ML16214A301

05000338/2016301 and 05000339/2016301 Post Exam Comments

ML16214A301
Person / Time
Site:	North Anna
Issue date:	07/14/2016
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Catherine Haney Region 2 Administrator
References
15-612G
Download: ML16214A301 (36)

Text

VIRGum. ELEcTific AND PowER CoMPY RICHMOND, VIRGIISTIA 23261 July 14, 2016 Ms. Catherine Haney Serial No. 15-612G Regional Administrator NAPS/JHL U. S. Nuclear Regulatory Commission, Region II Docket Nos. 50-338 Marquis One Tower 50-339 245 Peachtree Center Ave., NE Suite 1200 License Nos. NPF-4 AtIanta, Georgia 30303-1257 NPF-7

Dear Ms. Haney:

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS I AND 2 OPERATOR LICENSE EXAMINATION COMMENTS On July 7, 2016, the written examination for initial reactor operator and senior reactor operator candidates was administered at North Anna Power Station. provides the information requested in NUREG-1 021, ES-501, Initial Post-Examination Activities, Section C.i.a. In addition, Attachment 2 provides comments on the operating examination for consideration. The attachments to this letter are being provided to Mr. Bruno Caballero, NRC Chief Examiner.

Prompt consideration of these comments and recommendations will assist in completing the license examination process.

If there ate any questions concerning this material, please contact Mr. Bill Stand ley at the North Anna Training Center, (540) 894-2446.

Very truly yours, Gerald T. Bischof Site Vice President Attachments Commitments made in this letter: None.

cc: Document Control Desk (without attachments)

U. S. Nuclear Regulatory Commission Washington, D. C. 20005 Mr. Eugene F. Guthrie, Chief (without attachments)

U. S. Nuclear Regulatory Commission, Region II Operator Licensing and Human Performance Branch Division of Reactor Safety Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. Bruno Caballero U. S. Nuclear Regulatory Commission, Region II Operator Licensing and Human Performance Branch Division of Reactor Safety Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector (without attachments)

North Anna Power Station

ATTACHMENT 2 OPERATOR LICENSE EXAMINATION COMMENTS VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS I AND 2

Post Exam Comments Simulator Scenario 4 Event number 5 (Letdown Leak)

Comment:

The requirement for entry into Tech Spec 3.6.1, Containment, due to a leak on the letdown line outside of containment, is incorrect.

Recommendation:

Facility recommends that the requirement for entry into T.S. 3.6.1 for inoperable containment be removed from the scenario.

Discussion:

The one hour action of T.S. 3.6.1 does not apply based on the leak was isolated by closing the inside containment isolation valve which prevents a release from occurring during an accident. T.S. 3.6.3 is the correct T.S. call for this failure based on inoperability of the outside containment isolation due to leak between the valve and containment. This is the position of the Supervisor of Nuclear Shift Operations (Senior License) and was concurred with through the licensing department.

Administrative JPM A.3 (Radiological Control)

Comment:

Either RWP Task may be selected for the work to be performed.

Recommendation:

Facility recommends that JPM step 1 not be critical and that the answer key should be changed to accept 2 answers for JPM step 2 depending on which RWP Task was chosen.

Discussion:

The JPM task is to determine the appropriate RWP Task and allowed stay time for locally operating the cold leg loop stop MOV. The initial conditions also stated that it will take 15 minutes to locally close the valve. Neither RWP Task would allow sufficient stay time to fully close the MOV but either RWP Task could have been used to perform the work. The dose rates at the MOV handwheel to be operated are $0 mR/hr. RWP Task 1 is for dose rates less than 100 mR/hr with a dose alarm of 10 mR and a dose rate alarm of 50 mR/hr.

RWP Task 2 is for dose rates greater than lOOmR/hr with a dose alarm of 20 mR and a dose rate alarm of 150 mR/hr. RWP Task 1 could be used with a change to the dose rate alarm that can be authorized by the HP supervisor in accordance with RP-AA-274 (Radiation Work Permits) step 5.16.5.d (attached). During administration of the JPM, multiple candidates asked questions concerning interaction with the HP supervisor.

JPM Step two would still be critical with two different answers based on which RWP task was selected. RWP Task 1 would have a stay time of 6 minutes. RWP Task 2 would have a stay time of 12 minutes.

Step two still has multiple critical elements needed to arrive at the correct answer:

1. Knowledge of equipment location. The cold leg stop was not labeled on the survey map

2. Ability to read a survey map

3. Ability to read and comply with an RWP. Candidate had to read RWP to determine they needed to leave the area at 80% of allotted dose.

4. Ability to calculate a stay time.

Revised JPM and answer key are attached.

Dominion North Anna Power Station ADMINISTRATIVE JOB PERFORMANCE MEASURE EVALUATION OPERATOR PROGRAM INITIAL CONDITIONS Unit 2 is shutdown. The A Cold Leg Loop Stop Valve MOV has stopped in mid-position and must be locally closed by the hand wheel.

The dose rates are shown on the attached Unit 2 Containment, 262 Elevation A Motor Cube.

It will take 15 minutes to locally close the valve; assume no dose is accumulated in transit to or from the work location.

Your accumulated dose this quarter is 300 mrem.

INITIATING CUE You are directed to determine the maximum stay time AND the correct RWP task number (16-2229-1 or 16-2229-2).

1. The correct RWP is

2. The maximum stay time is minutes.

Dominion North Anna Power Station ADMINISTRATIVE JOB PERFORMANCE MEASURE EVALUATION OPERATOR PROGRAM TASK Determine the following:

• Correct RWP and subtask

• Dose Alarm

• Dose Rate Alarm

• Stay Time (Maximum and Allowed by RWP)

TASK STANDARDS The operator determines the previously listed variables successfully.

