ML081770473

May Examination 05000369 and 05000370/ 2008-301 Facilities Post-Examination Comments (Part 2 of 2)

ML081770473
Person / Time
Site:	McGuire, Mcguire
Issue date:	06/25/2008
From:	NRC/RGN-II
To:	Duke Energy Carolinas
References
50-369/08-301, 50-370/08-301
Download: ML081770473 (63)

Text

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 1 of 78 Rev. 9 UNIT 1 i A. Purpose The purpose of this procedure is to identify actions required in the event of a loss of KC, or leakage on the KC System.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 2 of 78 Rev. 9 UNIT 1 ACTI ON /E X PE C T E D ~ RE SP ON SE ~ ESP O NS E NOT OBTAI NED I

B. Symptoms

• "LO KC HX A INLET FLOW" computer alarm

• "LO KC HX B INLET FLOW" computer alarm

• Low flow alarms on components supplied by KC

• High temperature alarms on components supplied by KC

• Low level or level going down in KC Surge Tank

• Abnormal KC pump Flow

• "LO KC SURGE TANK COMPARTMENT A LEVEL" computer alarm

• "LO KC SURGE TANK COMPARTMENT B LEVEL" computer alarm

• "KC SURGE TANK ABNORMAL LEVEL" alarm.

C. Operator Actions

1. Check any KC pump - ON. Perform the following:

a. Isolate:

• Normal letdown

• Excess letdown

• NO letdown.

b. Close all NM valves located on 1MC-8 (vertical board).

2. Monitor Foldout page.

3. Secure any dilution in progress.

4. Check ND -IN RHR MODE. _ GO TO Step 7.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/N5500/21 3 of 78 Rev. 9 UNIT 1 ACTION/EXPECTED RESPONSE ~ESPONSE NOT OBTAINED

5. Check any KC pump - ON. Isolate containment as follows:

a. Announce the following on page:

_ 1) Description of event.

_ 2) "All personnel evacuate Unit 1 containment. "

b. Actuate containment evacuation alarm.

c. REFER TO RP/o/N5700/011 (Conducting a Site Assembly, Site Evacuation, or Containment Evacuation) while continuing with this procedure.

d. IF PT/1/N4200/002 C (Containment Closure/Integrity) in effect, THEN notify Containment Closure Coordinator to initiate containment closure.

e. GO TO Step 8.

6. IF AT ANY TIME all KC pumps are off, THEN RETURN TO Step 5.

7. Announce occurrence on paging system.

8. Check both train's KC Surge Tank level - _ IF Surge Tank level trend indicates a KC STABLE OR GOING UP. System leak, THEN GO TO Step 11.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/AJ5500/2 1 4 of 78

, Rev . 9 UNIT 1 ACTI ON/EXPE CTED RES PONSE RES PONSE NOT OBTA I NED

9. Start standby KC train as follows :

a. Check standby KC train - AVAILABLE a. Perform the following:

TO START.

1) IF any KC pump runn ing, THEN perform the following as necessary to maintain KC flow less than 4000 GPM per operating KC pump:

_ a) Maintain cooling water to critical heat loads.

CAUTION If NO in RHR and NC temperature is greater than 200°F, then KC flow must be maintained greater than 2000 GPM to operating NO train.

_ b) Evaluate throttling KC to NO HX .

_ c) Evaluate throttling KC to KF HX .

_ d) Evaluate raising RN flow to KC HX to lower KC temperature.

_ e) Evaluate reducing NV letdown to 45 GPM .

_ f) IF necessary to reduce KC flow ,

THEN notify Radwaste Chemistry to ensure NB evaporator is shutdown .

g) IF AT ANY TIME it is desired to restart tripped KC pump , THEN:

_ (1) Start desired KC pump.

_ (2) Exit this procedure .

_ 2) Do not continue until KC train available to start.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1 /A/5500 /21 5 of 78 Rev. 9 UN IT 1 I ACTI ON /E XPECTED RESPONSE .. ~, I I ~ E S PO NS E NOT OBTAI NED I

9. (Cont inued)

b. Check standby KC Surge Tank Level - b. Perform the following:

GREATER THAN 2 FT.

1) Initiate YM makeup to KC Surge Tank as follows :

a) Dispatch operator to open the following valves as required to maintain KC Surge Tank level:

• To makeup to 1A KC Surge Tank , unlock and open 1KC-1 07 (1A KC Surge Tan k Compartment YM Supp ly Isol)

(aux bldg , 767 +2, JJ-57 ,

under grating, between KC surge tanks)

• To makeup to 1B KC Surge Tank , unlock and open 1KC-111 (1B KC Surge Tank Compartment YM Supply Isol )

(aux bldg, 767+2, JJ-58 ,

under grating, between KC surge tanks).

_ b) Adjust makeup rate as required to prevent overflow of KC Surge Tank (approximately 8.5 ft).

_ 2) IF AT ANY TIME it is determined that YM makeup is inadequate, THEN align RN Makeup to KC PER Enclosure 3 (Aligning RN Makeup to KC Surge Tank) as required.

_ 3) Do not continue until surge tank level is greater than 2 ft.

c. Start standby KC train PER one of the following :

_ . To start A Train , GO TO Enclosure 4 (Startup of 1A KC Train)

OR

• To start B Train, GO TO Enclos ure 5 (Startup of 1B KC Train).

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500/21 60f78 Rev. 9 UNIT 1 I ACTI ON/ EXPECTED RESPONSE

I I RES PONSE NOT OBTA I NE D I

10. GO TO Step 41.

11. Initiate YM makeup to KC Surge Tank as follows:

a. Immediately dispatch operator to open the following valves as required to maintain KC Surge Tank level :

• To makeup to 1A KC Surge Tank, unlock and open 1KC-1 07 (1A KC Surge Tank Compartment YM Supply Isol) (aux bldg , 767+2 , JJ-57, under grating , between KC surge tanks)

• To makeup to 1B KC Surge tank ,

unlock and open 1KC-111 (1B KC Su rge Tank Compartment YM Supply Isol) (aux bldg , 767+2 , JJ-58, under grat ing , between KC surge tanks).

b. Adjust makeup rate as required to prevent overflow of KC Surge Tank (approximately 8.5 ft).

12. Dispatch operators to locate leak.

13. Check KC drain tank pump- OFF. Perform the following:

a. Dispatch operator to check KC drain tan k level locally.

b. IF abnormal inputs to KC drain tank suspected, THEN reference MCFD-1573 series (Flow Diagram of Component Cooling System) for possible leak on KC drain and relief headers.

14 . IF AT ANY TIME it is determined that YM makeup is inadequate to restore or stabilize KC surge tank level, THEN immediately align RN Makeup to KC PER Enclosure 3 (Aligning RN Makeup to KC Surge Tank) as required.

MNS LOSS OF KG OR KG SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 7 of 78 Rev. 9 UNIT 1  !

ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

15. Check both train's KC surge tank level* _ GO TO Step 20.

GREATER THAN 3 FT.

NOTE

• The following OAG points may be used to determine level drop in next step.

These points are also displayed on the KG system graphic:

• M1P1317 (1A Train KG surge tank level rate)

• M1P1318 (1B Train KG surge tank level rate) .

• A 0.10 ft/min level drop in one train's surge tank equals approximately 50 GPM leak.

16. Check sum of bothtrains' KC surge tank _ IF level is dropping faster than 0.10 level drops - LESS THAN OR EQUAL TO ftImin, THEN GO TO Step 20.

0.10 FT/MIN.

NOTE The next step allows maintaining current KG system alignment for small leaks that should be within the capacity of normal makeup. Allowing level to drop to 2 ft allows more time for operators to locally align makeup, prior to taking action to isolate KG headers.

17. Do not continue until at least one of the following occurs:

_ . KG makeup has been locally opened from RN.

OR

_ . Either train's KG Surge Tank level is less than or equal to 2 ft.

OR

• Both KG surge tank levels are stable or going up.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 8 of 78 Rev. 9 UNIT 1 ACTIO N/ EXPECTED RESP ONSE - !RE I

SPONSE N-6-T OBTAYNE-b _

_ __ J

18. Check KC surge tank level on both IF KC surge tank level is still going down train(s) - STABLE OR GOING UP. in an uncontrolled manner, THEN:

a. IF level goes below 2 ft, THEN ensure Foldout page item 1 is implemented.

b. GO TO Step 20.

19. GO TO Step 38.

20 . Isolate 1A KC Train from -18 KC Train as follows:

a. Check any 1A KC Tra in pump - a. GO TO Step 20J.

RUNNING .

b. Check the following valves - OPEN: b. GO TO Step 20.f.

• 1KC-3A (Trn A Rx Bldg Non Ess Ret Isol)

• 1KC-230A (Trn A Rx Bldg Non Ess Sup Isol) .

