ML20195B506
| ML20195B506 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/04/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9811160148 | |
| Download: ML20195B506 (12) | |
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UNITED STATES
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I ;g NUCLEAR REGULATORY COMMISSION t;
y REGION IV 611 RYAN PLAZA DRIVE, SUITE 400
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l ARUNGTON. TEXAS 76011-8064 NOV - 41998 l
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G. R. Hom, Senior Vice President of Energy Supply L
- Nebraska Public Power District 141415th Street Columbus, Nebraska 68601 l
SUBJECT:
NRC PROPOSED RESOLUTION TO YOUR POST EXAMINATION u
COMMENTS
Dear Mr. Hom:
l Enclosed with this letter are NRC's proposed specific responses for each of the comments l
provided by Nebraska Public Power District on the September 1998 initial examination, for your i
review and use. We plan to discuss any comments or concems on these proposed resolutions j
in our forthcoming meeting on these examinations.
Based on the analysis reflected in the attached comment resolutions, we believe that the written L
cramination administered on September 25,1998, was valid. We understand, based on l
~ October 30 and November 2,1998, telephone conversations between Messrs. Peckham, l
Shiever, and Pellet, that you will review the enclosed response to determine if you have any objections to that assessment and you will notify us by November 10,1998, if you have any objections. Based on this understanding, after November 10,1998, if you express no
. objections, we plan to proceed with issuance of examination results from the licensing i
examinations independent of our forthcoming meeting. Since examination validity issues have l
been resolved, this will not need to be discussed at our meeting. Meeting topics would then include:
Any comments or questions you have on our proposed resolutions to your specific comments, for your use in future examination development.
The results of your root-cause assessment and your corrective or remedial actions and schedule related to:
o Any knowledge or ability weaknesses demonstrated by the applicants, i
i Changes to the training program content or duration for this license class, and j
o i
o Your development process for license examinations.
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9811160148 981104 0
PDR ADOCK 05000298
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V PDR J
l Nebraska Public Power District If you have any questions regarding this matter, please contact me at (818) 860-8180 or J. Pellet at (817) 860-8159. Based on the telephone conversation described above, we are scheduling the meeting to discuss these issues for November 30,1998, in the Region IV office in Arlington, Texas, at 1 p.m. We will officially notify you of this meeting separately.
Sincerely, b
b Arthur T. Howellill, Director Division of Reactor Safety l
Docket No.:
50-298 License No.: DPR-46
Enclosure:
Cooper Nuclear Station Licensee Post Examination Comment Resolution cc w/
Enclosure:
Dave Cook, Nuclear Training Manager Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 J. H. Swailes, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L Houston, Nuclear Licensing and Safety Manager l
Nebraska Public Pow'er District P.O. Box 98 Brownville, Nebraska 68321 I
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Nebraska Public Power District l
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l Dr. William D. Leech l
MidAmerican Energy 907 Walnut Street P.O. Box 657 i
Des Moines, Iowa 50303-0657 Mr. Ron Stoddard Lincoln Electric System 1040 O Street P.O. Box 80869 Lincoln, Nebraska 68501-0869-Randolph Wood, Director Nebraska Department of Environmental Quality P.O. Box 98922 i
Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street.
Aubum, Nebraska 68305 Cheryl Rogers, LLRW Program Manager l
Environmental Protection Section Nebraska Department of Health.
301 Centennial Mall,' South P.O. Box 95007 Lincoln, Nebraska 68509-5007 R. A. Kucera, Department Director
- of Intergovemmental Cooperation Department of Natural Resources P.O. Box 176
' Jefferson City, Missouri 65102 Jerry Uhlmann, Director State Emergericy Management Agency
- P.O. Box 116 Jefferson City, Missouri 65101
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Kansas Radiation Control Program Director
7 Nebraska Public Power District,
bec to DCD (IE42) bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/C)
MIS System Branch Chief (DRP/TSS)
RIV File Project Engineer (DRP/C)
Robert Gallo Laura Hurley
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DOCUMENT NAME: G:\\OB\\ EXAMS \\CNS\\FAC-LT22.WPD To receive copy of document, Indicate in box: "C" = Coiy without enclosures *E" = Co >y with erdosures "N" = No copy l RIV:C:OB R
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OFFICIAL RECORD COPY jj,3 C $ i-e s
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l ENCLOSURE COOPER NUCLEAR STATION LICENSEE POST EXAMINATION COMMENT RESOLUTION DESCRIPTION OF ANALYSIS Ref (a) HLC 97-01 NRC Exam Comments and Recommended Changes.