KIA

REFERENCE:

GEN 2.3.7 (3.5/3.6)

ALTERNATE PATH:

N/A TASK COMPLETION TIMES Validation Time = 20 minutes Start Time =

Actual Time = minutes Stop Time =

PERFORMANCE EVALUATION Rating [ ] SATISFACTORY [1 UNSATISFACTORY Candidate (Print)

Evaluator (Print)

Evaluators Signature /

Date EVALUATORS COMMENTS 2016 NRC EXAM Page: 2 of 8 Admin JPM RadCon (ALL)

Dominion North Anna Power Station ADMINISTRATIVE JOB PERFORMANCE MEASURE (Evaluation)

OPERATOR PROGRAM READ THE APPLICABLE INSTRUCTIONS TO THE CANDIDATE Instructions for Simulator JPMs I will explain the initial conditions, and state the task to be performed. All control room steps shall be performed for this JPM, including any required communications. I will provide initiating cues and reports on other actions when directed by you. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.

Instructions for In-Plant JPMs I will explain the initial conditions, and state the task to be performed. All steps, including any required communications, shall be simulated for this JPM. Under no circumstances are you to operate any plant equipment. I will provide initiating cues and reports on other actions when directed by you. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.

INITIAL CONDITIONS Unit 2 is shutdown. The A Cold Leg Loop Stop Valve MOV has stopped in mid-position and must be locally closed by the hand wheel.

The dose rates are shown on the attached Unit 2 Containment, 262 Elevation A Motor Cube.

It will take 15 minutes to locally close the valve; assume no dose is accumulated in transit to or from the work location.

Your accumulated dose this quarter is 300 mrem.

INITIATING CUE You are directed to determine the maximum stay time AND the correct RWP task number (16-2229-1 or 16-2229-2).

2016 NRC EXAM Page: 3 of 8 Admin JPM RadCon (ALL)

EVALUATION METHOD Demonstration if conducted in the simulator or in a laboratory (use DEMONSTRATION cues)

Verbal-visual if conducted in the station or on a dead simulator (use VERBAL-VISUAL cues)

TOOLS AND EQUIPMENT RWPs, Survey Map, Calculator PERFORMANCE STEPS START TIME I From the RWPs provided determine which RWP is applicable for Procedure Step the job. RWP 16-2229-2 Critical Step ISAT[] UNSAT[J Standards I RWP 16-2229-2 is selected from the two RWPs provided.

Notes/Comments:

RWP 16-2229-I is not correct due to local dose rates would exceed the alarm setpoint.

RWP 16-2229-2 is the correct RWP and subtask.

2016 NRC EXAM Page: 4of8 Admin JPM RaUCon (ALL)

2 Determine the maximum stay time Procedure Step:

RWP 16-2229-2 Critical Step IST[] UNSAT[]

Standards If RWP Task I is selected then use the following calculation:

Operator uses RWP to determine dose alarm is set at 10 mRem.

Operator determines from the RWP (Worker Instruction #4 that the Operator must place the plant in a safe condition and leave the area once 80% of the dose alarm setpoint is reached.

Operator determines that they must leave the area after l6mRem of dose has been achieved. (80%

• 10 mRem = 8 mRem)

Operator uses survey map to determine general area dose rate is 80 mR/hr.

Operator then divides 8 by 80 to obtain a stay time of 6 minutes

(.10 hrs).

If RWP Task 2 is selected then use the following calculation:

Operator uses RWP to determine dose alarm is set at 20 mRem.

Operator determines from the RWP (Worker Instruction #4) that the Operator must place the plant in a safe condition and leave the area once 80% of the dose alarm setpoint is reached.

Operator determines that they must leave the area after l6mRem of dose has been achieved. (80%

• 20 mRem = 16 mRem)

Operator uses survey map to determine general area dose rate is 80 mR/hr.

Operator then divides 16 by 80 to obtain a stay time of 12 minutes

(.20 hrs).

Notes/Comments:

END OF EVALUATION 2016 NRC EXAM Page: 5 of 8 Admin JPM RadCon (ALL)

STOP TIME 2016 NRC EXAM Page:6of8 Admin JPM RadCon (ALL)

Answer Key

1. The correct RWP is 16-2229-2

2. The maximum stay time is RWP Task 1: 6 minutes (or the equivalent = .10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> or 1/10 hour), RWP Task 2: 12 minutes (or the equivalent .20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> or 1/5 hour).

2016 NRC EXAM Page: 7of 8 Admin JPM RadCon (ALL)

SIMULATOR, LABORATORY, IN--PLANT SETUP (If Required)

ADMINISTRATIVE JOB PERFORMANCE MEASURE TASK Determine appropriate RWP and subtask, Limits, and Stay Times based on various RWP limits.

CHECKLIST Survey Map Selection of RWPs for the candidate to chose from Calculator 2016 NRC EXAM Page: 8 of 8 Admin ]PM RaUCon (ALL)

Unit 2 Containment, 262 Elevation Verified Current By Date A Motor Cube Newtron Count Today Called North LDWA Low Dose Waiting Area I-WA Hot Particle Area CAM Continuous Air Monitor LHRA Locked High Radiation Area CA Contaminated Area 3 Frisking Station HRA High Radiation Area ARA Airborne Radioactivity Area RCAB Radiological Control Area Boundary RA Radiation Area RM Radioactive Material(s)

NDCR Neutron Dose Calculation Required All gamma and/or neutron D Gen Area; Contact; LCK Locked Gate; IX Barrier readings in mRem/hr unless noted.

RADIATION WORK PERMIT SUMMARV 16-2229 RP-AA-274 Afl. 2 PLANT CODE YEAR RWP NUMBER REV. RWP START TYPE CATEGORY RWP EXPIRATION 2 16 16-2229 0 0l-MAR-2016 00:00 S RM 31-MAY-2016 23:59 RWP DESCRIPTION

[ Routine duties. waikdowns and valve line-ups by Operations personnel.