C. Close the following valves :

_ 1) 1KC-53B (Trn B Aux Bldg Non Ess Sup 1501).

_ 2) 1KC-2B (Trn B Aux Bldg Non Ess Ret 1501).

_ 3) 1KC-228B (Trn B Rx Bldg Non Ess Sup Isol).

_ 4) 1KC-18B (Trn B Rx Bldg Non Ess Ret Isol) .

d. WHEN valves in Step 20.c are closed , d. IF 1A KC Surge Tank level stabilizes, THEN check 1A KC Surge Tank leve l - AND 1B KC Surge tank level continues GOING DOWN . to go down , THEN leak is on 1B Essential header.

e. GO TO Step 21.

A (;.(. fY\f/\ r 2-MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500/21 9 of 78 Rev . 9 UNIT 1 ACTI ON/ EXPECTED RESPONSE ~ES P O N S E NOT OBTAINED

20. (Continued)

f. Close the following valves:

_ 1) 1KC-50A (Trn A Aux Bldg Non Ess Sup Isol).

_ 2) 1KC-1A (Trn A Aux Bldg Non Ess Ret Isol).

_ 3) 1KC-230A (Trn A Rx Bldg Non Ess Sup Isol).

_ 4) 1KC-3A (Trn A Rx Bldg Non Ess Ret Isol) .

_ g. WHEN valves in Step 20.f are closed, _ g. IF 1B KC Surge Tank level stabilizes, THEN check 1B KC Surge Tank level - AND 1A KC Surge tank level continues GOING DOWN. to go down, THEN leak is on 1A Essential header.

21. Check Unit 2 KC Surge Tank level* IF Unit 2 KC Surge Tank level is going up STABLE. in an uncontrolled manner, THEN:

a. Have Rad Waste Chemistry check KC alignment for:

• NB and WL evaporators

• WG system.

b. IF KC drain tank pumps are aligned to Unit 2, THEN:

• Dispatch operator to align drain tank to Unit 1 PER OP/1/A/64001005 (Component Cooling Water System),

Enclosure 4.8 (Swapping KC Drain Tank Discharge).

• Have Work Control SRO evaluate any KC drain operation in progress or other potential KC drain paths .

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 10 of 78 Rev. 9 UNIT 1 ACTI ON / EXPECTED RES PONS E ~ ES PONS E NOT OBTAI NED L _'_ __ _ _... .J 22 . Check KC pumps - AT LEAST ONE WHEN KC Surge Tank Level greater than RUNNING. 2 ft, THEN start one KC Train PER one of the following:

• IF desired to start 1A KC Train, AND 1A KC Surge Tank is greater than 2 ft, THEN GO TO Enclosure 4 (Startup of 1A KC Train) .

OR

• IF desired to start 1B KC Train , AND 1B KC Surge Tank is greater than 2 ft, THEN GO TO Enclosure 5 (Startup of 1B KC Train) .

23. Check KC Surge Tank level on both Perform the following:

train(s) - STABLE OR GOING UP.

a. IF either train's KC Surge Tank level is less than 3 ft, THEN GO TO Step 27.

b. IF Makeup to the KC Surge Tank from RN has been opened, AND level is still going down, THEN GO TO Step 27.

c. IF KC Surge Tank levels are greater than 3 ft, THEN observe Note prior to Step 25 and GO TO Step 25.

24. GO TO Step 38.

MNS LOSS OF KG OR KG SYSTEM LEAKAGE PAGE NO .

AP / 1/A/5500/21 11 of 78 Rev . 9

'U NI T 1 ACTI ON/ EXPECTED RESPONSE RES PONSE NOT OBTAINED NOTE The next step allows waiting to see if KG Surge Tank levels can be stabi lized using makeup, prior to taking actions to isolate KG headers. If level can be stabilized using makeup, header with leak may be left in service.

25 . Do not continue until one of the following is met:

_ . Either train's KG Surge Tank level is less than 3 ft.

OR

_ . Makeup to the KG Surge Tank has been initiated using RN.

OR

• Both KG Surge Tank levels are stable or going up .

26. RETURN TO Step 23.

27. IF AT ANY TIME leak is known to be on an Essential header, THEN perform one of the following:

NOTE The enclosure used in next step will also isolate Essential header with lea k.

_ . IF leak on 1B Train , THEN GO TO Enclosure 4 (Startup of 1A KG Train) .

OR

• IF leak on 1A Train, THEN GO TO Enclosure 5 (Startup of 1B KG Train).

.. ; ~ .'. ~:.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 12 of 78 Rev. 9 UNIT I I ACTI ON/ EXPECTED RESPONSE I BES PONSE NOT OBTAINED I

28. Check if leak is on Reactor Bldg Non-essential header as follows:

a. Check leak - KNOWN TO BE ON a. GO TO Step 28.c.

REACTOR BLDG NON-ESSENTIAL HEADER.

b. GO TO Step 30.

c. Check containment floor and equipment c. Perform the following:

sump levels - GOING UP

_ 1) IF Containment Floor and Equipment pumps are off, THEN GO TO Step 29.

_ 2) Stop Containment Floor and Equipment pumps.

_ 3) Check if Conta inment Floor and Equipment sump level is going up.

_ 4) IF sump level indicates a leak in containment, THEN GO TO Step 30.

_ 5) IF sump level is normal , THEN GO TO Step 29.

_ d. GO TO Step 30.

29. Attempt to isolate leak by isolating KC Aux Bldg Non-essential header as follows:

a. Isolate letdown as follows :

1) Close :

• 1NV-458A (75 GPM LID Orifice Outlet Cont Isol)

• 1NV-457A (45 GPM LID Orifice Outlet Cont Isol)

• 1NV-35A (Variable LID Orifice Outlet Cont 1501).

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500 /21 13 of 78 Rev. 9 UNIT 1 ACTI ON/ EXPECTED RESPONSE ~E S P ON S E NOT OBTA I NED 1______ __ _ __ __ _ _ ~ _

29 . (Continued)

_ 2) Chec k NO - IN SERVICE PRIOR TO _ 2) GO TO Step 29 .b.

EVENT.

_ 3) Close 1NV-121 (NO Letdown Control).

b. Close all NM valves located on 1MC-8 (vertical board) .

c. Ensure recirc valve(s) on operating KC pumps in "AUTO":

• 1KC-51A (Train A Recirc Isol)

• 1KC-54B (Train B Recirc Isol).

d. Close the following :

_ 1) 1KC-50A (Trn A Aux Bldg Non Ess Sup Isol).

_ 2) 1KC-1A (Trn A Aux Bldg Non Ess Ret Isol) .

_ 3) 1KC-53B (Trn B Aux Bldg Non Ess Sup Isol).

_ 4) 1KC-2B (Trn B Aux Bldg Non Ess Ret Isol).

e. Evaluate whether leak is isolated based on :

• Surge Tank(s) level trend

• Amount of makeup established

• IF KC surge tank level is going up, AND status of leak isolation is unknown, THEN reduce KC surge tank makeup flow as required to determine if leak is isolated .

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500 /21 14 of 78 Rev . 9 UNIT 1 ACTI ON/ EXPECTED RESP ONSE RES PONSE NOT OBTA I NED

29. (Continued)

f. Check leak - ISOLATED. f. IF leak still exists, THEN:

_ 1) Raise KC surge tank makeup flow as required to maintain level.

2) WHEN Surge Tank on operating train is greater than 2 ft, THEN reopen the following valves on the operating train:

• A Train

_ a) 1KC-1A (Trn A Aux Bldg Non Ess Ret Isol).

_ b) 1KC-50A (Trn A Aux Bldg Non Ess Sup Isol) .

OR

• B Train

_ a) 1KC-2B (Trn B Aux Bldg Non Ess Ret Isol) .

_ b) 1KC-53B (Trn B Aux Bldg Non Ess Sup Isol).

_ 3) GO TO Step 30.

_ g. Assume leak was on the Aux Bldg Non-essential header.

h. Close :

• 1NV-1A (NC LID Isol To Regen Hx)

• 1NV-2A (NC LID Isol To Regen Hx).

_ i. GO TO Step 38.

30. Check the following valves - CLOSED: _ GO TO Step 32.

• 1KC-305B (Excess LID Hx Sup Hdr Cant Otsd Isol)

• 1KC-315B (Excess LID Hx Ret Hdr Cant Otsd Isol) .

