ML20138J469

Requests That Question 7.4 Be Deleted from Cold Licensing Exams Administered at Facility on 850930-1004.Matl Supporting Position & Request Encl

ML20138J469
Person / Time
Site:	Seabrook
Issue date:	10/09/1985
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Keller R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20138J417	List: IR 05000443/1985024 ML20138J415 ML20138J469
References
NUDOCS 8512170529
Download: ML20138J469 (9)

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... 1 p' 9 j George S. Thomas a Vice PreskMnf Nuctoor P cduenco l Put2c Service of New Hampshire New Hampshiro Yankee Division October 9, 1985 Mr. Robert M. Keller, Chief Projects Branch No. I Division of Reactor Projects U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Subj ect : Review of NRC Written Exam

Dear Mr. Keller:

During the cold licensing exams administered at Seabrook Station during the week of September 30 through October 4, the Training Center staff was provided the opportunity to review the written exam.

As a result of this review, it is requested that question 7.4 he eliminated from the exam. The basis for this request is described below.

Seabrook Station has impicmented site specific procedures adapted f rom the Emergency Response Guidelines (ERGS) developed by^the Westinghouse owners Group (WOG). Question 7.4 testa cach candidate's knowledge of entry level conditions for a Functional Restoration (FR) procedure. Entry to procedure FRZ.3 is made on a yellow path f rom a Critical Safety Function (CSF) status tree. The priority assigned the color yellow calls for " eventual operator action."

The integration of the CSF status trees and the ERGS require the operator to begin monitoring critical safety functions only af ter bcIng directed to do so from either E-0, Reactor Trip or Safety Injection or ECA-0.0 Loss of All AC Power. Direct entry to a functional testoration procedure is never made.

Memorizing entry conditions to procedures other than E-0 or ECA 0.0 is unnecessary and is discouraged by the ERG philosophy and our operator t ra in ing program.

Attached is mater tal supporting our position and request. This material was extracted from the Users Guide for the ERG set provided by the West inghouse Owners Group.

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• Telephe>no(603)d7d 9521

Mr. Robert M. Keller October 9, 1985 Page 2-Should you have any questions concerning'this information, please contact Mr. Peter M. Richardson, Seabrook Training Center Manager, 'at (603) 474-9521,.

extension 2605.

Very truly yours, l e S. Thomas CST /cj b Attachments d

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TABLE 4 STATU3 TREE COLOR LEGEND COLOR CODE Definition Green The critical safety function is satisfied - no operator action is called for.

Yellow The critical safety function is not fully satisfied - operator action may eventually be needed.

Orange The critical safety function is under severe challenge prompt operator action is necessary.

Red The critical safety function is in jeopardy -

immediate operator action is required.

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Monitoring may be terminated af ter the Reactor Protection System and Engi-neered Safeguards System are both restored to operable status (SI reset.and

( trip breakers closed). At this point, the operator should no longer be using the ERPs.

A YELLOW terminus does not' require immediate operator attention.

Frequently it is indicative of an off normal i and/or temporary . condition which will be restored to normal status by actions already in progress. In other cases where RED or ORANGE termini are possible, the YELLOW status might provide an early indication of a problem developing. Following' FRP implementa tion, a YELLOW might indicate a residual off-aormal condition.

The operator is allowed to decide whether or not ito implement any YELLOW condition FRP. \

Tree monitoring can be done automatically by compu'ter; however, the opera-tor should verify proper automatic status monitoring at least once and as S early as possible. This is accomplished by comparing status tree indica-tions with hard wired MCB indicators for appropriate ' parameters. - ,

5. . EXAMPLE OF STATUS TREE USAGE

• 1 The actu'al process of working through the trees will be illustrated by exa-mining the first (Suberiticality) < status tree. The user enters die tree,at the lef t-hand arrow and is asked if neutron flux (NIS channels) indicatiba is less than 5%. The possible answers are either "yes" or "no". If indi- ,

cated power. is greater than 57.,, then the appropriate answer is "no", so the user would follow , the "no" path directly to the terminus and determine tha t: '

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i e the response, phiority is RED (immediate response required) ,

5 e the appropriate Function Restoration ?rocedure is FR-S.I.

