ML20205G122

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Forwards Detailed Comments on NRC 870303 Senior Reactor Operator (SRO) Upgrade Exam.General Comments Listed Re open- Ended Questions & Questions for Which SRO Not Responsible
ML20205G122
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 03/09/1987
From: Andrews R
OMAHA PUBLIC POWER DISTRICT
To: Cooley R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20205G111 List:
References
LIC-87-144, NUDOCS 8703310377
Download: ML20205G122 (22)


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Omaha Public Power District i 162 3 H,unoy omaru N bra %a 68 p)2.'211 1 102 536 4000 l

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, March 9, 1987 LIC-87-144 l

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l Mr. Ralph A. Cooley Operator Licersing Section j U.S. fluclear Regulatory Commission

611 Ryan Plaza Drive Suite 1000 i Arlington, TX 76011 I

References:

1. Docket No. 50-285
2. March 3, 1937, f1RC-Administered SRO Upgrade Examination l

Dear Mr. Cooley:

I 0.P.P.D. personnel have extensively reviewed the referenced examination.

! llowever, we have two general comr..ents as well as specific comments l concerning the examination. Our general comments are as follows: i i

l 1. Some questions are open ended, and could be improved by indicati,19 the number of responses des trod.

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! 2. Some questions addressed items for which SR0's are not i

responsible.

The attachment contains our detailed comments on the questions and answ..es for this examination. Please contact either Jay Fluehr or John lesarek at I (402) 426-4011, if you have any questions regarding our commont s. l

" cc / , G/

R. L. Andrews M l Division Manager i fluclcar Product ton t l

RIA:ket c: LeBoeuf, Lamb, Leiby & MacRao l 1333 New Hampshire Ave. , fl.W. '

Washington, CD 20036 P. H. Harrell, NRC Sen!ar Resident inspottor l

070331 D:1/ / f) 7 03;.%

f' Oh ADOCK 05000-'0',

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QUESTION 5.04 a:

It should not be necessary to use the term " thermal diffusion length". An acceptable correct answer should be one which explains that as the moderator heats up, neutrons travel further and more will reach the CEA to be absorbed.

i QUESTION _5.05_c:

1 I Additional correct answers should be axial and radial locations of the rod. Rods located near the top, bottom or radial periphery of the core j tend to absorb relatively more leakage neutrons versus neutrons which sustain the chain reaction, thus, they tend to have a lower worth, which is not due to the neutron flux. (Ref., Cencral Physics Academic Program for Nuclear Power Plant Personnel, Volume 11, Chapter 4, Section 0, pages 4-107 through 4-109)

QVLEU0fLL9B:

The question could be misleading since the exaninee may have assumed a constant fuel temperature in all cases, in which case (b), (c), and (d) would not change. it is suggested that the question be revised to include the following: " Assume T ayn and reactor power are the same for all four (4) cases".

00ESTION 5.09:

An additional correct answer should be erratic flow.

QUESTION 5.12 b:

An additional correct answer is one which is based on the NOTE from Figure 4-2 in the Emergency Operating Procedures. "Any time RCS has experienced an uncontrolled cooldown causing RCS temperature to go below 500*F". A copy of Figure 4-2 is attached. E0P-1 instructs the operator to maintain the RCS pressure and temperature between the 20*F subcooled curve and the 200*F subcooled curve. Any uncontrolled cooldown, causing the RCS tempera-ture to go below 500*F, which takes the RCS pressure and temperature to the left of the 200*F subcooled curve results PTS conditions.

QUESTION 6.01 a:

Alternate correct answers would include the converse of the answers specified in the answer key. For example, one could say " enable rate of change output at less than 15% power" as opposed to " disable the rate of change output at greater than 15% power."

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\ Ouestion 6.01 4: (continued) g -

m In additi n, the question, as stated, may have been somewhat confusing.

s It is suggested that the ques' tion be reworded as follows: "(1) A linear power channel drawer in the RPS contains a Level I bistable. Describe the purpose of this bistable and state the applicable setpoint(s). (2) A wide range NI channel drawer in the RPS contains Level I and Level II i

bis tables. Describe.the purpose of the bistables and state the applicable setpoint(s)."