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 15 of 78 Rev . 9 UNIT 1 I ACTI ON/E XPECTED RESPONSE ,I I RES PONSE NOT OBTAI NED I

31. GO TO Step 33.

32. Attempt to isolate leak by isolating KC to excess letdown as follows:

a. Isolate Excess Letdown by closing the following valves:

• 1NV-24B (C NC Loop To Exs LID Hx Isol)

• 1NV-25B (C NC Loop To Exs LID Hx Isol) .

b. Close the following valves:

• 1KC-305B (Excess LID Hx Sup Hdr Cont Otsd Isol)

• 1KC-315B (Excess LID Hx Ret Hdr Cont Otsd Isol).

c. Evaluate whether leak is isolated based on:

• Surge Tan k(s) level trend

• Amount of makeup established

• IF KC surge tank level is going up AND status of leak isolation is unknown , THEN reduce KC surge tank makeup flow as required to determine if leak is isolated .

d. Check leak - ISOLATED . d. IF leak still exists, THEN :

_ 1) Raise KC surge tank makeup flow as required to maintain leve l.

_ 2) GO TO Step 33.

e. Assume leak was on excess letdown HX.

f. GO TO Step 38.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500/21 16 of 78 Rev. 9 UNIT 1 I ACTI ON/E XPECTED RES PONSE I RES PONSE NOT OBTAI NED I

33. Attempt to isolate leak by isolating KC to NCDT as follows:

a. Close the following valves :

• 1KC-320A (NCDT Hx Sup Hdr Cant Outs ide Isol)

• 1KC-333A (NCDT Hx Ret Hdr Cant Outside Isol)

• 1 KC-332B (NCDT Hx Ret Hdr Cant Inside Isol) .

b. Evaluate whether leak is isolated based on:

• Surge Tank(s) level trend

• Amount of makeup estab lished

• IF KC surge tank level is going up, AND status of leak isolation is unknown, THEN reduce KC surge tank makeup flow as required to dete rmine if leak is isolated.

c. Check leak - ISOLATED. c. IF leak still exists, THEN:

_ 1) Raise KC surge tank makeup flow as required to maintain level.

2) Reopen the following valves :

• 1KC-320A (NCDT Hx Sup Hdr Cant Outside Isol)

• 1KC-333A (NCDT Hx Ret Hdr Cant Outside Isol)

• 1KC-332B (NCDT Hx Ret Hdr Cant Inside Isol).

_ 3) GO TO Step 34.

I' : --- _~ -. - '::'- ..

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/AJ5500/21 17 of 78 Rev. 9 UNIT 1 AC T I ON / EX P EC T Eb ~ RES PON~ ~

33. (Continued)

d. IF AT ANY TIME NCDT temperature approaches 200 0 F, THEN perform the follow ing to prevent flashing of KC water in NCDT HX:

_ 1) Stop NCDT pump(s).

_ 2) Close 1WL-23 (NCDT Pump Level Cntrl).

_ 3) Close 1WL-41B (NCDT Vent Cont Outside Isol).

4) IF AT ANY TIME NCDT pressure approaches VCT pressure , THEN close one of the following:

_ . 1NV-94AC (NC Pumps Seal Ret Cont Inside Isol)

OR

_ . 1NV-95B (NC Pumps Seal Ret Cont Outside Isol).

e. GO TO Step 38.

34. Check the following: Perform one of the following:

a. Any NC pump - RUNNING.

• IF leak location is believed to be on Reactor Bldg header, OR location

b. Both trains KC surge tank level - ON unknown , THEN observe Notes prior to SCALE. Step 37 and GO TO Step 37.

c. Both trains KC surge tank level - OR STABLE OR GOING UP.

• IF leak has been identified on an Essential header, THEN RETURN TO Step 27.

35. IF AT ANY TIME KC surge tank level starts going down, THEN perform Step 34.

36. GO TO Step 38.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/N5500/21 18 of 78 Rev. 9

,UNIT 1 I ACTI ON / EXPECTED RESPONSE I RES PONSE NOT OBTAI NED I

• If the leak is not stopped by isolating the KC Reactor Bldg Header, and KC pumps are on, then this step will immediately restore KC cooling to NC pumps.

• KC cooling for NC pump motor bearings and thermal barriers will be isolated in the next step. The Foldout page provides NC pump trip criteria.

37. Attempt to isolate leak by isolating entire KC Reactor Bldg Header as follows:

a. Close the following valves:

_ 1) 1KC-230A (Trn A Rx Bldg Non Ess Sup Isol).

_ 2) 1KC-3A (Trn A Rx Bldg Non Ess Ret Isol).

_ 3) 1KC-228B (Tm B Rx Bldg Non Ess Sup Isol).

_ 4) 1KC-18B (Trn B Rx Bldg Non Ess Ret Isol) .

b. Evaluate whether leak is isolated based on:

• Surge Tank(s) level trend

• Amount of makeup established

• IF KC surge tank level is going up, AND status of leak isolation is unknown , THEN reduce KC surge tank makeup flow as required to determine if leak is isolated.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/AJ5500/21 19 of 78 Rev. 9 UNIT 1 I ACTION/EXPECTED RESPONSE I I RESPONSE NOT OBTAINED I

37. (Continued)

c. Check leak - ISOLATED. c. IF leak still exists, THEN perform the following:

_ 1) Raise KC surge tank makeup flow as required to maintain level.

_ 2) Assume leak is on the train's Essential header with affected surge tank level.

3) IF 1A KC pumps running, AND 1A KC Surge Tank level is greater than 1 ft, THEN align 1A KC train to Reactor Bldg header as follows:

a) Close the following valves:

_ (1) 1KC-228B (Tm B Rx Bldg Non Ess Sup Isol).

_ (2) 1KC-18B (Trn B Rx Bldg Non Ess Ret Isol).

b) Open the following valves:

_ (1) 1KC-3A (Tm A Rx Bldg Non Ess Ret Isol).

_ (2) 1KC-230A (Trn A Rx Bldg Non Ess Sup Isol).

(RNO continued on next page)

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO .

AP/1/A/5500/21 20 of 78 Rev . 9 UNIT 1 ACTI ON/EXPE CTED RESPONSE RES PONSE NOT OBTA INE D 37 . (Continued)

4) IF 1B KC pumps running , AND 1B KC Surge Tan k level is greater than 1 ft , THEN align 1B KC train to Reactor Bldg header as follows :

a) Close the following valves:

_ (1) 1KC-230A (Trn A Rx Bldg Non Ess Sup Isol).

_ (2) 1KC-3A (Trn A Rx Bldg Non Ess Ret Isol) .

b) Open the following valves:

_ (1) 1KC-18B (Trn B Rx Bldg Non Ess Ret Isol) .

_ (2) 1KC-228B (Trn B Rx Bldg Non Ess Sup Isol) .

NOTE The enclosure used in next step will also isolate Essential header with leak. It will also align non-essential headers to the intact KC train .

5) Perform one of the following :

• IF leak on 1B Train, THEN GO TO Enclosure 4 (Startup of 1A KC Train)

OR

• IF leak on 1A Train , THEN GO TO Enclosure 5 (Startup of 1B KC Train).

_ 6) GO TO Step 39.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 21 of 78 Rev. 9 UNIT 1 ACTI ON / EXPECTED RESPONSE RES PONSE NOT OBTAI NED

37. (Continued)

d. IF AT ANY TIME NCDT temperature approaches 200 0 F, THEN perform the following to prevent flashing of KC water in NCDT HX:

_ 1) Stop NCDT pump(s).

_ 2) Close 1WL-23 (NCDT Pump Level Cntrl).

_ 3) Close 1WL-418 (NCDT Vent Cont Outside Isol).

4) IF AT ANY TIME NCDT pressure approaches VCT pressure , THEN close one of the following:

_ . 1NV-94AC (NC Pumps Seal Ret Cont Inside Isol)

OR

_ . 1NV-958 (NC Pumps Seal Ret Cont Outside Isol).

e. Trip reactor .

f. WHEN reactor tripped, THEN stop all 4 NC pumps .

_ g. GO TO EP/1/A/5000/E-0 (Reactor Trip or Safety Injection), while continuing in this AP as time and conditions allow.

- - -. -~ -. ~ ' ~'~._.

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 22 of 78 Rev. 9 UNIT 1 ACTI ON /EX PECTED RESPON SE RES PON SE NOT OBTAI NED 38 . Check KC pumps - AT LEAST ONE WHEN KC Surge Tank Level greater than RUNNING. 2 ft, THEN start one KC Train PER one of the following:

• IF des ired to start 1A KC Train . AND 1A KC Surge Tank is greater than 2 ft.

THEN GO TO Enclosure 4 (Startup of 1A KC Train) .

OR

• IF desired to start 1B KC Train , AND 1B KC Surge Tank is greater than 2 ft.

THEN GO TO Enclosure 5 (Startup of 1B KC Train).

39. Continue attempts to identify and isolate leak:

a. Check header with leak - ISOLATED. a. Perform the following as desired to isolate leak :

NOTE Header with leak may be left in service as long as KC surge tank level can be maintained. The decision to isolate leak should depend on size of leak and critical components on associated header.