According to the Rules of Priority, the operator should suspend whichever ORP is bein'g performed and immediately initiate the actions in procedure FR-S.L. Monitoring of the Status . Trees may continue for information pur-poses, but by Rules of Priority, no other higher priority condition, can exist. When the actions required by FR-S.1 are complete, the ope'ra tor . is, .

directed to "Re turn to Procedure and Step in Effect". This allows recove'ry actions to continue exactly where they were suspended when the RED priority was recognized. This also signals continued monitoring of status trees.

In this case, the user and/or operator would know, because of the FR-S.l actions and checks, tha t the subcriticality tree would have no status more severe than YELLOW.

4 If indicated power is less than 5%, then the first question block is answered with a "yes" and the user would follow the "yes" pa th to the.,next question, block. '

In this second block, the user is asked whether the Intermediate Rango' S tartup ' Rate is zero or negative. If the indicated rate is positive, then the userl would follow the "no" response path directly to a terminus and determine tha t:

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6. CONTROL ROOM USAGE OF THE ERG NETWORK While the previous sections. discussed the separate usage of an individual

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guideline and evaluation of Status Trees, this section presents the intended overall usage of the entire ERG network.

Entry into the Emergency Response Guideline se*. is limited to two specific conditions:

o If at any time a reactor trip or safety injection occurs or is required, the operator will enter guideline E-0, REACTOR TRIP OR SAFETY INJECTION.

o If at any time a complete loss of power on the ac emergency busses takes place, the operator will enter. guideline ECA-0.0, LOSS OF ALL AC POWER. This includes any time during the performa~nce _of any other ERG. -

The entry into E-0 is expected to be the one more frequently used, so it is i described first:

I The. operator enters at Step 1 and proceeds through E-0, following the rules of guideline usage as described above, with two possible outcomes:

c o He remains in E-0 and is directed by an action step to begin monitoring the Status Trees, or x'

o He transfers to some other guideline, at which point he begins to monitor the Status Trees.

, ' Monitoring of the Status Tre'es takes place in accordance with its own rules of usage, in parallel with the recovery actions being performed by the operator.

The monitoring may be done directly by one of the operators in the control room, by some other member of the shift assigned to the control room, or by a dedicated computer routine. The only requirement of the monitoring function is a

USERS GUIDE 16 September 1, 1983 6689B:1 ga

.[* Mesitarirg' may be terminated af tsr ths Rocctor Protectics Systea cad Engi-

, noorsd Sofcguardo Systea era both ractorsd to oporchio status (SI rasat cod

• trip breakers closed).. At this point, the operator should no longer be using the ERPs.

AYg terminus doesy require immediate operator attention.

Frequently it is indicative of, an off-normal &nd/or temporary condition

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which will be restored to normal status by actions already in progress. In other cases where RED or ORANGE termini are possible, the YELLOW status might provide an early indication of a problem developing. Following FRP.

implementation, a YELLOW might indicate a residual off-normal condition.

The operator is allowed to decide whether or not to implement any YELLOW condition FRP.

Tree monitoring can be done automatically by computer; however, the opera-tor should verify proper automatic status monitoring at least once and as early as possible. This is secomplished by comparing status tree indica-tions with hard wired NCB indicators for app opriate parameters.

5. EXAMPLE OF STATUS TREE USAGE

' The actual proces - p . working through the -trees will be illustrated by exa-mining the first (24acriticality) status tree. The user enters the tree at the lef t3 hand arrow and is asked if neutron flux (NIS channels) indication is less chan 5%. The possible answers are either "yes" or "no". If indi-cated power is greater than 5%, tren the appropriate answer is "no", so the user would follow the "no" path directly to the terminus and determine tha t:

t e the reopnnse priority is RED (immediate response required) e the appropriate ~ Function Restoration Procedure is FR-S.I.

According to the Rules of Priority, the operator should suspend whichever ORP is being performed and. immediately initiate the actions in procedure FR-S.L. Monitoring of the Status Trees may continue for information pur-poses, but by, Rules of Priority, no other higher priority _ condition can exist. When - the actions required by FR-S.L are complete, the operator is directed to Re turn to Procedure and S tep in Eff ect". This allows recovery actions to continue exactly where they were suspended when the RED priority was recognized. This also signals continued monitoring of status trees.

i In this case, the user and/or operator would knce, because of the FR-S.l j actions and checks, tha t the subcriticality tree would have no status more severe than YELLOW.