DOSE ALARM DOSE RATE ALARM TIME INTERVAL TASK SuMMARY I Dose rates <100 mremAir Routine duties, waikdowns and valve line-ups by Operations 10 60 personnel.

2 Dose rates >100 mremffir Routine duties, waikdowns, and valve line-ups by Operations 20 150 personnel ALARA INFORMATION ALARA Review No. Hours-Esttmated Person-mrem 16-013 1999998 2845 SPECIAL INSTRUCTIONS:

Requirements for High Radiation Area Entry or Locked High Radiation Area:

-Notify HP Pnor to entry

-Sign In on an RWP that ALLOWS entry into a High Radiation Area or Locked High Radiation Area.

-Understand the ED Alarm set points and your response to a dose or dose rate alarm.

-Understand the radiological conditions fag. dose rates) In the area

-Monitor Electronic Dosimetry frequently. (Approximately every 15 minutes.)

-Notify RP upon exit.

Prepared By - Robert McNutt DATE: 0-2:0f Approved DATE: i c-i c RevIsed By DATE: Approved By DATE:

Terminated By DATE: Approved By DATE:

ORIGINAL Page 1

Task Number I OF 2 RP-M-274 AlT, 2 VALID FROM 0f.MAR-2016 00:00 TO 31*MAY*2016 23:59 RWP 16-2229-1 REV NO 0 DOSE RATE ALARM: ° rnremlHr BUDGETED DOSE: 245 mrem DOSE LIMIT ALARM: 10 mrom ALARA EVALUATION NO: 16013 JOB LOCATIONS:

Station Property excluding Unit I Reactor Containment.

JOB DESCRIPTION: Dose rates <100 mrenVhr Routine duties, walkdowns and valve line-ups byOperations personnel.

THE MAXIMUM POSTED AREATHAT CAN BE ENTERED:

Locked High Radiation Area VI RADIOLOGICAL CONDITIONS:*Indlcates estimated value for RWP Preparation. See survey forms for details GENERAL AREA RADIATION L.EVELS (mrernlhr):

See Radiological Status Boards or specific survey form.

CONTACT!HOT SPOT RADIATION LEVELS (mrem/hr):

See Radiological Stews Boards or sp,ecific survey form. V CONTAMINATION LEVELS (dpmll OOcm2):

See Radiological Status Boards or specific survey form.

AIRBORNE RADIOACTIVITY (DAC):

<.30 -

REQUIRED JOB COVERAGE:

ROUTINE COVERAGE COMMENTS:

1.0)Continuous coverage required fort 1.1) When loose surface levels are greater than 1,000,000dpm/lOOcm2 or area has known DRP5 greater than or equal to 100 mrem/hr on contact (open window).

• 1.2) When extremity dose rates are greater than 5,000 mrem/hr.

DOSIMETRY REQUIREMENTS: V ED/SRD TLD DOSIMETRY COMMENTS:

l.0)Caution: If PAM(ED) is utilized, ensure PAMfED) i V secured so that individual can feel the vibration if PAM(ED) alarms.

2.0)Notify HP prior to entry into a Neutron Exposure Area for additional dosimetry requirements.

ORIGINAL Page 2

Task Number I OP 2 RP-M-274AY1.2 PROTECTIVE CLOTHING REQUIREMENTS:

LAB COAT; SHOE COVERS & GLOVES MAY BE WORN FOR ANY NON-PHYSICAL ACTIVITIES f I.E. OBSERVATIONS OR EQUIPMENT CHECKS) AND CONTAMINATION LEVELS ARE LESS THAN 10,000 DPM/100CM2.

l.O)Required Protective clothing:

1.1) Surgeons Hood 1.l.l)Full hoods required in cavity, accessing over head in loop rooms, and when wearing communication devices/headsets.

l.2)One Pair Coveralls 1.3)Rubber Boots l.4)Higli Top Shoe Covers 1.5)Cotton Inserts l.6)One Pair Rubber Gloves 2.O)Protective Clothing requirements as stated are for entry into Contaminated Areas only.

3.0)Protective Clothing requireients for a Hot Particle Area (EPA) Un additibn to those stated above) are:

3.l)Hood, gloves, coveralls, high top shoe covers and rubber boots.

3.2)Workers interfacing with individuals/equipment in a EPA - Gloves and face shield.

ARWP PRE-JOB BRIEFING IS REQUIRED:

HRA BRIEF BYAN HP TECHNICIAN AND SIGN ATTENDANCE SHEET.

WORKER INSTRUCTtONS:

NOTE: ED dose rató alarm set-points are set conservatively at a low, yet feasible value for ALARA purposes. It is expected that some ED dose rate alarms may be received when dose rate alarm net-points are set below 100 mR/hr.

l.0)ED Alarms l.l)If ED dose rate alarm occurs,reposition yourself such that the alarm clears.

l.1.l)If ED dose rate alarm continues or three consecutive dose rate alarms occur, then leave area immediately and report to the HP Off ice l.2)If ED dose alarm occurs, then leave area immediately and report to the HP Office.

2.0)Do not enter High Radiation Areas without HP coverage or a ED with knowledge of work area dose rates.

3.0) Workers shall read their ED approximately every 15 minutes.

4.0)When 80% of the dose alarm set point is reached, leave work area in a safe condition and exit the RCA.

5.0)Workers are responsible for notifying the HP Supervisor prior to venting\draining systems, that may affect Radiological Conditions in an area, to ensure proper Health Physics Monitoring.

6.0)HPA exit instructions:

6.l)Use extreme care in removing PCs and frisking.