• IF required to swap operating trains of KC due to leak on an Essential header. THEN evaluate performing Step 27.

• IF required to isolate the entire Aux Bldg Non-essential header, THEN evaluate performing Step 29.

(RNO continued on next page)

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1 /A/5500/21 23 of 78 Rev. 9 UNIT 1 ACTI ON/EXPE CTED RESPONSE RES PONSE NOT OBTAINED

i. _

39. (Continued)

• IF required to isolate leak on excess letdown or NCDT, THEN evaluate performing Steps 30 through 33.

NOTE If cool ing to NC pumps will be isolated, it is preferable to wait until NC pumps are already shutdown .

• IF required to isolate KC to just the NC pumps , THEN:

_ 1) Ensure NC pump trip criteria on Foldout page is monitored.

2) Evaluate closing the following valves:

_ a) 1KC-338B (NC Pump Sup Hdr Cont Outside Isol).

_ b) 1KC-425A (NC Pumps Ret Hdr Cant Outside Isol).

_ c) 1KC-424B (NC Pumps Ret Hdr Cont Inside Isol).

• IF required to isolate entire Reactor Bldg Non-essential header, THEN observe Notes prior to Step 37 and evaluate performing Step 37.

b. Determine individual component that is leak ing .

40 . WHEN leaking individual component is isolated, OR if an isolated KG non-essential header is determined to be intact, THEN evaluate placing affected KG header back in service PER Enclosure 7 (Reopening KG Headers).

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 24 of 78 Rev. 9 UNIT 1 I ACTI ON/ EXPECTED RESPONSE I I RES PONSE NOT OBTAI NED I

41. Check any letdown path - IN SERVICE. Perform the following:

a. IF KC is aligned to the Aux Bldg Non-essential header, THEN:

_ 1) Align normal letdown PER AP/1/A/5500/12 (Loss Of Letdown, Charging Or Seal Injection).

_ 2) IF NO is in RHR mode and NO letdown is desired, THEN establish letdown from the NO System PER OP/1/A/6200/001 A (Chemical and Volume Control System Letdown) ,

Enclosure 4.1 (Establishing Aux Letdown From The NO System, Charging Flow and Seal Injection Flow).

b. IF KC is aligned to the Reactor Bldg Non-essential header, AND excess letdown is required , THEN establish PER EP/1/A/5000/G-1 (Generic Enclosures), Enclosure 2 (Establishing Excess Letdown) .

42. Check NC pump thermal barrier valves >> _ Open valves unless required closed to OPEN: isolate leak.

• 1KC-394A (A NC Pump Therm Bar Otlt)

• 1KC-345A (C NC Pump Therm Bar Otlt)

• 1KC-364B (B NC Pump Therm Bar Otlt)

• 1KC-413B (0 NC Pump Therm Bar Otlt).

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 25 of 78 Rev. 9 UNIT 1 ACTI ON/ EXPECTED RES PONSE RES PONSE NOT OBTA I NED

1. _

43. Check KC to Aux Bldg Non-essential Perform the following:

header - ESTABLISHED.

a. Ensure all NM valves located on 1MC-8 (vertical board) are closed.

b. Notify secondary and primary chemistry that:

• NM valves have been isolated .

• KC cooling to Aux Bldg Non-essential header is isolated .

• Normal and NO letdown is isolated.

c. REFER TO Enclosure 6 (VCT High Temperature Actions).

d. Notify station management to evaluate Spent Fuel Pool cooling .

e. GO TO Step 46.

44. Check NM valves (on 1MC-8) - _ GO TO Step 46.

PREVIOUSLY CLOSED BY THIS PROCEDURE.

45. Notify Chemistry to coordinate reestablishing NM.

46. Evaluate KC chemistry requirements as follows:

• Notify Primary Chemistry of KC makeup that has occurred or is in progress .

• Evaluate recirculating the KC Surge Tank volume and feed and bleed of KC System PER OP/1/A/64001005 (Component Cooling Water System) .

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 26 of 78 Rev. 9 UNIT 1 I ACTI ON/ EXPECTED RESPONSE

,I I RESPONSE NOT OBTAINED I

47. Check both trains RN suction- ALIGNED Perform the following:

TO LLI.

a. IF both A and B train RN pumps are aligned to the SNSWP , THEN GO TO Step 48.

b. IF both of the following valves are closed, THEN GO TO Step 48:

• 1RN-41B (Train B To Non Ess Hdr 1501)

• 2RN-41 B (Train B To Non Ess Hdr 1501).

c. IF both of the following valves are closed , THEN GO TO Step 48:

• 1RN-43A (Train B To Non Ess Hdr 1501)

• 2RN-43A (Train B To Non Ess Hdr 1501).

(RNa continued on next page)

MNS LOSS OF KC OR KC SYSTEM LEAKAGE PAGE NO.

AP/1/A/5500/21 27 of 78 Rev. 9 UN IT 1 ACTI ON/ EXPECTED RESPONSE RES PONSE NOT OBTAIN ED 47 . (Continued)

d. Contact station management to evaluate the following:

NOTE

• If train with suction on pond is aligned to train with discharge to RC (via open cross tie), or to non-essential header, SNSWP may be pumped to the lake .

• Unit 1 non-essential headers discharge to A Train discharge. Unit 2 non-essential headers discharge to B Train discharge.

• Unit 1 and 2 non-essential headers may be cross tied through RN to RL tie.

• SNSWP draw down

• Alignment of RN System.

48. RETURN TO procedure and step in effect.

Examination Outline Cross- Level RO SRO reference:

Tier # 1 Group # 1 KiA # (026) G2.1.25 Importance Rating 4.2 Rev" 1 to the package Loss of Component Cooling Water / Conduct of Operations : Ability to interpret reference materials, such as graphs, curves, tables, etc Proposed Question: SR077

Initial conditions:

Time = 0 minutes

• Unit 1 is at 100% power.

• "A" Train KC pumps are running.

• Operators have been dispatched to initiate YM makeup to the KC Surge Tank.

• "A" KC Surge Tank level is 6.5 ft.

• "B" KC Surge Tank level is 6.5 ft.

Current conditions:

Time = 5 minutes

• "A" KC Surge Tank level is 5.6 feet

• "B" KC Surge Tank level is 6.4 feet.

Which ONE (1) of the following describes (1) the approximate KC system net leak rate, and (2) the required action and procedure use required in AP/21 , Loss of KC or KC System Leakage?

(Reference Provided)

A. (1) 50GPM (2) Isolate KC Non-Essential Headers in accordance with Enclosure 2.

B. (1) 50 GPM (2) Isolate "A" KC train from "B" KC train.

C. (1) 100 GPM (2) Isolate KC Non-Essential Headers in accordance with Enclosure 2.

D. (1) 100 GPM (2) Isolate "A" KC train from "B" KC train.

Proposed Answer: 0 Explanation (Optional):

D is correct per conditions . Applicant must interpret curve and determine the leak rate indications based on level decreases A incorrect because leak rate is wrong (1/2 of actual, as interpreted by curve.)

Also , action is incorrect, as procedure will direct splitting trains for indication shown B incorrect because leak rate is incorrect. Plausible because action is correct C incorrect because procedure use is incorrect. Approximately 0.1 feet/minute ,

perform step 20 to split trains Technical AP/21 Step 20 Rev 9 (Attach if not previously Reference( s): provided)

AP/21 Basis Document Rev 3 Proposed references to be provided to applicants during OP/1/N61 00/22 examination: Enclosure 4.3 Curve 7.31 Learning Objective: None Question Source: Bank#

Modified Bank x (Note changes or attach

1. parent)

New Question History: Last NRC Exam Modified from 2007 NRC exam 78 Question Cognitive Memory or Fundamental Knowledge Level:

Comprehension or Analysis x 10 CFR Part 55 55.41 Content:

55.43 5 Comments:

KA matched because use of a curve is required and interpretation of that curve is required to determine KC (CCW) leak rate. SRO level because assessment of

conditions based on available indications, and selection of procedures (attachments) is required RFA Concurs 4/17/08 SRO Question 77 During the Post Exam Item Analysis we have determined that Question 77 has two correct answers with Distracter "C" being a subset ofthe Correct Answer "D". Due to this determination we propose that both "C" and 'D" be accepted as correct.

In this question the candidate is asked to determine a leak rate from the KC (Component Cooling) System. The operator is given KC surge tank levels for T=O and T- +5 min along with a copy of the KC Surge tank level curve from the Data Book. Correctly performed, the leak rate is determined to be approximately 100 GPM. Also in the stem of the question the operator is advised that "Operators have been dispatched to initiate YM makeup to the KC surge tank", but are not told that this makeup has actually been established. The initial level in the surge tank is 6.5 ft. The candidate is then asked to determine "the required action and procedure use required in AP/21, Loss ofKC or KC System Leakage".

