".

guestion 3.12b NRC resolution:

Comment accepted.

Based on a review of the answers given by the candidates, the clarity of this question may not have been sufficient to elicit the desired responses.

Therefore, the answer key has been modified to accept the three individual fast start signals as independent answers.

ENCLOSURE 5

SIMULATOR FACILITY REPORT Facility Licensee:

Tennessee Valley Authority Facility Docket No.:

50-259, 50-260, and 50-296 Operating Tests Administered on:

December 13-15, 1989 During the conduct of the simulator portion of the operating

tests, the following items were observed:

ITEM DESCRIPTION None other than the continued problems previously documented.