6.2)Workers are to be monitored by HP upon exiting the HPA.

6.3)Individuals exiting the HPA are to proceed directly to the RCA exit to perform whole body monitoring.

6.4)Workers are to be monitored by HP-after interfacing with workers/equipment in a HPA.

7.0)00 not remove any items from a posted Hot Particle Area until authorized by HP-Ops.

8.0)Remote telemetrics dosimetry shall be used for workers entering containment when available.

9.0)If telemetric ED is used then check in with HP after the telemetric ED has been issued to verify that it is transmitting properly.

lO.0)Notify Health Physics prior to setting up any ladder.

ll.O)Notify HP prior to entry in overhead areas greater than 8 feet.

12.O)Prior to returning Electronic DosimetryCED), all individuals shall process through the FDA for wiole body monitoring. This is not reguired.if returning ED solely for the purpose of changing RWFs.

HEALTH PHYSICS INSTRUCT1ONS:

This RU? authorizes work in an ALPHA Level II area.

ORIGINAL . Page 3

Task Number I OF 2 RP-M-274 ATT. 2 l.0)Stop work and leave area if whole body dose rates exceed 100 mRem/hr.

l.l)If ED dose rate alarm equals the stop work dose rate, then DO NOT authorize worker to work through an alarm.

2.0)Hot Particle Area (HPA) monitoring requirements:

2.1) Workers exposed skin shall he monitored by HP-Ops every four hours (unless specified by the HP Supervisor) while the workers are, in the HPA.

2.2)Personnel monitoring for workers exiting the HPA will consist of a whole body scan witnin 1/2 inch using a RO-2 or equivalentfopen window)with background less than 1.0 mrem/hr.

2.3)Worker release criteria: a net reading of less than 2.0 mrem/hr.

2.4)Instruct all individuals exiting the HPA to proceed directly to the RCA exit to perform whole body monitoring.

ORIGINAL Page 4

Task Number 2 OF 2 RP-M-274 AlT. 2 01-MAR.2016 00:00 3f-MAY-2016 23:59 RWP 16-2229-2 REV. NO 0 VALID FROM TO DOSE RATE ALARM: ° mrem/Hr BUDGETED DOSE: 2600 mrem DOSE LIMIT ALARM: 20 mrem ALARA EVALUATION NO: 16013 JOB LOCATIONS:

STATION PROPERTY EXCLUDING U-I CONTAINMENT JOB DESCRIPTION: Dose rates >100 mremThr: RoutIne duties. walkdowTls, and valve line-ups by Operations personnel THE MAXIMUM POSTED AREATHAT CAN BE ENTERED:

Locked High RadiatIon Area I I RADIOLOGICAL CONDITIONS:1ndlcates estimated value for RWP Preparation. See survey forms for details GENERAL AREA RADIATION LEVELS fmremlhr):

See Radiological Status Boards or specific survey form CONTACTIHOT SPOT RADIATiON LEVELS (mremlhr):

See Radiological Status Boards or specific survey form CONTAMINATION LEVELS (dpm!lOOcm2):

See RadIological Status Boards or specific survey form AIRBORNE RADIOACTIVITY (DAC):

<.30 REQUIRED JOB COVERAGE:

ROUTINE COVERAGE COMMENTS:

1.0)Continuous HP coverage required for:

1.1) When loose surface levels are greater than 1,000,000 dpm/lOOcm2 or area has known DRPs greater than or equal to 100 mrem/hr on contact (open window).

1.2)When extremity dose rates are greater than 5,000, mrem/hr.

OOS1METRY REQUIREMENTS:

EDISRD - CD DOSIMETRY COMMENTS:

1.0 )Caution

If PAM(ED) is utilized, ensure PANtED) is secured so that individual can feel the vibration if PAM (ED) alarms.

2.0)Notify HP prior to entry into a Neutron Exposure Area for additional dosimetry requirements.

ORIGINAL Page 5

Task Number 2 OF 2 RP-AA274 AlT 2 PROTECTiVE CLOTHING REQUiREMENTS:

LAB COAT, SHOE COVERS & GLOVES MAY BE WORN FOR ANY NON-PHYSICAL ACTIVITIES (I.E. OBSERVATIONS OR EQUIPMENT CHECKS) AND CONTAMINATION t,EVELS ARE LESS THAN 10,000 DPM/IOOCM2.

l.0)Required Prtective clothing:

l.l)Surgeons Hood l.1.1)Full hoods required in cavity, accessing over head in loop rooms, and when wearing communication devices/headsets.

1.2)One Pair Coveralls 1.3)Rubber Boots 1.4)High Top Shoe Covers l.5)Cotton Inserts 1.6)One Pair Rubber Gloves 2.0)Protective Clothing requirements as stated are for entry into Contaminated Areas only.

3.0)Protective Clothing requirements for a Not Particl Area (EPA) tin addition to those stated above] are:

3.l)Hood, gloves, coveralls, high top shoe covers and rubber boots.

3.2) Workers interfacing with individuals/equipment In a HPA - Gloves and face shield.

A RWP PRE-JOB BRIEFiNG IS REQUIRED:

HRA BRIEF BYAN HP TECHNICIAN AND SIGN ATTENDANCE SIEET.

WORKER INSTRUCTIONS:

1.0)ED Alarms:

l.l)If ED dose rate alarm occurs, THEN leave area immediately and notify HP (unless authorized by HP Supervisor and have been briefed on proper responses).

l.2)If ED dose alarm occurs, THEN leave area immediately and report to the Health Physics office.

2.0)130 not enter High Radiation Areas without HP coverage or a ED with knowledge of work area dose rates.

3.0) Workers shall read their ED approximately every 15 minutes.

4.0)Wlien 80s of the dose alarm set point is reached, leave work area in a safe condition and exit the RCA.