Per paragraph 7 of Appendix E of NUREG-I021 page 2 of 6 which is part of the briefing given prior to the exam, the candidates are given the following instructions, "When answering a question, do not make assumptions regarding conditions that are not specified in the question unless they occur as a consequence of other conditions that are stated in the question. Similarly, you should assume that no operator actions have been taken, unless the stem of the question or the answer choices specifically state otherwise.

Finally, answer all questions based on actual plant operation, procedures or the answer choices specifically stated otherwise".

With this direction in mind the candidate can correctly assume that YM makeup is not initially aligned but within a reasonable period of time it will be. (Per the Time Critical Actions for our plant this should occur within 10 min of dispatch) According to the background document for AP-21 pg 10 of23, "Per engineering, YM makeup should be sufficient to keep up with the FSAR design basis leak of 50 GPM". After determining that a 100 GPM leak exists, even with YM make up aligned the candidate would reasonably come to the conclusion that KC surge tank level would continue to decrease.

Procedurally we would align the Nuclear Service Water assured makeup ifYM was not sufficient to keep up with the leak but the candidates are told to not assume any operator actions not stated, therefore it is reasonable for the candidate to assume that this has not and will not happen unless otherwise stated.

Procedural guidance per AP-21 directs that once it has been determined that a leak exists operators be dispatched early to initiate YM make up per Step 11. The procedure then checks surge tank level greater than 3 ft which for the scenario given it should be for the first pass thru this step. The operator is then directed to check the "sum of both trains' KC surge tank level drops LESS THAN OR EQUAL TO 0.10 FT/MIN". If true, which for the leak rate calculated, it would be, the crew is directed to Step 20 which will Isolate

. ~.... -:.- :.. : .'.. . .. ~

..:_., :.;:,. ~...:.~:.'.'.: .

"A" KC train from "B" KC train. This action is consistent with the actions stated in the Correct answer "D" making it a valid correct answer. Once again, assuming no operator action has taken place, the surge tank levels will continue to decrease until they reach a level of 2 ft. At this point the "foldout" page would direct the operator to isolate the affected train PER Enc. 2. This action is stated in Distracter "C" and since the stem does not refer to the "First" or "Next" action taken, this action is actually a subset of "D" and therefore a correct answer.

Based on the discussion above and the attached references , we recommend that both "C" and "D" be accepted as correct answers.

The Post-exam Item Analysis indicated that 4 of 9 applicants missed this question.

• All 4 chose "C" - Understandably since this distracter is an action that would be taken assuming no other actions occur.

No applicant asked for clarification on this question while taking the exam.

How did this question get through Validation?

Question 77 underwent minor revisions during the validation process but remained fairly close to the original version. Given tank levels were changed for clarification in determining the leak size due to earlier misses because of miscalculation of the 50 GPM vs 100 GPM leak size. It was also recognized that we needed to clarify that makeup to the system had not been initiated. Once the leak size issues were addressed , 10 more operators validated the question with 6 missing and all but 1 picked "C". We attributed this to the fact that none of these operators had probably studied the AP in quite a while so it made sense that the "decay" of the in depth knowledge required to answer this question would result is a substantial number of wrong answers. In all the post validation interviews, I do not remember anyone questioning that both answers were correct and from what I can remember all were satisfied with attributing the incorrect answer to "decay" of memory. I also reviewed my notes from all of these validations and I recorded nothing concerning the possibility of two correct answers. As described above, I believe it was just easy for everyone concerned to accept this being a problem with decay of memory and that the HLP students would be operating on a higher level of in depth procedure knowledge so this question was considered to be acceptable.

During the post exam item analysis, we revisited this question and with everyone that missed it picking distracter "C" it became apparent that we may have missed something.

It was hard to apply the "decay of knowledge" theory to the HLP students so we reconsidered distracter "C". The AP for KC is fairly difficult to follow without reading it within an actual scenario and when we looked more closely at how the question was presented in the stem and the plausibility of distracter "C" it became apparent that this action would indeed be taken and that it was actually a subset of "D".

a SRO Question 84 Based on Post Examination Test Item Analysis, accept both A and D as correct.

Both answers are correct and do not contain conflicting information.

Selected License Commitment (SLC) 16.11.3 states:

"16. 11.3 Dose - Liquid Effluents COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS (see Figure16.11.1-1) shall be limited:

a. During any calendar quarter, to:s 1.5 mrem to the total body and to :s 5 mrem to any organ , and

b. During any calendar year , to ~ 3 mrem to the total body and to

~ 10 mrem to any organ .

APPLICABILITY At all times. "

Distracter D of the question reads

" 3 mrem whole body do e in a calendar year, A D 10 mrem organ dose in a calendar year" . This is a direct match to 16.11.3.b as seen above .

The proposed answer of A is still correct as shown below:

"16.11.3 Dose - Liquid Effluents COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS (see Figure16.11.1-1) shall be limited:

a. During any calendar and to:s 5 mrem .to any organ, and

b. During any calendar and to

s 10 mrem to any organ.

APPLICABILITY At all times."

Distracter "A" reads

, AND This covers requirements in both 16.11.3.a and b.

b SRO Question 84 Question 84 ended up with two correct answ ers becau se I made a last minute change to C and D distracter and didn 't validate the technical accuracy . I thought I was merel y correcting a typo in both distracters.

In our ori ginal submittal this question was unsat becau se of low discriminatory value. At that time it was not a two part question. Ju st a few days before our trip to Atlant a, we made each distracter two-part to increase its discriminatory value. Thi s is what it looked like on 4/16/08:

Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF-31 , is discovered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE ( 1) of the following describes the impact of this condition?

The do se or dose commitment to members of the public may exceed the requirements of IOCFR50 of. ...

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year.

c. 1.5 mrem whole body do e in a calendar year, AND 5 mrem ma calendar year.

D. 3 mrem whole body dose in a calendar year , AND IO mrem in a calendar year Correct answer: A During a final review prior to our leaving for Atlanta, I reali zed that both parts of C and D deal with whole body dose in a calendar year. This made them obvi ously implausible.

Being in a rush , l ju st changed the second to "or ga n". I didn't take the time to validate against the SLC , so I didn't realize l ju st made "D" a correct answer .

This error gave us the question that was administered to the applicants.

I didn 't realize the real typo was the "year" in the first part of C and D distracter. I should have changed the "year" in the first part to "quarter". This would have made D incorrect. c SRO Question 84 The original intent of the que stion was to test the whole body dose limits per quarter and per year. All four distracters SHOULD have addressed quarter and year, not just year.

Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF -31 , is discovered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE (I) of the following describes the impact of this condition?

The dose or dose commitment to members of the public may exceed the requirements of IOCFR50 of. ...

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year .

C. 1.5 mrem whole body dose in a calendar vear quarter, AND 5 mrem whole body dose in a calendar year.

D. 3 mrem whole body dose in a calendar ~ quart er, AND 10 mrem whole body dose in a calendar year Correct answer: A

Examination Outline Cross- Level RO SRO reference:

Tier # 1 Group # 2 KIA # (059) G2.2.38 Importance Rating 4.5 Accidental Liquid Radwaste Release / Equipment Control: Knowledge of conditions and limitations in the facility license.

Proposed Question: SR084 Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF -31, is discovered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE (1) of the following describes the impact of this condition?

The dose or dose commitment to members of the public may exceed the requirements of 10CFR50 of....

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year.

C. 1.5 mrem whole body dose in a calendar year, AND 5 mrem organ dose in a calendar year.

D. 3 mrem whole body dose in a calendar year, AND 10 mrem organ dose in a calendar year.

Proposed Answer: A Explanation (Optional):

A. Correct. This is a memory item. SLC states that the dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS shall be limited During any calendar quarter, to ~ 1.5 mrem to the total body and to ~ 5 mrem to any organ, and During any calendar year, to ~ 3 mrem to the total body and to

~ 10 mrem to any organ. Below options are plausible because the numbers supplied are all part of the SLC.

B. Incorrect. 3 mrem is Whole Body Dose allowed for a calendar year, 5 mrem is Organ Dose allowed for a calendar quarter.

C. Incorrect. 1.5 mrem correct, 5 mrem is Organ Dose allowed for a calendar

quarter D. Incorrect. 3 mrem is Whole Body Dose allowed for a calendar year, 10 mrem is Organ Dose allowed for a calendar year.