Ref (b) NLS 980171 October 13,1998 Subj: Post Examination Analysis NRC reviewed the facility informal post examination comments (Ref (a)), provided on October 2,1998, and the formal post examination comments (Ref (b)) provided on October 13, 1998. This review encompassed both the technical and psychometric validity of each question and comment. The following summary and detailed table contains the NRC's analysis and proposed resolution of those comments. In the detailed table, questions common to both examinations are designated by a "C" after the number and RO or SRO unique questions are designated by an 'R' or "S", respectively. The resolution reflects changes that were made to the original examination answer keys for final grading of the Cooper initial written examinations that were administered by facility proctors on September 25,1998.
SUMMARY
OF CHANGES The facility licensee recommended changes to 43 questions, which included 33 deletions and accepting additional or different answers for the other 10. NRC analysis resulted in the following examination changes:
10 questions were deleted as suggested by the facility, as follows:
4 common [#s 13,19,23,45),
2 RO ONLY [#s 81,99], and 4 SRO ONLY [#s 73,78,83,87).
4 question keys were revised to accept additional answers, as recommended by the facility, as follows:
2 common [#22,31} and 2 RO ONLY [#91,100].
4 questions were changed based on additional information provided by the facility, but not as recommended by the facility, as follows:
2 common:
- 30: accept 2 answers rather than facility recommended deletion
- 97: reject comment but correct key error 1 SRO ONLY:
- 66: accept 2 answers rather than facility recommended deletion Page __a
1 25 comments were rejected and did not result in changes to the final examination answer keys, as follows:
9 common (9,12,17,33,36,42,55,56,62],
9 RO ONLY [63,77,82,85,89,91,93,94,95], and 7 SRO ONLY [65,75,82, 84,94,98,100].
a RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 09C Reject, no The entry conditions for procedure 2.4.8.4.2 are given as: Drywell High change Temp, Drywell FCU High DischTemp, and/or Drywell High Pressure Alarms. These conditions were not given in the stem, and the immediate actions given in the stem are applicable only to those actions taken for procedure 5.2.4. The question is technically correct as given.
12C Reject, no This question requires the candidate to deduce that a blockage has change occurred in the SLC injection path, resulting in no injection to the vessel.
Expected discharge pressure from two SLC pumps running with only one squib valve open is approximately 1200 psig. The given 1500 psig in the question stem indicates that the discharge relief valve (1500 psig setpoint) is open and no flow is going to the vessel. The applicant should then diagnose that alternate boration is required. Distractor (b) is a valid alternate boration method, but requires extensive manual operation in the plant. The answer, (a), is the preferred method.
Procedure 2.2.74 would require stopping of the A SLC pump due to failure of its respective squib valve, however, given the abnormally high discharge pressure, alternate boration would still be required by procedure 5.8.8.
13C
- Accept, This is a technical error not identified during validation. There is delete technically no correct answer to the question, although the knowledge required to answer the question is reasonable and "d" would clearly be the correct answerif the question stem had read:"Which of the following conditions would cause SRM A.."
17C Reject, no The answer is technically correct, and no facility reference was provided change to show this question to be invalid. Familiarity with containment inerting criteria is reasonable and important to maintain containment integrity given elevated hydrogen in the containment.
19C
- Accept, The question asks which of the given distractors " applies," which is delete confusing, and is unclear what knowledge is being tested. The comments provided do not address this, but highlight the confusing nature of the question.