If indicated power is less than 5%, then the first question block is answered with a "yes" and the user would follow the "yes" path to the next question block.

In this second block, the user is asked whether the Intermediate Range S tartup Rate is zero or negative. 'If the indicated ra te is positive, then

the ' user would follow the "no" response path directly to a terminus and determine tha t

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6. CONTROL ROOM USAGE OF THE ERG NETWORK While the previous sections discussed the separate usage of an individual guideline and evaluation of Status Trees, this section. presents the intended overall usage of the entire ERG network.

Entry into the Emergency Response Guideline set is limited to two specific conditions:

o If at any time a reactor trip or safety injection occurs or is required, the operator will enter guideline E-0, REACTOR TRIP OR SAFETY INJECTION.

o If at any time a complete loss of power on the ac emergency busses takes place, the operator will enter guideline ECA-0.0, LOSS OF ALL AC POWER. This includes any time during the performance of any other ERG.

The entry into E-0 is expected to be the one more frequently used, so it is described first:

The operator enters at Step 1 and proceeds through E-0, following the rules of guideline usage as described above, with two possible outcomes: '

o He remains in E-0 and is directed by an action step to begin monitoring the Status Trees, or o He transfers to some other guideline, at which point he begins to monitor the Status Trees.

Monitoring of the Status Tre~es takes place in accordance with its own rules of usage, in parallel with the recovery actions being performed by the operator.

The monitoring may be done directly by one of the operators in the control room,'by some other member of the shift assigned to the control room, or by a dedicated computer routine. The only requirement of the monitoring function is USERS GUIDE 16 September 1, 1983 6689B:1

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s' ATTACHMENT 2 Facility Comments and Resolutions Question Comment 5.3b Typo - change 231 to tau.

5.7 Half lives were not asked for in the question and will

.not be required in the answer.

5.12 . Natural circulation indications in ES-0.1 Appendix A may be'used since they are essentially equivalent to those in the answer key.

6.2 According to UEC Dwg. 9763-M-310882-SHA05b, the electrical supply bus 86 relay is NOT a part of the-RCP starting interlock. It is, therefore, not a required part of the correct answer.

6.4 In part 4, change " BIT" to "SI Flow Path" since the BIT has been removed.

6.5 Answer key typo: change _ point value to 2.0 for entire question and 0.4 for each part of part b.

6.12 According to UEC Dwg. 9763-M-503492, only three EDG trips correctly answer the question: Mechanical overspeed, generator differential (primarily lockout),

and 2/3 low Lube oil pressure.

6.14a According to UEC Dwg. 9763-M-503398, the CCP mini-flow recirc valves reopen on low flow after an SI signal. This is the correct response to part a.

7.4 Facility comment was that this question requires memorizing the yellow path entry condition to FR-Z.3 Responseoto High Containment Radiation, and that such memorization is not required by the guidance given for the use of the Emergency Response Guidelines (ERG). This procedure would always be entered by direction from another ERG or from a Critical Safety Function (CSF). status tree. Based on the Westinghouse Owners' Group (WOG) Executive Summary Users' Guide section, which is the source of the above guidance, the question will be deleted from the exam. However, two points should be made.

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1) NUREG 1122,.Knowledges and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors, gives a^high importance rating to generic ability #10 - Ability ,to recognize abnormal. indica--

tions for_ system operating parameters, which are entry-level conditions for emergency and abnormal operating procedures.

Future questions can and will be based on this ability, including the ERG's where appropriate, i.e. red path. conditions, which are characterized as requiring immediate operator action by-the WOG User's Guide.

2) In accordance with NUREG 1021 Operator Licensing Examiner Standards Section 402.A.3, candidates must be able to describe conceptually the objectives and methods used to achieve those objectives for all emergency and off-normal procedures. Based on this, questions related to the general plant conditions under which a particular ERG would.be used are con-sidered relevant and permissible.