Technical SLC 16.11.3, Rev 0 (Attach if not previously Reference(s) _ _ _ _ _ _ _ _ _ _ provided)

Proposed references to be provided to applicants during None examination:

Learning Objective: WE-RLR Obj 6 Question Source: Bank#

Modified Bank (Note changes or attach

1. parent)

New -X---

Question History: Last NRC Exam - - - - - - - - - - - - - - -

Question Cognitive Memory or Fundamental Knowledge X Level:

Comprehension or Analysis 10 CFR Part 55 55.41 Content:

55.43 1,2,4 Comments :

KA is matched because 10CFR50 requirements for radioactive release are limitations in the facility license. SRO knowledge because the item requires knowledge of SLC (TRM) conditions that will require action by the SRO RFA Concurs 4/17/08

Dose - Liquid Effluents 16.11.3 16.11 RADIOLOGICAL EFFLUENT CONTROLS 16.11.3 Dose - Liquid Effluents COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS (see Figure16.11 .1-1) shall be limited:

a. During any calendar quarter, to.$ 1.5 mrem to the total body and to .$ 5 mrem to any organ, and

b. During any calendar year, to.$ 3 mrem to the total body and to

.$ 10 mrem to any organ.

APPLICABILITY At all times .

REMEDIAL ACTIONS

---

NOTES-----------------------------------------------------

Enter applicable Conditions and Required Actions of SLC 16.11.12, "Total Dose," when the limits of this SLC are exceeded by twice the specified limit.

CONDITION REQUIRED ACTION COMPLETION TIME A. Calculated dose from ---------------------NOTE--------------

release of radioactive The Special Report shall include materials in liquid the results of radiological analyses effluents exceeding of the drinking water source, and above limits. the radiological impact on finished drinking water supplies with regard to the requirements of 40 CFR 141, Safe Drinking Water Act, as applicable.

A.1 Prepare and submit a 30 days Special Report to the NRC which identifies the causes for exceed ing the limits, corrective actions taken to reduce releases , and actions taken to ensure that subsequent releases are within limits.

McGuire Units 1 and 2 16.11.3-1 Revision 0

.:.-. 0 _-

Dose - Liquid Effluents 16.11.3 TESTING REQUIREMENTS TEST FREQUENCY TR 16.11.3.1 Determine cumulative dose contributions from liquid 31 days effluents for current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM.

BASES This commitment is provided to implement the requirements of Sections II.A, III.A and IV.A of Appendix 1,10 CFR Part 50. The commitment implements the guides set forth in Section II.A of Appendix I. The REMEDIAL ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable ." Also, for fresh water sites with drinking water supplies that can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR Part 141. These requirements are applicable only if the drinking water supply is taken from the river 3 miles downstream of the plant discharge.

The dose calculation methodology and parameters in the aDCM implement the requirements in Section liLA of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropr iate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Append ix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

This commitment applies to the release of liquid effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system in accordance with the guidance given in NUREG-0133, Chapter 3.1.

McGuire Units 1 and 2 16.11.3-2 Revision 0

Dose - Liquid Effluents 16.

11.3 REFERENCES

1. McGuire Nuclear Station, Off site Dose Calculation Manual

2. 40 CFR Part 141, Safe Drinking Water Act

3. 10 CFR Part 50, Appendix I

4. Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977.

5. Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

McGuire Units 1 and 2 16.11.3-3 Revision a

Examination Outline Cross- Level RO SRO reference:

Tier # --

Group # 2 KIA # (059) G2.2 .38 Importance Rating _4_._5 _

Rev 1 to the package Accidental Liquid Radwa ste Release / Equipme nt Control : Know ledge of conditions and limitations in the facility license.

Proposed Question: SR084 Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF-31, is discovered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE (1) of the following describes the impact of this condition?

The dose or dose commitment to members of the public may exceed the requirements of 10CFR50 of ....

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year.

C. 1.5 mrem whole body dose in a calendar year, AND 5 mrem organ dose in a calendar year.

D. 3 mrem whole body dose in a calendar year, AND 10 mrem organ dose in a calendar year.

Proposed Answer: A Explanation (Optional):

A. Correct. This is a memory item. SLC states that the dose or dose comm itment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS shall be limited During any calendar quarter, to ~ 1.5 mrem to the total body and to ~ 5 mrem to any organ, and During any calendar year, to ~ 3 mrem to the total body and to

~ 10 mrem to any organ. Below options are plausible because the numbers supplied are all part of the SLC .

B. Incorrect. 3 mrem is Whole Body Dose allowed for a calendar year, 5 mrem is Organ Dose allowed for a calendar quarter.

C. Incorrect. 1.5 mrem correct, 5 mrem is Organ Dose allowed for a calendar

quarter ~~

D. Incorrect. 3 mrem is Whole Body Dose allowed for a calendar year, 10 mrem is Organ Dose allowed for a calendar year.

Technical SLC 16.11.3, Rev a (Attach if not previously Reference( s) provided)

Proposed references to be provided to applicants during None examination:

Learning Objective: WE-RLR Obj 6 Question Source: Bank#

Modified Bank (Note changes or attach

1. parent)

New X Question History: Last NRC Exam Question Cognitive Memory or Fundamental Knowledge X Level:

Comprehension or Analysis 10 CFR Part 55 55.41 Content:

55.43 1,2,4 Comments:

KA is matched because 10CFR50 requirements for radioactive release are limitations in the facility license. SRO knowledge because the item requires knowledge of SLC (TRM) conditions that will require action by the SRO RFA Concurs 4/17/08 a

SRO Question 84 Based on Post Examination Test Item Analysis, accept both A and D as correct.

Both answers are correct and do not contain conflicting information.

Selected License Commitment (SLC) 16.11.3 states:

"16.11.3 Dose - Liquid Effluents COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS (see Figure16.11.1-1) shall be limited :

a. During any calendar quarter, to :5. 1.5 mrem to the total body and to :5. 5 mrem to any organ , and

b. During any calendar year, to :5. 3 mrem to the total body and to

~ 10 mrem to any organ.

APPLICABILITY At all times ."

Distracter D of the question reads

" 3 mrem whole body dose in a calendar year, AND 10 mrem organ dose in a calendar year". This is a direct match to 16.11.3.b as seen above.

The proposed answer of A is still correct as shown below:

"16.11.3 Dose - Liquid Effluents COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS (see Figure16.11 .1-1) shall be limited:

a. During any calendar uarter to < 1.5 mrem to the total bod and to:5. 5 mrem to any organ, and

b. During any calendar and to

5. 10 mrem to any organ.

APPLICABILITY At all times."

b SRO Question 84 The Post-exam Item Analysis indicated that 6 out of 9 applicants missed this question.

• 3 chose " B" - wrong because 3 mR is yearly limit , not quarterl y; 5 mR is quarterly limit, but to organs, not whole bod y.

• 1 chose "C" - wrong because 1.5 mR is quarterly limit to whole body dose, not yearly limit ; 5 mR is quarterl y limit to organs , not yearly limit

• 2 chose " D" - determined this is also a correct answer.

Question 84 ended up with two correct answers because a last minute change to C and 0 distracters was made without validating the technical accuracy. The intention was to correct what was thought to be a typo in both distracters.

How did this question get through validation?

The original question was not a two-part question. During validation, this question had a high miss rate. However, this was attributed to the fact that this SLC is more difficult to remember than other more common ones. When originally submitted, this question was determined to be unsat because oflow discriminatory value. On 4-15-08 (just prior to the written exam review in Atlant a), the question was revised to make each distracter two-part to increase its discriminatory value. At this time, the question had just one correct answer. It is shown on Attachment A.

On 4-16-08 , just prior to traveling to Atlanta, a change was made to Oistracters C and D.

The intention was to correct a typo. However, this change was not validated against the SLC, so no one detected the fact that "0 " was now a correct answer. This two-part question was not validated until after the written exam review in Atlant a.

During the post-Atlanta validation, 4 out of 4 individuals missed this question:

• 1 chose " B"

• 3 chose "C" The validation results were not questioned because of the assumption that this was just a difficult SLC question (based on the previous validation result s) that was made more difficult when it was made a two-part question Although no one picked "D ", this correct answer may have been detected if we had allotted adequate time to debrief each validator.

We have captured this lesson learned to ensure we allot adequate time to debrief all validators or at a minimum to more thoroughly investigate all high miss questions.

ATTACHMENT A This is what Q 84 looked like on 4-16-08:

Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF-31 , is disco vered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE (1) of the following describes the impact of this condition?

The dose or dose commitment to members of the public may exceed the requirements of 10CFR50 of....

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year.

c. 1.5 mrem whole body dose in a calendar year, AND 5 mrem ma calendar year.

D. 3 mrem whole body dose in a calendar year, AND 10 mrem ma calendar year Correct answer: A During a final review prior to our leaving for Atlanta, it was noticed that both parts of C and D deal with whole body dose in a calendar year. This made them obviously implausible. Therefore, the second was changed to "or gan". This change was not checked against the SLC, so no one realized that "D" was now a correct answer.