5.0) Workers are responsible for notifying the HP Supervisor prior to venting\draining systems, that may affect Radiological Conditions in an area, to ensure proper Health Physics Monitoring.

6.0)HPA exit instructions:

6.l)Uee extreme care in removing ?Cs and frisking.

6.2) Workers are to be monitored by HP upon exiting the HPA.

6.3)Individuala exiting the EPA areto proceed directly to the RCA exit to perform whole body monitoring.

6.4)Workers are to be monitored by HP after interfacing with workers/equipment in a HPA.

7.0)Do not remove any items from a posted Hot Particle Area until authorized by HP-Ops.

S.O)Notlfy Health Physics prior to setting up any ladder.

9.O)Notify HP prior to entry in overhead areas greater than 8 feet.

l0.0)Remote telemetrics dosimetry shall be used for workers entering containment when available.

ll.O)If telemetric ED is used then check in with HP after the telemetric ED has been issued to verify that it is transmitting properly.

12.0) Prior to returning Electronic DosimetryCED), all individuals shall process through bhe PDA for whole body monitoring. This is not required if returning ED solely for the purpose of changing RWPs.

HEALTH PHYSICS INSTRUCTiONS:

This RWP authorizes work in an ALPHA Level XI area.

l.0)Stop work and leave area if whole body dose rates exceed 3000 mRem/hr.

2.0)When the ED dose rate alarm is set >1000 mRem/lir then:

2.l)Stay times and continuous HP coverage is required.

ORIGINAL Page

Task Number 2 OF 2 RP-M-274 ATT. 2 3.0)Mot Particle Area (HPA) monitoring requirements:

3.l)Workers exposed skin shall be monitored by HP-Ops every four hours (unless specified by the HP Supervisor) while the workers are in the HPA.

3.2)Personnel monitoring for workers exiting the HPA will consist of a whole body scan witnin 1/2 inch using a RO-2 or equivalent (open window) with background less than 1.0 mrem/hr.

3.3)Worker release criteria: a net reading of less than 2.0 mrem/lir.

3.4)Instruct all individuals exiting the HPA to proceed directly to the RCA exit to perform whole body monitoring.

) )

ORIGINAL Fage 7

DOMINION RP-AA-274 Nuclear Fleet Technical Procedure Revision 5 Page 33 of 55 5.16.5 WHEN RWP task and/or HRA briefing is complete, THEN PERFORM the following:

a. ENSURE each worker records the required entries on Attachment 5, Briefing Attendance Roster.

b. ENTER initials on Attachment 5 under Briefed By.

c. IF HRA Briefing was checked in HIS-20, THEN ENSURE workers Plant ID is entered in HIS-20 under the appropriate task.

NOTE: Modifying ED dose and/or dose rate alarm setpoints require RP supervisor approval.

When worker Plant IDs are entered in the HIS-20, individual dose and dose rate alarm setpoints may be revised. If settings are not revised, HIS-20 will automatically set dose and dose rate alarms based on RWP task values.

ED dose rate alarms are never set above stop work dose rates.

d. IF an individuals ED dose and/or dose rate alarm setpoints are to be modified from the RWP default values, THEN PERFORM the following:

1. ENSURE desired alarm settings are recorded on Attachment 5.

2. ENSURE worker acknowledges set points by signing Attachment 5.

3. ENSURE RP supervisor signs on Attachment 5 under Briefed By.

4. ENSURE alarm settings are entered in the HIS-20.

INFORMATION USE

Administrative JPM A.4 (PAR Update)

Comment:

Reporting of previously reported sectors on a PAR update is not critical.

Recommendation:

Facility recommends that the answer key be modified to make reporting of the previous affected sectors not critical.

Discussion:

The PAR JPM was administered as a time critical JPM. A post exam review has identified flaws in the manner in which the JPM was administered that adversely impacted candidate performance.

An Initial Condition of the JPM was that the TSC was not yet manned (implying that no turnover of SEM duties had occurred).

Another Initial Conditions of the JPM was EPIP 1.06, Protective Action Recommendations, was entered and a PAR was issued. The previously completed EPIP-1.06 and PAR paperwork are provided for your review; however the start time of the JPM began prior to the candidates performing a thorough review of the procedure and paperwork.

The JPM task initiating cue was perform EPIP-1.06, beginning at Step 11 (a marked up copy of an already in progress procedure).

Given the manner in which the JPM was administered the candidates were placed in the role of assuming SEM duties (the updated PAR to be given was message number three, one hour and 15 minutes following the first General Emergency declaration). We say placed in the role, because as previously stated, if they were the SEM from the onset of the event (i.e. Shift Manager who has not yet been relieved since the TSC is not manned) they would have full knowledge of all activities, communications, and conditions up to that point.

To assume the duties and responsibilities of the SEM a turnover is required.

NUREG-0654 requires that facilities have turnover processes in place. EPIP 1.01 Attachment 2 is the facility guidance that implements the NUREG requirement and is required to be completed prior to assuming the duties of the SEM. The candidates were placed in the awkward position of assuming a duty in a manner contrary to both their training and the procedures of the facility. The candidates spent a significant amount of time reviewing, getting up to speed with what had transpired because they realize the importance of accuracy in classifying, communicating, & reporting and wanted to make sure they thoroughly understood the situation at hand.

The candidates were told to start at step 11 of EPIP-1.06. This step loops you back to step 7.

By strict procedural compliance they check the box for Average Wind Direction Shifts To Any New Area(s) and go to Step 17. If the candidates were given time to review the previous steps performed (as would be the case during turnover in a real emergency) they would have reviewed the entire procedure and worked through the procedural difficulties to arrive at the step that requires previous sectors to be included.