OVESTION 6.01 b:

An alternate correct answer is a rapid power decrease. The " Dropped Rod NI" annunciator is activated by a power decrease of 8% in eight (8) seconds. Other alarms which might be generated from the NI system s following a dropped CEA would be " Power Range Subchannel Deviation" and

" Nuclear Delta T Power Cha*.nel Deviation". Points should not be deducted if these additional alarms a're discussed, since they would be indirect 4'

indications of a dropped CEA. (Ref., lesson Plan No.1-3-37, attached, and OP-10, Pages A20-14, A20-35, and A20-7, copies attached.)

! .v Orestion 6.02 a:

1. Accident load shedding is also referred to as "480 V load shed." This load shed results from an SIAS, but not from a CIAS. (Ref.,USAR section 8.4.3, attached) '

00ESTION 6.02 a: (continued)

2. An additional initiator of load shed is Offsite Power Low Signal (0PLS). This results from coincident occurrence of degraded voltage and SIAS. (Ref., USAR Section 8.4.3, attached) This is also reflected by the existing answer key for part b.

j 00ESTION 6.03 b:

The question could have been interpreted in such a way that an answer which discusses the two (2) methods as " switching to a live bus" and

" switching to a dead bus" should also be accepted for full credit. As indicated in the attached pages from Operating Instruction 01-EE-4, the methods used for transferring to a live bus are significantly different from methods used when transferring to a dead bus.

QUESTIONS 6.03 d:

There are other design features that add reliability to the inverters.

Any of the following answers should be acceptable for full credit: (1)

Each inverter has its own internal frequency reference. (2) The ability exists to cross-tie instrument AC buses. (3) The power supply for the inverters is from a battery which provides backup power in case the battery charger fails. (4) Spare battery charger.

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OUESTION 6.03 d: (continued)

The question could be improved by stating the number of design features

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desired.

Any of the above design features, or the one in the key, should be accepted for full credit. (Ref., System Description II-1)

QUESTION 6.04 a: '

An additional correct answer is that the " auto-inhibit" switch must be in the " auto" position. (Ref., Slide 1-03-42.3)

OUESTION 6.04 b:

Resetting the turbine as an option for stopping the ramp function once it has been initiated is not a prudent operator action. An appropriate i

second method that the operator could take to stop the ramp down once it had been initiated would be to place the " auto-inhibit" switch in the

" inhibit" position. (Ref., Slide 1-03-42.3 and Lesson Plan 7-12-15))

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OUESTION 6.05 a:

An alternate correct answer is to prevent a harsh environment for FW-6 created by rupture of a steam line for FW-10. Therefore, FW-10 is considered to be the designated emergency pump, and FW-6 is given preferential operation. (Ref., Operations Memorandum No. 82-4)

It is also correct to mention the undesirable conditions introduced due to the fact that use of FW-10 introduces an unmonitored release path. (Ref.,

E0P-20, Page 86, attached.)

OUESTION 6.05 b:

Any discussion addressing redundancy or single failure criterion should be acceptable for full credit for "Why are two (2) flowpaths necessary?".

QUESTION 6.05 c:

The normal path for feeding auxiliary feedwater to the steam generator is

, through the main feedwater line. The auxiliary feed nozzle is used only for emergencies. Since examinees may have assumed that feedwater was being introduced through the main feedwater line, it should not be

necessary to discuss submergence of the nozzles for full credit. An i

answer that addresses thermal shock and water hammer should be adequate for full credit.

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OUESTION 6.05 c: (continued)

In order to reduce the confusion in this question, it might be reworded as follows: "Why is it recommended that steam generator level be maintained greater than or equal to 80% when feeding through the auxiliary feedwater nozzles?" (Ref., E0P-05, Page 10 and 0I-FW-4, Page 6, copies attached.)

OUESTION 6.06 a:

It is very unclear as to what is meant by "... options available to the operator for reading these indicators...". Therefore, a discussion of any of the options available for reading the radiation monitor should be accepted for full credit. Examples include: All positions, any three (3) decades, alert setpoint, alarm setpoint, local (meter), and remote (meter). Note that there are six (6) combinations of three (3) consecu-tive decades available to the operator. (Ref., Attached page from Victoreen Technical Manual)

OUESTION 6.06 c:

This question is very confusing since there are not four (4) separate release points where potential radioactive gaseous effluents are monitored by the process radiation monitoring system. We consider a monitored release point to be a point where the effluents are monitored and leave the plant boundary or structure. In this case, the answer key only i

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OUESTION 6.06 c: (continued) contains one (1) release point, the Auxiliary Building ventilation exhaust. Answers (2), (3) and (4) all discharge to point I and are monitored at this point. There is one additional potential radioactive gaseous affluent release point which is the condenser off-gas (monitored by RM-057). Therefore, it is requested that full credit be given to any response which contains the Auxiliary Building ventilation exhaust and the condenser off-gas as release points. The question should be revised accordingly.