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RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 22C
- Accept, The answer as given is the second immediate action in procedure accept "a" 2.4.8.4.2, after the first immediate action given in the stem of the or "b" question. Distractor "b" is also accepted as correct since the alarm 1
l procedure for the given alarm would be automatically carried out by the board operator, and includes verifying the temperature alarm, checking all FCUs operating, then verifying proper REC lineup. The first two of these actions are given in the stem, and although alarm response procedure actions are not required to be recalled from memory, the third action is a valid response to the question.
l 23C
- Accept, The intent of the question was to ask about a reactor startup, transition delete to mode 2, in which case the correct answer would clearly be "d", since the mode switch cannot be placed in startup (entry into mode 2) until all l
ECCS systems are operable. However, the term plant startup was used, which can imply starting from mode 3 or 4, although typically startup is conducted from mode 4 and transition to mode 2 is made by placing the mode switch in startup. lf mode 4 is assumed, distractors "a" and "c" will meet T/S 3.5.2 for ECCS, Shutdown. Distractor "b" is only correct if you assume startup had already begun and the failure occurs in mode 2. Therefore, three answers can be correct and the question is invalid.
l 30C Accept "c" The question does not state that steady state conditions are to be or "d" analyzed, and thereby cannot be used as justification to disca" l ansient conditions. Additionally, the licensee comment that at steady state vessel level will indicate the same or lower is also incorrect, since the reference leg would have boiled off, the variable leg is at steady state, and vessel level would indicate erroneously high. The facility does state that during the boil off, flow restrictions through the (variable leg) nozzle will cause vessel level to indicate erroneously high. Combined with the boiling in the reference leg which also causes an erroneously high indication, the laitial effect of the transient is an erroneously high level l
(answer"d"). Closer to steady state, the effect of boiling in the variable leg will have an erroneous negative level error, which makes "c" correct.
Distractor "a" is not an affect of boiling in the variable leg, and distractor "b" is false.
31C
- Accept, This is a technical error not identified during validation.
accept "b" or "c" 33C Reject, no The answer is technically correct as given. 20 minutes are allowed to change attempt to restore charging header pressure, then the rod is declared slow or inoperable within one hour. Clearly, the correct action and reasonable knowledge being tested is to restore pressure and avoid declaring the rod inoperable or slow due to low charging header pressure.
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RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 36C Reject, no The question is technically correct as given. Distractors "a" and "c" can change be discarded since they do not represent an offsite release, and distractor "b" is incorrect since the ERP Kaman reading is not high enough to warrant EOP entry.
42C Reject, no The answer is technically correct and reasonable knowledge of reactor change protection system bases.
45C
- Accept, There is no correct answer. This is a technical error not identified during delete validation.
SSC Reject, no Operators are expected to know what plant conditions require a manual change scram. The conditions in this question would require implementation of the Emergency Shutdown procedure, GOP 2.1.5, which does require a manual scram in step 2, but also has a precaution to ensure there is no way to do a normal, controlled shutdown. For the conditions given, the SRO should begin a normal shutdown until suppression pool temperature approaches 110 F, which then requires the manual scram.
56C Reject, no The references supplied support the question and answer as written.
change Either 1 AF.o_r 1 FA must be open, but the latter is not offered as a choice for the question and so the original key is correct.
61C
- Reject, Both RO and SRO candidates should recognize this condition as a delete failure of the Reactor Protection System, which as a minimum requires entry into the emergency plan. With that, distractors "a" and "b" are incorrect. Any declaration of an EAL in the emergency plan makes "c" a correct answer.
Distractor "d" can be ruled out only through determination that Alternate Rod insertion (ARI) should not be expected given these conditions combined with application of the emergency plan, which was provided to SRO candidates only. Although the question is technically correct as is, the candidate should not be held accountable to determine if ARI has actuated from the information in the stem.
Therefore, the question is deleted on both examinations.
62C Reject, no EOP 3A logic clearly shows, contrary to the facility comment, that when change torus pressure cannot be maintained below PSP (PC/P-11), then Emergency Depressurization is required, then before PCPL is exceeded (PC/P-12), either the torus or the drywell is emergency vented based on containment water level. The question is technically correct as given.