A note before step 17 of EPIP-1.06 states: NOTE: A new PAR is only issued for wind shifts, based on the conditions below, in new affected sectors that have NOT been included in a previous PAR. CR1041252 was submitted to enhance the procedure.

RIS 2003-12 Clarification of NRC Guidance for Modifying PARS was reviewed. This RIS was issued based on a utility modified PAR that decreased the effectiveness of a PAR. This utility changed a previous PAR from evacuate to shelter. The updated PAR conflicted with the previous PAR. NAPS EPIP 1.06 has a caution that does not allow downgrading of previous PARS without consultation with the State. The critical step is to identify new sectors affected and make the correct recommendation for those sectors. The updated PAR did not modify the initial PAR provided for the omitted sectors.

The proposed answer key that includes these comments is attached.

Dominion North Anna Power Station JOB PERFORMANCE MEASURE EVALUATION OPERATOR PROGRAM INITIAL CONDITIONS At 1330, the SEM declared a General Emergency SG-1 .1 for a Station Blackout At 1400, the SEM declared a General Emergency FG-1.1 Classification was declared on Unit 1 EPIP 1.06, Protective Action Recommendations, was entered and a PAR was issued.

The previously completed EPIP-1 .06 and PAR paperwork are provided for your review.

The time is now 1445 minutes and current conditions are:

• Unit 1: Conditions unchanged

• Unit 2: Conditions unchanged

• TSC is still not operational

• Meteorological Data o Wind Speed25 mph o Wind Direction 280° INITIATING CUE You are requested to perform EPIP-1 .06, beginning at Step 11 Portions of this JPM are time critical.

Dominion North Anna Power Station JOB PERFORMANCE MEASURE EVALUATION OPERATOR PROGRAM TASK Determine updated protective action recommendations (EPI P-i .06).

TASK STANDARDS Task was performed as directed by the procedure referenced in the task statement within parentheses (one of the underlined procedures if several are cited)

KIA

REFERENCE:

GEN-2.4.44 (2.1/4.0)

ALTERNATE PATH:

N/A TASK COMPLETION TIMES Validation Time = 15 minutes Start Time =

Actual Time = minutes Stop Time =

PERFORMANCE EVALUATION Rating [1 SATISFACTORY [ ] UNSATISFACTORY Candidate (Print)

Evaluator (Print)

Evaluators Signature /

Date EVALUATORS COMMENTS

Dominion North Anna Power Station JOB PERFORMANCE MEASURE (Evaluation)

OPERATOR PROGRAM READ THE APPLICABLE INSTRUCTIONS TO THE CANDIDATE Instructions for Simulator JPMs I will explain the initial conditions, and state the task to be performed. All control room steps shall be performed for this JPM, including any required communications. I will provide initiating cues and reports on other actions when directed by you. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.

Instructions for In-Plant JPMs I will explain the initial conditions, and state the task to be performed. All steps, including any requited communications, shall be simulated for this JPM. Under no circumstances are you to operate any plant equipment. I will provide initiating cues and reports on other actions when directed by you. Ensure you indicate to me when you understand your assigned task. To indicate that you have completed your assigned task return the handout sheet I provided you.

PREREQUISITES The trainee has completed the applicable course knowledge training at the senior reactor operator level.

INITIAL CONDITIONS At 1330, the SEM declared a General Emergency SG-1 .1 for a Station Blackout At 1400, the SEM declared a General Emergency FG-1.1 Classification was declared on Unit 1 EPIP 1 .06, Protective Action Recommendations, was entered and a PAR was issued.

The previously completed EPIP-1 .06 and PAR paperwork are provided for your review.

The time is now 1445 minutes and current conditions are:

• Unit 1: Conditions unchanged

• Unit 2: Conditions unchanged

• TSC is still not operational

• Meteorological Data o WindSpeed25mph o Wind Direction 2800 INITIATING CUE You are requested to perform EPIP-1 .06, beginning at Step 1 1 Portions of this JPM are time critical.

EVALUATION METHOD Perform if conducted in the simulator or in a laboratory (use Performance Cue(s))

Simulate if conducted in the station or on a dead simulator (use Simulation Cue(s))

TOOLS AND EQUIPMENT None PERFORMANCE STEPS START TIME

1 CHECK THE FOLLOWING: Procedure Step Z Average wind direction shifts to any new area(s) (refer to ATTACHMENT 2, AFFECTED SECTOR(S) MAP)

Critical Step SAT[] UNSAT[J Standards SRO notes that wind direction has shifted and proceeds to step 17 Notes/Comments 2 UPDATE ATTACHMENT 2, AFFECTED SECTOR(S) MAP: Procedure Step j

• Record time wind data acquired

• Record average wind direction from, in degrees Record average wind speed in mph

• Record affected sectors

• Mark new area(s) affected on map (use distinguishable markings from previous markings):

• Include all downwind sectors from previous PARs for this event AND

• All new downwind sectors for the PAR AND

• Any downwind sectors through which the wind shift occurred

Standards Attachment 2 is updated (See KEY)

Notes/Comments 3 - COMPLETE PROTECTIVE ACTION RECOMMENDATION: Procedure Step a) Complete ATTACHMENT 3, REPORT OF PROTECTIVE ACTION RECOMMENDATION

1) Mark appropriate PAR box(s)

2) Record Mile radius and Miles downwind

3) Record Downwind Sectors

4) Record Potassium Iodide (optional)

5) Record Remarks (optional)

6) Approve PAR (sign report)

7) Record date and time report approved SAT[] UNSAT[]

Critical Step SAT[] UNSAT[J Standard Attachment 3 is completed with updated data (See KEY)

Notes/Comments The new PAR has evacuated Sectors D and E to the 10 mile downwind (Sectors F, G, and H are still included from the original PAR.