0VESTION 6.07 a:

A general description of the location of the switches should be acceptable for full credit. Specifying panels by number such as AI-45 or CB-1 should not be necessary for full credit. It is felt that the required answer is excessively long for only 1.5 points.

QUESTION 6.07 b:

Question 6.07 (a) addresses only the component cooling water / raw water system interface valves. Therefore, it is logical to assume that part (b) of the question is also addressing the same valves. No indication is given that valves strictly in the raw water system should be considered in the response. An answer which discusses the use of air accumulators and describes or lists the interface valves equipped with air accumulators should be accepted for full credit. (Ref., Lesson Plan No. 7-11-19)

Q.UESTION 6.08 a:

There are three (3) additional correct answers: (1) Since this flowpath may be used for correcting boron concentration in the SI tanks, it may also be used for filling the SI tanks. (2) This flowpath is also used for hot leg injection (long-term core cooling). (Ref., lesson Plan No. 7-11-2, Page 70, attached) (3) This flowpath could also be used for directing HPSI flow to the pressurizer auxiliary spray nozzle. (Ref., P&ID No.

E-23866-210-120, Page 1 of 2, copy attached.)

4 DUESTION 6.08 b:

An additional correct answer is that the valve is used for shutdown 4

cooling purification as detailed in valve checklist from OI-SC-5, attached.

QUESTION 6.08 c. PART 1:

Additional correct answers include filling the spent fuel pool from the SIRWT, draining the fuel transfer canal, and reducing level in the spent fuel pool. Refer to P&ID ll405-M-11 for flow paths.

QUESTION 6.08 c. PART 2:

Responses which address failures of the spent fuel pool cooling system components or full core discharge in short periods of time should also be considered acceptable responses.

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QUESTION 6.09 a:

The sequencers are started by receipt of an accident signal, therefore, accident signal should be acceptable in part 3 of this question.

QUESTION 6.09 b:

A number of additional correct answers exist for this question. These include: (1) Drain and refill the VCT as part of the venting process (Ref., 01-CH-3 IV.C, attached). (2) Lower VCT pressure to allow gases to come out of solution. (Ref., as above). (3) Obtain maximum purification and letdown flow (actually a way of enhancing filtration and deminerali-zation). (4) " Burp" the VCT with hydrogen and nitrogen. (Ref., 0I-CH-3 IV.C)

OUESTION 6.10 b:

Additional correct answers include low temperature over-pressurization, shutdown cooling system valve interlock, and pressurizer pressure low signal (PPLS initiates SI). Any four (4) answers should be accepted for full credit.

It is recommended that the question could be worded to say " List four (4) protective action signals that could be initiated by high or low pressurizer pressure." (Ref., lesson Plan No.1-3-41, applicable pages attached.)

OUESTION 7.01 a:

It is unclear as to what is meant by: "Be specific as to technique of determination." Therefore, any answer which discusses in some detail the process used for generating 1/M plots should be accepted for full credit.

QUESTION 7.01 c:

An additional correct answer is stack gas radiation monitor (RM-052).

(Ref., A0P-08, copy attached.)

OUESTION 7.02 a:

Two (2) additional correct answers exist: (1) A correct basis is to

reduce the probability of fuel failures (fuel ccnditioning). (2) A correct basis is to limit increases in local power density. (Ref., TDB III.22 and 01-RR-1 IV.D, copies attached.) Any two (2) of the four (4) correct answers should be accepted for full credit.

OVESTION 7.02 b; l

l Additional correct answers include: acceptable power peaking factors are i

maintained, the minimum available shutdown margin is maintained, the potential consequence of CEA ejection accidents are limited to acceptable i

l levels, core burnup distribution for LSSS setpoints, and negligible

, effects due to xenon distribution. (Ref., Technical Specification 2.10.2 i

bases, Page 2-52.) Any two answers should be accepted for full credit.

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OUESTION 7.02 c:

To clarify this question, it is suggested that it be reworded as follows:

"During initial criticality of a newly refueled core, why may the Reactor Engineer place limits on maximum withdrawal of the CEA's?"

OUESTION 7.03 b:

With the RCS pressure at 1500 psig, pressurizer pressure low signal (PPLS) would be blocked since this must occur above 1600 psia. Therefore, an alternate correct answer would be to initiate PPLS by placing the PPLS block switch to the emergency reset position. (Ref. , A0P-14, Page 2, attached.)