This error gave us the question that was administered to the applicants.

Subsequent review indicated the real typo was the "year" in the first part of C and D distracter. The "year" in the first part should have been changed to "q uarter". This would have made D incorrect. This is shown in Attachment B.

---

,.-=.-:-:---:-"

r A TT ACHMENT B The original intent of the question was to test the whole body dose limits per quarter and per year. All four distracters SHOULD have addressed quarter and year, not just year.

Given the following:

Turbine Building Sump to RC Radiation Monitor, EMF-31 , is discovered to have an alarm setpoint that is set ONE decade higher than required.

Which ONE (1) of the following describes the impact of this condition?

The dose or dose commitment to members of the public may exceed the requirements of 10CFR50 of. ...

A. 1.5 mrem whole body dose in a calendar quarter, AND 3 mrem whole body dose in a calendar year.

B. 3 mrem whole body dose in a calendar quarter, AND 5 mrem whole body dose in a calendar year.

C. 1.5 mrem whole body dose in a calendar J'\-"-af quarter, AND 5 mrem whole body dose in a calendar year.

D. 3 mrem whole body dose in a calendar Vaf quarter, AND 10 mrem whole body dose in a calendar year Correct answer: A

Attachment 4 SRO Question 87 After further investigation we propo se that Question 87 be deleted due to two correct answers that cont ain confl icting informati on.

The que stion uses the term "early transition out" , this is not a defined term in OMP 4-3, Use of Abnorma l and Emergency Procedures. This term can have two different meanings to the operators .

1) Leaving the procedure prior to readin g " RETU RN TO procedure and step in effe ct". In this case application of the Note prior to step 8 and use of step 8 would meet the definition of "early transiti on".

2) Leaving the proc edure prior to a procedural exit point. Step 8 could be seen as a structured exit path. Leaving the only opti on of "early transition" for use to apply a higher priority status tree.

One interpretati on can mean the operator uses the note prior to step 8 which states that the proc edure may be com pleted as a yellow path procedure if a fault ed S/G break occurs.

The stem of the question states a Main Steam Break has occurred. The operator can eva luate that exitin g the procedure using this note is an "early transition" out of the proce dure since the rema inder of the procedure has not been completed. Thi s would lead the opera tor to select choice A. Th is was the original correc t answer for this question .

Another interpretation can mean for the operator to temporarily susp end the procedure prior to a struc tured transition out of the procedure. Since step 8 stat es to "Per form the remainder of this EP as time allows" this could be considered a pro cedural transition out of FR-Z .l since FR-Z .1 is now considered a yellow path pro cedure. An example is listed in OMP 4-3 sections 7. 15. 1.4 and 7. 15. 1.5 (pages 17 & 18) ofa higher priority red or orange path proc edure, the operator is required to immediately impl ement the corresponding EP. Any recovery EP previ ously in progress shall be discontinued. The ope rator has not completed the steps in FR-Z.l. This may be eva luated as an "early transition" out of the procedure. This would lead the operator to select choi ce B as the COITect answer. With this interpre tation of "early transition " choice B would be correct.

Based on the operator interpretation of "early transition" this leads to two correct answers that cont ain confli cting information. Based on NUREG-1 021 ES-403 guidance this question should be deleted.

r

-A \f cchrn t",j- 4 p aj'~ 2-

.. ES-401 Sample Written Examination Form ES-40 1-5 Question Worksheet Examination Outline Cross- Level RO SRO reference:

Tier # 2 Group # 1 KIA # 026 A2 .03 Importance Rating

--"---=-------=------ _4_._4 Ability to (a) predict the impacts of the following malfunction s or operations on the CSS; and (b) based on those predictions, use procedure s to correct, control , or mitigate the consequenc es of those malfunctions or operations: Failure ofESF Proposed Question: SRO 87 Given the following:

• A Main Steam Break has occurred on Unit 1.

• The Train "A" Load Sequencer is de-energized .

• "B" NS Pump did NOT automatically start.

• The crew has transitioned to E-2, Fau lted Steam Generator Isolation, when the following conditions are observed:

o NC SYSTEM pressure 1400 ps ig and lowering.

o Containment Pressure 13 psig and rising.

Which ONE (1) of the following describes (1) the proper Status Tree entry and (2) the criteria for exiting FR-Z.1?

A . (1) ORANGE CSF Status T ree (2) Early transition out of FR-Z.1 is allowed after the NC Pumps and RV pumps are off and at least ONE NS Pump is running .

8. (1) ORANGE CSF Status Tree (2) Early transition out of FR -Z.1 is allowed ONLY if a higher priority ORANGE or RED condition occurs.

C. (1) RED CSF Status Tree (2) Early transition out of FR -Z .1 is allowed after the NC Pumps and RV pumps are off and at least ONE NS Pump is running.

D. (1) RED CSF Status Tree (2) Early transition out of FR -Z.1 is allowed ONLY if a higher priority RED condition occurs.

Page 230 of 27 1 Rev Final

A +\-t L~rnt",.J '-i pOJ G '3

• ES-401 Sample Written Examination Form ES-401-5 Question Worksheet Proposed Answer: A Explanation (Optional):

A. Correct. After step 8, procedure is treated as a yellow path for conditions such as a steam line break. This is determined by the SRO B. Incorrect. SRO should know that a steam break is occurring and note will apply that procedure may be treated as a yellow path after initial actions are performed C. Incorrect. Red path is 15 psig, but actions are correct D. Incorrect. Red path is 15 psig and procedure is treated as a yellow path after step 8 Technical FR-Z.1 (Rev 14) (Attach if not previously Reference(s) _ _ _ _ _ _ _ _ _ _ provided)

EP-FRZ Rev 15 OMP 4-3 p17, 18 Proposed references to be provided to applicants during None examination:

Learning Objective: EP-FRZ Obj 2 & 4 Question Source: Bank #

Modified Bank (Note changes or attach

1. parent)

New -X- - -

Question History: Last NRC Exam Question Cognitive Memory or Fundamental Knowledge Level:

Comprehension or Analysis X 10 CFR Part 55 55.41 Content:

55.43 -

Comments:

KA is matched because a containment spray failure has occurred. The impact is the result on CSF status, and the action required is also tested . SRO level Page 231 of 271 Rev Final

A TtcdVnl'"J- l-t . pOJ! Y i ES-401 Sample Written Examination Form ES-401-5 Question Worksheet because the SRO must select the appropriate strategy for procedure use, including a judgment of when the Containment Orange condition may be treated as a yellow condition RFA Concurs 4/17/08 Page 232 of 271 Rev Final

0 & '-~ ry'\f,",~ Lf Pq JC ~

MNS RESPONSE TO HIGH CONTAINMENT PRESSURE PAGE NO.

EP/1 /A/5000/FR-Z.1 2 of 44 Rev. 14 UNIT 1 ACTI ON/EXPE CTED RES PONSE RES PONSE NOT OBTA I NED C. Operator Actions

1. IF loss of emergency coolant recirc has occurred, THEN this procedure may be completed as time allows.

2. Monitor Foldout Page.

3. Stop all NC pumps.

4. Ensure all RV pumps are in manual and off.

CAUTION The following breakers must be closed within 50 minutes of S//.

5. Dispatch operator to remove white tags and close the following breakers:

• 1EMXA-R2A (1A NO To A&B Cold Legs Cont Outside Isol Motor (1NI-173A)) (aux bldg, 750, FF-54, FF-55)

• 1EMXB1-6B (1B NO To C&O NC Cold Leg Cont Outside Isol Motor (1NI-178B))

(aux bldg, 733, GG-55 , GG-56) .

6. Check containment pressure - LESS _ GO TO Step 9.

THAN 15 PSIG.

7. Check any NS pump - ON. _ GO TO Step 9.

The remainder of this EP may be completed with the priority of a yellow path EP.

Completion of this EP should be delayed if faulted S/G has occurred , or other higher priority actions are required.

8. Perform the remainder of this EP as time allows.

. ~- .:"o~ :.. :.~. .' .. , _ ,

OMP 4-3 Page 16 of35 7.14.2 The configuration control cards filled out in Step 7.14.1 shall be handled per the following two situations:

• Without Operations Support Center (OS C) activation The configuration control card will be handled by OPS shift per SOMP 02-0 1 (Safety Tagging and Configuration Contro l).

• With OSC activation WHEN the OSC is activated, OPS will report to the OS C and shall bring with them all configuration control cards that have been filled out. The cards taken to the OSC shall be given to the OPS SRO in the OSc. For handling card s in the OSC , refer to RP/o/AJ5700/020 (Activation of the Operations Support Center (OSC)) .