4 DIRECT EMERGENCY COMMUNICATORS TO NOTIFY Procedure Step j OFF-SITE AUTHORITIES OF PAR:

Virginia Emergency Operations Center (VEOC) notified lAW:

EPIP-1 .06, PROTECTIVE ACTION RECOMMENDATIONS Critical Step SAT[] UNSAT[]

Standards Completed within 15 minutes.

Notes/Comments

>>>>> END OF EVALUATION <<<<<

STOP TIME

KEY NUMBER ATTACHMENT TITLE ATTACHMENT EPIP-1.06 3 REPORT OF PROTECTIVE ACTION RECOMMENDATION REVISION PAGE 11 lofi PAR MESSAGE# 3 NOTE:

• Transmit to Virginia EOC only using the VEOC ARD.

• IF VEOC ARD nonfunctional, THEN use VEOC autodial or direct dial (804) 674-2400 or (804) 310-8868.

• IF all means of communications with VEOC nonfunctional, THEN use lnsta-Phone.

This is North Anna Power Station with a(n) Drill Message gEmergency Message for Protective Action Recommendation. Use the Report of Protective Action Recommendation form to copy this message.

(READ SLOWLY)

PROTECTIVE ACTION RECOMMENDATION:

SHELTER-IN-PLACE: Mile radius 360° and Miles downwind in the following sectors:

CRITICAL STEP VACUATE: .__ Mile radius 360° and JQ Miles downwind in the following sectors: DATA D,E,F,G,H .Additional Sectors D & E are the only E BEYOND 10 MILE EPZ:

critical step data Evacuate Area: Centerline in degrees; in Miles; Width in feet LI Shelter-in-place: Centerline in degrees; in Miles; Width in feet LI POTASSIUM IODIDE:

Recommend implementation of Potassium Iodide (KI) strategies for the general public.

The projected dose at the site boundary is > 5 Rem Thyroid CDE.

The time is (24-hr time).

This is

/ Emergency Communicator.

Message received by: Virginia EOC Watch Officer (name)

This is North Anna Power Station out at (24-hr time) on (date).

REMARKS (OPTIONAL) I APPROVAL INFORMATION [DO NOT READ]

NOTE: Shelter-in-Place may be recommended as a result of evacuation impediments (e.g., Hostile Action events) or other known conditions which make evacuation dangerous.

REMARKS:

APPROVED BY: Signature Todays Date i Current Station Emergency Manager or Recovery Manager Date Time Signature, Date and Time are CRITICAL STEP DATA. Time must be within 15 minutes of start time.

KEY

BIRT Report Viewer Page 1 of4 Condition Report Details Site: North Anna CR1041252 NANN Discovery Date: 06/28/2016 01:13 PM Type: NCAQ Date Reported: 06/28/2016 01:13 PM Status: ASSIGNPEND Revision: 0 DescriDtion:

enhancements to EPIP-1.06 and 4.07 Lona DescriDtion:

1. EPIP-l.06 step 12 states Go to step 12. This is a typo. It should state go to step 21 for EPIP termination. 2. EPIP-1.06 and EPIP-4.07 state; IF PAR change required due to wind shift, THEN new PAR must include the following downwind sectors:

• All downwind sectors from previous PARs for this event AND

• All downwind sectors for the new PAR AND

• All downwind sectors through which the wind shift occurred Attachment 3 of both EPIP procedures for documenting and notifying the State EOC of a PAR change for the change in wind direction does not make it clear that previous downwind sectors should be noted.

Initial Actions:

Notified EPIP group Locations and Programmatic Indicators Location: Safety Qual Class: Seismic: EP Cat A:

EQ Related: Component Class: BDB:

Reg 1.97: PRA: B.5.b.:

Plant System: App R: HELE:

Local System(Mill Only):

Locations and Assets Screening Significance Potential Repeat? Previous Issue Notes CRT Comments; Assignments Type CR Asgmt # Site Assignd Dept Due Date Pri DCAC Eval Status DTI CA3034756 NANN EP 12/14/2016 TYLER52 ]0HN249 INPROG Evaluate CR1041252s recommended changes to NAPS EPIP5 1.06 & 4.07 5.2 WO WO #: Status Date:

Work Actual Finish Performed: Date:

Previous CAP #:

Related CR / LC / P1 Site Related Record # CR Type Class Discovery Date Status Related Assignments / Work Orders Site Related Record # Work Type Class Status Screening Questions BACC Questions N SAFETY (Nuclear, Industrial, or Radiological) ?

Is this CR associated with Boric Acid Corrosion Control Program Y/N N PLANT EQUIPMENT Systems, Structures, Components Is the boric acid wet, glistening, moist or dripping? (ER-AP (SSC) related to BAC-lOl)

N ENVIRONMENTAL (Deficient equipment or conditions Is the boric acid deposit excessive? (ER-AB-BAC-lOl) that challenge compliance with envionmental regulations)

N REGULATORY COMPLIANCE Is the boric acid discolored (e.g., non-white) or is there any visible degradation? (ER-AP-BAC-lOl)

N Does this report identify a human performance, Does the boric acid appear to originate from a crack, a pinhole document, or process issue or documented trend that leak or through a welded connection? (ER-AP-BAC-lOl) http ://pamsrpt.dominionnet.com/maximo/output?_reportdomCRCRABundle.rptdesign... 7/14/2016

BIRT Report Viewer Page 2 of 4 challenges: SAFETY, PLANT EQUIPMENT, ENVIRONMENTAL OR REGULATORY COMPLIANCE?