63R Reject, no The question is technically accurate, and appropriate for the RO.
change 77R Reject, no The question is technically correct. A question of this difficulty does not change require prints, since only two valves, MO-15 and MO-16, the inboard and outboard Steam Line isolations, are in the distractors. The knowledge needed to answer the question is not from a system print.
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RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 81R
- Accept, This is a technical error not identified during validation.
I delete i
82R Reject, no The question is technically correct as written. This question reflects one l
change of the changes in acceptance criteria for operability brought about by ITS implementation, and is a relatively simple change. This is also not an obscure surveillance, and is performed daily in the control room. The acceptance criteria changed with ITS from 10 to 20%.
83R
- Accept, This is a technical error not identified during validation.
accept "a" l
85R Reject, no The given answer is technically correct and "b" is clearly the correct I
change answer. Choice "d" can be ruled out as incorrect since a ground in the C channel IRM range switch, that would result in the indications in the A channel given in the stem, must also be expected to give some indications in the directly affected C channel. Since the stem had no l
indication of abnormal operation of the C channel, "d" is not a correct
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answer, which can be determined by specific application of general system knowledge.
89R Reject, no This question requires the candidate to recognize a failed temperature l
change detector in channel TR-25, and recall from memory that average suppression pool temperature is determined by averaging the highest four valid temperature indications in the suppression pool.
it is reasonable that the applicant should recognize point 2 on TR-25 as failed since it is inconsistent with its nearby temperature sensors, as well as its redundant point on channel TR-24. Additionally, HPCI discharges near point 6 in the suppression pool, which is consistent with the elevated readings given on point 6 and nearby temperature indicators.
i The ability to determine average suppression pool temperature is important given its frequent use in decision blocks in the EOPs, and manual calculation would be required for events such as a loss of power.
l The procedure addresses the given question. Any invalid reading due to component failure must not be used. Step 6.1.3 in procedure 5.8.9 does not apply since the four highest (valid) points on TR-24 and -25 are not high off scale. Additionally, since RHR A is no longerin service, inlet temperature to the heat exchanger is not a valid reading for average suppression pool temperature. The question is technically correct as is.
91R Reject, no A reasonable assumption for this question is that the indicated level is change wide range, as this is standard terminology when entering the EOPs.
Level in the fuel zone is normally designated as such. This question is technically correct as written.
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l RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 93R
- Accept, This is a technical error not identified during validation.
accept "c" or "d" 94R Reject, no The question is technically correct as written. This question does not change require recall from memory of subsequent action steps in the abnormal procedure.
It simply requires recognition of where the action is conducted, whether locally or in the control room.
95R Reject, no The answer is technically correct.
Distractor (d) is invalid because change.
CREFS does not isolate. (c) is the only correct answer, and the other distractors can be ruled out without detailed knowledge of the MCC loads.
97R
- Reject, The question requires the RO to recall from memory that a T/S LCO for accept "a" combined fuel oil storage tank volume is not met. T/S require a combined volume of less than 49,500 gallons and greater than 42,800 gallons. The combined volume given in the question is 38,800 gallons, which is approximately 10% less than the required minimum volume. It is reasonable for the RO to recognize that the EDGs are functional, therefore distractors "b" and "c" would not be correct, and familiarity with the subject LCO would allow distractor "d" to be discarded. The question asks for reasonable closed reference application of knowledge and is technically accurate. However, "a" is the correct answer, vice "b" as is on the original answer sheet.
99R
- Accept, The question is technically correct, however, no reference was supplied, delete and we agree that this knowledge is too detailed for the RO without the use of references.
100R
- Accept, This is a technical error not identified during validation accept "b" and "c" 65S Reject, no The question is technically correct. It solicits the definition that is change expected knowledge for an SRO, and not the detailed supplemental procedural actions that are taken to verify if a rod can be inserted at elevated drive water pressures.
66S
- Reject, This question requires broad scope knowledge of reactor feed pump accept "a" normal startup procedures, which is a general oversight function and "c" expected of an SRO. Only major system evolutions are described and required to be recognized which is correct, not recalled from memory.
Choice "c"is also accepted as correct, since it is true and responsive to the stem exact phrasing, although "a" is more correct and, if the stem were more restrictive, would have been the only credited answer.