It should be noted, also, that the answer provided in the key is incorrect. The correct answer can be ascertained by reviewing the block diagram for Engineered Safeguards Control actuation which is attached.

QUESTION 7.04 b:

A0P-19, " Loss of Shutdown Cooling", has no specified "last resort" method for removing residual heat subsequent to a complete loss of shutdown cooling for the condition with the head removed with refueling conditions established. Since this question was misleading, it is requested that Question 7.04 b either be deleted from the examination or any reasonable flowpath be accepted for full credit. The appropriateness of a flowpath can be verified by referring to the P&ID's for the Fort Calhoun Station.

QUESTION 7.04 a:

It is suggested that an answer describing a flowpath from the SIRWT, through the HPSI pumps, into the primary system, and out of the PORV's or loop drains to the RCDT is a complete answer. Aligning the RCDT pumps to 4

the SIRWT should not be required for full credit. This question could be clarified by revising the first sentence as follows: " Describe the LAST RES0RT method, per A0P-19, including flowpaths . . . ."

DUESTION 7.05 a:

Full credit should be given for stating that the recirculation valves have been closed on a RAS or that the recirculation to the SWIRT has been isolated on a RAS. A0P-23 does not discuss the deadheading of the pumps.

QUESTION 7.06 a:

4 An additional vent path exists, that of venting the pressurizer to the VCT. This vent path is described in 01-CH-3, IV.D. (copy attached).

While this flowpath is not part of the reactor coolant gas vent system, it would be an available flowpath and would be considered for use following

, an accident. If only the answers in the key are desired, it is suggested that the question be revised as follows: "During recovery from an accident it becomes necessary to vent the RCS of non-condensible gases using the reactor coolant gas vent system..."

't OUESTION 7.06 b:

Regarding Question 7.06 b., 01-RC-12 specifically references using Figures 2 and 3 for determining pressurizer bubble size and therefore, utilization of the graphs in the procedure should be accepted as a correct answer. In regard to venting of the reactor vessel, any discussion of a specific trial and error method should be accepted for full credit. It is noted that the Reactor Vessel Level Monitoring System is now approved for use.

The latest revision of the procedure has not yet been updated to reflect 1

this.

00ESTION 7.07 a:

An alternate correct answer is that a star (*) preceding a step in the Safety Function Status Check portion of the Emergency Operating Procedures requires the operator to record the value of the parameter. (Ref.,page 24 of E0P-01) 00ESTION 7.07 b:

i A description of actions taken to attempt to establish reactivity control  :

should be accepted for full credit instead of the statement of attempting

! to establish reactivity control. In order to aid clarity, it is suggested that the question be reworded as follows: "What course of action does E0P-20 direct the operator to take if acceptance criteria for reactivity l control are not met ..."

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00ESTION 7.09 a:

In E0P-02 Step 3.5, it is assumed that 4160 volt and 480 volt AC power has been lost. However, it is not assumed that control power has been lost.

Therefore, local operation of FW-10 and the specified valves would normally not be required. Full credit should be awarded for a discussion of the components which must be operated; it should not be necessary to state that the operation would be local. In addition, consistent with Step 3.5, full credit should be given for steaming through MS-291/292 or HCV-1040. '

I QUESTION 7.09 b:

It is requested that the answer in the key be replaced with the following statement from Page 4 of E0P-02: "Cooldown below no-load T avg with no i means of makeup to the RCS may result in loss of RCS pressure and inven-tory control." Void formation is not mentioned in this statement from E0P-02.

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OUESTION 7.09 c:

An additional step which may be taken in an attempt to prolong the useful availability of DC power source is to secure emergency lighting as specified in Step 3.10A, Part 3, of E0P-02.

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OUESTION 7.10 b:

Credit should also be given for the following responses: (1) Isolating the steam generator, as detailed in Step 3.14 of E0P-04. (2) Controlling RCS pressure 0-100 psid above isolated steam generator pressure, as detailed in Step 3.18 of E0P-04.

OUESTION 7.10 d:

Voiding in the head should be an acceptable answer in addition to voiding in the RCS.

QUESTION 8.01 a. 2:

The answer in the key is incorrect since the question refers to compliance with the Limiting Condition for Operation. This clearly refers to Technical Specifications. The steam generator tube leakage limit in the Technical Specifications is 1.0 gpm. Therefore, the correct answer is "in compliance". However, full credit should be given if the individual i

discussed the .3 gpm limit as being imposed by a Special Order.