Does the boric acid appear to come from under insulation or has it run under insulation or is the source of leak unknown?

fEP-AP-BAC- 101)

User Information Reported By: JAME272 Submitters Dept: Training Changed By: ]0HN249 Jim Crossman (Generation - 3) John Costello (Generation 6)

Email: jim.crossman@dom.com Supervisor: PATRI69 Changed 06/29/2016 10:21 AM Date:

Phone: Patty Ignaszewski (Generation 3) -

Reported Date: 06/28/2016 01:13 PM Trends - Affected Department Site Affected Dept Description Trends Multiple CR Flags CR FLag Description Trends Multiple Station PO&C POC # Description Trends - Classifications Trend Classification Class Description Comments Work Logs Date Class Log Type Created By Description Condition Report Status History Date Status Modified By Memo 06/29/2016 10:21 AM ASSIGNPEND ]0HN249 06/29/2016 09:55 AM DEPTREV PATRI69 06/28/2016 01:18 PM SUPRREV ]AME272 06/28/2016 01:13 PM DRAFT ]AME272 CR Assignment Details North Anna CA3034756 Assignment DTI Status: INPROG Type:

Created 06/29/2016 Due Date: 12/14/2016 Assigned EP Date: Dept:

Short

Description:

Evaluate CR1041252s recommended changes to NAPS EPIP5 1.06 & 4.07 Detailed Assignment: Evaluate CR1041252s recommended changes to NAPS EPIP5 1.06 & 4.07: 1.

Change EPIP-1.06 step 12 from GO TO STEP 12 to GO TO STEP 21 apparent -

transposition error. 2. Change EPIP-1.06 and EPIP-4.07 Attachments 3, Report of Protective Action Recommendation, to make it clear that previous downwind sectors should be noted for a PAR changed due to a change in wind direction (reference EPIP-1.06 Step 17.f & EPIP-4.07 Attachment 1 Step 3 (RNO)).

Response: The first recommended change was to correct an apparent transposition error where NAPS EPIP-1.06 Step 12 directed the user to GO TO STEP 12. This error existed since Revision 11 became effective on 12/22/20 14. Comparison with Surrys EPIP-1.06 Revision 11 validated the statement in the parent condition report suggesting that the appropriate transition should have been to Step 21. This error was corrected by issuance of EPIP-1.06 Revision 12, which became effective on The second recommended change was to enhance EPIP-1.06 and EPIP-4.07 by modifying Attachments 3, Report of Protective Action Recommendation, to make it clear that previous downwind sectors should be noted for a PAR changed due to a change in wind direction. EPIP-1.06 Revision 12 refers to EPIP-4.07 for evaluation of wind shifts where previous revisions allowed this evaluation by either procedure. No change was made to EPIP-1.06 or EPIP-4.07 http ://pamsrpt.dominionnet.com/maximo/output? report=domCR_CRABundle.rptdesign... 7/14/2016

BIRT Report Viewer Page 3 of 4 Attachments 3, but PAR development instructions in EPIP-4.07 Revision 24 (effective date address carrying forward or superseding the PAR in-effect.

DCAC: TYLER52 Tyler A Swearingen Priority:

(Generation 6) -

Evaluator: J0HN249 John Costello (Generation LTCA:

- 6)

Supervisor: ED00001 James E Collins Pre-Staged?: Y (Generation 6) -

Manager: ED00001 James E Collins Manager Review N (Generation 6) - Required?:

No Assignment information in this section CR Information CR# : CR1041252 enhancements to EPIP-1.06 and 4.07 Long

Description:

1. EPIP-1.06 step 12 states Go to step 12. This is a typo. It should state go to step 21 for EPIP termination. 2. EPIP-1.06 and EPIP-4.07 state; IF PAR change required due to wind shift, THEN new PAR must include the following downwind sectors:

• All downwind sectors from previous PARs for this event AND

• All downwind sectors for the new PAR AND

• All downwind sectors through which the wind shift occurred Attachment 3 of both EPIP procedures for documenting and notifying the State EOC of a PAR change for the change in wind direction does not make it clear that previous downwind sectors should be noted.

CRT Comments:

Site: NANN Discovery Date/Time: 06/28/2016 01:13 PM Significance:

Parent CRA #:

Locations and Programmatic Indicators Location: Safety Qual Seismic: EP Cat Class: A:

EQ Related: Component BDB:

Class:

Plant System: Reg 1.97: PRA: B.5.b.:

App R: HELB:

Local System (Mill only):

Additional Reviews Additional Review Additional Review Group 1: Person 1:

Additional Review Additional Review Group 2: Person 2:

Additional Review Additional Review Group 3: Person 3:

Assignment Extensions EXT # Requester Reason Requested Request Extension Ext Date Date Status

1. of APPR EXT Follow-On Assignments http ://pamsrpt.dominionnet.com/maximo/output?_reportdomCR_CRABundle.rptdesign... 7/14/2016

BIRT Report Viewer Page 4 of 4 Asgnmnt Type CR Asgn # Site Asgn Dept Due Date Priority DCAC Eval Status Related CR I LC / P1 Site Related Record # CR Type Description Class Discovery Date Status Relationship Related Assignments I Work Orders Site Related Record # Work Type Description Class Status Relationship Work Log Date Record Class Created By Summary User Information Created By: J0HN249 Changed By: TYLER52 John Costello (Generation - 6) Tyler A Swearingen (Generation 6)

Created Date: 06/29/2016 1003 AM Changed Date: 06/29/2016 10:24 AM CR Assignment Status History Date Status Modified By Memo 06/29/2016 10:24 AM INPROG TYLER52 06/29/2016 10:22 AM WASSIGN MAXADMIN 06/29/2016 10:01 AM DRAFT ]0HN249 Report Version 3.1 05/16/2016 Report Version 3.1 05/16/2016 07/14/2016 09:39:16 1 / 1 http ://pamsrpt.dominionnet.comlmaximo/output?_report=domCR_CRABundle.rptdesign... 7/14/2016