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RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 73S
- Accept, This is a technical error not identified during validation.
delete l
75S Reject, no The question is technically accurate it is reasonable to assume an SRO l
change familiar with the EOPs could eliminate distractors (a) and (d) as invalid.
Information in the stem should lead the candidate to assume RBHVAC isolated on High Radiation. Distractor (b) could be the answer only if the l
applicant assumes exhaust radiation levels rapidly drop to less than 10mr/hr after RBHVAC had automatically isolated. With radiation levels approaching the Maximum Safe Operating limits (1000mr/h-), it is l
reasonable to assume that RB exhaust plenum radiation levels would l
remain greater than 10mr/hr absent specific information. Choice (c) is the only correct answer given the conditions in the stem.
78S
- Accept, The question has three correct answers. The best answer is "a",
delete however loss of power to CCP-1A causes loss of reactor building exhaust fans, which normally supply a process flow signal to the Kaman monitors. SGT initiates, but does not supply a process flow signal, therefore "c" is a reasonable correct answer. Further, the given condition isolates process flow to the Kaman monitor, and even though the sample isolation valves are not closed, "b" could be considered correct since the sample point is effectively isolated.
I 82S Reject, no The question is technically correct as written. RCS pressure reaching l
change 1135 psig with two SRVs failing to open is outside the facility design basis, and constitutes an actual threat to the integrity of the RCS. Since the question asks which of the following requires NRC notification via the ENS within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, it is essentially asking for the most severe condition given, since the most severe accident at any plant only requires NRC notification as soon as possible, but within one hour. The other distractors are clearly less severe.
83S
- Accept, The question is technically accurate, however, this is an infrequently delete performed evolution, and the use of the "on the spot change" is only l
referred to in the administrative limits of procedure 10.21, "Special l
Nuclear Materials Control and Accountablity Instructions."
l 84S Reject, no The question is technically accurate, and "a" is clearly the correct l
change answer. Distractor "c" cannot be assured that it meets the safety limit unless MCPR is known, and the stem clearly states "with no additional information."
87S
- Accept, There is no correct answer. This is a technical error not identified during delete validation.
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RESOLUTIONS TO LICENSEE COMMENTS ON INDIVIDUAL QUESTIONS Q#
Resolution Analysis 94S Reject, no A limitation stated in Procedure 10.7 directs that Reactor Engineering be change notified if MAPRAT exceeds 0.99. When the highest MAPRAT e'xceeds 1.00, the procedure states to immediately take action to reduce the MAPRAT to less than 1.00 (by reducing power using recirculation flow and/or control rods), then contact reactor engineering as soon as possible following the power reduction. Therefore, this question tests recognition of a directed immediate action. The question is technically correct as written.
98S Reject, no The question is technically correct. Original references provided with the change proposed examination for this question agree with the reference supplied with the comments. The applicant must recognize that the lowest energy state refers to initiating an Emergency Depressurization, and that after depressurization,3 SRVs open and one LPCI pump injecting assures adequate decay heat removal by steam cooling and injection flow.
Before adequate steam flow is lost, the core is covered enough such that level alone provides adequate heat removal (submergence.) Distractor "a" and "b" are incorrect because the Core Spray pump does not have adequate flow capacity to replace the LPCI pump (approximately half of LPCI capacity).
The question directly tests equipment operating conditions to assure core cooling.
100S Reject, no The question asks general knowledge of the authority of the shift change supervisor during abnormal / emergency conditions. The question does not require detailed knowledge from memory to perform the TCC, only the knowledge that it can be authorized without formal safety evaluations in the conditions given. An urgent TCC is defined as a condition where "immediate actions are required to protect the health and safety of the public and plant personnel, protect equipment, or prevent deterioration of plant conditions..." The question does not give enough information for the applicant to assume that a urgent TCC is not required, therefore the question should be answered as asked, and only "d" is the correct answer.
NOTE: Questions common to both examinations are designated by a "C" after the number.
RO or SRO unique questions are designated by an "R" or "S", respectively.
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