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00ESTION 8.02 a:

This question is extremely difficult to interpret. It appears that a I

i specific item from the surveillance section of Technical Specifications or l

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QUESTION 8.02 a: (continued) a surveillance test is being solicited. It is not apparent that an item appearing in the definitions section of the Technical Specifications is the desired response. Due to the misleading nature of this question, it is requested that this question be deleted from the examination. Should this information be desired in a future examination, it is suggested that a multiple choice question might be appropriate.

QUESTION 8.02 b:

The discussion concerning what must be done immediately if the number of operable channels becomes two (2) and the explanation for this could be based on Technical Specification 2.15, Instrumentation Control Systems operability requirements. Table 2-2, Item 2, contains a multitude of footnotes in regard to operable channels. Footnote (b) states that if minimum operable channel conditions are reached, one (1) inoperable channel must be placed in a trip condition within one hour from the time of discovery of loss of operability. The remaining channel may be bypassed for a certain amount of time. The above discussion should be accepted as an alternative correct answer for immediate action required.

The basis for this Technical Specification, as detailed on Page 2-66, addresses requirements.

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00ESTION 8.02 c:

Alternative correct responses to the reason for the required action to be taken are contained in the last paragraph of the basis for Technical Specification 2.15 on Page 2-66a. Some of these other reasons include:

preventing a limiting condition for operation on CEA insertion, CEA deviation, CEA overlap or CEA sequencing from being approached.

QUESTION 8.05 c:

Any specific example of a PRC approved procedure should be accepted for full credit. For example, surveillance test, Safety-Related Design Change Order (SRD0), or maintenance procedure should be considered acceptable t

answers. These specific documents are all described in the Standing Orders.

QUESTION 8.06 d:

l The Fort Calhoun Storeroom is also referred to as the Fort Calhoun Warehouse. Warehouse should be accepted for full credit.

QUESTION 8.06 e:

Standing Order G-28 states: " Personnel discovering a fire will immediately announce over the plant communication system (Gai-tronics) the location and type of fire." Therefore, an examinee describing this action should j

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00ESTION 8.06 e: (continued) not have points deducted. A copy of this portion of the Standing Order is attached. Should use of the fire alarm be included as part of his answer, an examinee should not lose credit since the fire alarm is considered part of the plant communication system.

QUESTION 8.07 a:

The last paragraph in Technical Specification 2.3(3) states: " In the event that no charging pumps are operable, a single HPSI pump may be made operable and utilized for boric acid injection to the core." An examinee

. should not be penalized if he specified this as a condition mitigating the l requirement to disable HPSI pumps.

l In order to clarify the question, it is suggested that the second sentence be reworded as follows: "What conditions eliminate the need for the requirement to disable the pumps..."

l OUESTION 8.08 a:

This question could be clarified by adding that each of the first two l barriers start at the core and work out.

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QUESTION 8.09 c:

Full credit should be awarded for-stating that the oocument should be handled as little as possible and should be preserved for investigators.

Copying the original message should not be required since it is not a

" precaution" as requested in the question. Rather, copying the message is an action to be taken.

QUESTION 8.10 b:

The question solicited a response to the previous _ method in which RWP's 4

were approved. As detailed in section K of RPP-20, Radiation Work Permits (Revision 7, 11-24-86), all RWP's must be signed by a radiation protection technician, plant health physicist, ALARA coordinator, and the Supervisor-Chemical and Radiation Protection. In addition, with the exception of routine chemistry sampling, all RWP's written for containment entry during power operations must be signed by the supervisor of the work group. Due i

to the manner in which the question was asked, the examinees could have i

responded with the outdated approval chain (that is, the answer as pre-sented in the key) or with individuals in the current approval chain.

Therefore, the answer key should be revised to read as follows: Accept any three (3) of the following individuals; plant health physicist, Supervisor-C/RP, plant manager, radiation protection (health physics) technician, ALARA coordinator, or group Supervisor.

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OUESTION 8.10 c:

4 The question as written is in error. Technical Specification 5.11.1 l addresses High Radiation Areas. Technical Specification 5.11.2 addresses i Very High Radiation Areas. (From the answer key it appears that the desired response was the methods required for the High Radiation Area.) As such, the candidates could have been misled by the question and responded '

with the items listed in Technical Specification 5.11.2. Due to the confusion created, this question should be deleted from the examination.

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