7. 15 Usage of Status Trees There are six different tree s, eac h one evaluating a separa te Critical Safety Function (CSF) of the plant. Color-coding of the status tree end points will be either red, orange, yellow, or green, with green representing a "satisfied" safe ty statu s. Each non -green co lor represents an action level that shou ld be addressed according to the Rules of Priority as discussed below.

The six Statu s Trees are always evaluated in the sequ ence:

• Subcriticality

• Core Coo ling

• Heat Sink

• Integrity

• Containment

• Inventory IF identical color prioriti es are found on different trees durin g monitoring, the requ ired action priority is determ ined by this sequence.

Initial monitoring of the status trees should begin on either of the following conditions:

• As directed by an action step in EP/ l ,2/ AJ5000/E-0 (Reac tor Trip or Safety Inj ection).

• WHEN a transfer is made out of the Safety Injection procedure to another EP.

An except ion to this is that CSF procedures are NOT required to be implemented dur ing the Loss of All AC Power EP since none of the electrically powered safeguards equipment can be used. WHEN power is subsequently restored, EPIl,2/A/5000 /ECA -0.l or 0.2 (Loss of All AC Power Reco very procedures) will direct the operator when implementing CSF procedures is requ ired.

OMP 4-3 Page 17 of35 7.15.1 Implementing CSF Path Procedures 7.15.1.1 CSF procedures are NOT to be implemented prior to transition from EPIl,2/A/5000/E-O (Reactor Trip or Safety Injection). IF a CSF path is red or orange while the operating crew is in EP/1,2/A/5000/E-O, but has turned to green upon transition from E-O, the CSF procedure which was in alarm shall NOT be implemented. IF the CSF path is yellow, it shall be handled as any other yellow path procedure per Section 7.15.1.7. IF there are any valid red or orange path CSF's on transition from E-O (unless transition is to EPIl,2/A/5000/ECA-O (Loss of All AC Power), the associated CSF procedure shall be implemented.

7.15.1.2 IF a valid red or orange path flickers into alarm on SPDS but returns to green prior to the crew validating the condition and implementing the procedure (implementation of procedure being that the SRO either hands out fold-out pages or starts reading from the procedure), the CSF procedure shall NOT be implemented. IF the CSF path is yellow, it shall be handled as any other yellow path procedure per Section 7.15.1.7. Likewise, if a valid red path or orange path goes into alarm during performance of a higher priority CSF procedure, but returns to green prior to transition from the higher priority CSF path procedure to the lower priority CSF procedure, the associated CSF procedure shall NOT be implemented.

7.15.1.3 IF a CSF procedure directs the operator to return to the procedure and step in effect, AND the corresponding status tree continues to display the offnormal conditions, the corresponding CSF procedure does NOT have to be implemented again, since all recovery actions have been completed. However, if the same status tree subsequently changes to a valid higher priority condition, OR if it changes to lower condition and returns to higher priority condition again, the corresponding CSF procedure shall be implemented as required by its priority.

7.15.1.4 Red Path IF any valid red path is encountered during monitoring, the operator is required to immediately implement the corresponding EP. Any recovery EP previously in progress shall be discontinued. IF during the performance of any red path procedure, a valid red condition of higher priority arises, the higher priority condition should be addressed first, and the lower priority red path procedure suspended.

OMP 4-3 Page 18 of35 7.15.1.5 Orange Path IF an y valid orange path is encountered, the operator is expected to scan all of the remaining trees, and then, if no valid red is encountered , promptly implement the corresponding EP. IF during the performance of an orange path pro cedure, an y valid red co nd ition or higher priority valid orange condition ari ses, the red or higher pri ority orange condition is to be addressed first, and the orig ina l orange path procedure suspended.

7.15.1.6 Complet ion of Red or Orange Path Procedure Once procedure is entered due to a red or orange condition, that procedure sho uld be performed to completion, unless preempted by some high er priority condition. It is expected that the actions in the procedure will clear the red or orange condition before all the operator actions are complete. However, these procedures should be per formed to the point of the defined transition to a specific procedure or to the "procedure and step in effect" to ens ure the condition remains clear. At thi s point any low er priority red or orang e paths curr ently indi cat ing or pre viously started but NOT completed shall be addressed.

FR-S.I , P.I and 2.1 can be entered from ei ther an orange or red path status . IF the color chang es from orange to red while you are in one o f the se EPs, the crew shou ld co ntinue and complete the EP from wh ere th ey are. Cr ew does NOT ha ve to backup and restart the EP. IF the orange path is exi ted, and it subsequentl y turns red , the EP must be re-entered at Step 1.

Upon continuat ion of recovery actions in Op timal Recovery procedure, som e judgment may be required by the operator to avoid inadvertent reinstatement of a Red or Orange condition by undoing so me critical step in the Function Recovery procedure.

The Op timal Reco ver y procedures are optimal assuming that safety equipme nt is av ailable. The app earan ce of a Red or Orange co ndition in mo st cases implies that some equipment or function required for safety is NOT ava ilable, and by implication some adj us tme nt ma y be required in the Optimal Recovery proc edure.

OMP 4-3 Page 19 of35 7.15.1.7 Yellow Path A yellow path does NOT require immediate operator attention.

Frequently, it is indicative of an off-normal and/or temporary condition which will be restored to normal status by actions already in progress. In other cases, the yellow status might provide an early indication of a developing red or orange condition. The operator is allowed to decide whether or NOT to implement any yellow path procedure.

Implementation of a yellow path function restoration guideline is based on operator judgment when it is determined that adequate time exists to implement it. In other words, the operator does NOT have to implement a yellow path guideline if a judgment has been made that it is inappropriate based on available time or current plant state; and if an event of higher priority is in progress, the operator should attend to the more important matters prior to implementing a yellow path function restoration guideline. In the prioritization scheme in the EPs, the Optimal Recovery procedures (including applicable foldout pages) have priority over the yellow path function restoration procedures.

The yellow path procedure can be considered as a supplementary set of actions that were provided to address one parameter being in an off-normal state. The controlling guideline in effect is the Optimal Recovery procedure that the operator is in when he decides that he has enough time to perform the yellow path procedure actions. While performing the actions of the yellow path, continuous actions or foldout page items of the optimal recovery procedure in effect are still applicable and should be monitored by the operator. This concurrent procedure usage should NOT cause the operator any difficulties since yellow path procedures are only performed when adequate time exists.

For example, if the operator is in ES-l.l (Safety Injection Termination) and decides to implement FR-H.5 because of low SO level and NC subcooling is lost while in FR-H.5, the operator should terminate FR-H.5 and implement the action of the ES-1.l foldout page to re-initiate SfI flow.

\0 OMP 4-3 Page 20 of3 5

7. 15.1.8 SPDS Normally, the condition of the status trees is continuously moni tored and displayed by the OAC. The OA C can be used to check any off-normal alarm and to determine which EP to implement. The ent ire Control Room crew is responsible for monitoring the SPDS .

SPDS indication must be validated using reliable control board indicators prior to imp lementing CSF procedure.

7.15.1.9 How Long to Mon itor Status Tree s Monitoring of status trees may be stopped when any of the following are met:

• Cold shutdown and TSC concurrence OR

• Transition to normal recovery procedure (OP)

OR

• Tran sition to a Severe Accident Mit igation Guideline (SAMG) 7.15.1.1 0 CSF procedur es should NOT be entered until the entry condition is met, except under conditions of 50.54x (reference Section 9).

P O..)C 1/

aMP 4-3 Page 21 of35

7. 16 Se lec ted Definition s Some words used in the eme rgency procedures ha ve unique mea nings . These un ique meanings should be und erstood based upon training and expe rience or by the spec ific use of the word in the context of the step bein g performed. Some word s with unique meanings are listed below :

Chec k to determine present status. (no action)

Ensure to take nec essary action s to guarantee tha t the co mponent or reading is as spec ified. (Loca l actions in EPs and AP s are only required if step specifies to dispatch personnel though).

Faulted refers to a steam generator tha t has a secondary break.

Ruptured refe rs to a stea m gene rator that has a primary to seconda ry leak (SGTR) .

Implement begin a req uired program or series of procedures.

Intact refers to a steam generator that is NOT faulted or ruptured and is avai lable as a heat sink.

GO TO di scontinue use of present procedure and stay in the referenced pro cedure. The referenced procedure is alw ays entered at the first step un less oth erwise specified.

REF ER TO . PER user is directed to a suppleme ntal procedure/enclosure for actions bu t will rem ain in the controlling pro cedure.

Stable Mai ntained ste ady. IF a parameter is bei ng contro lled within a desired ran ge, or if a slight trend in either direc tion is oc curring, op erator judgment may be used to de termine if parameter is co ns ide red sta ble.

Evalua te Appra ise the situ ation. Includes taking action based on evaluation.

7.17 Tolerances Ran ges or toleran ces are provided if it is imp ortant to maintain a parameter within a given band. WHE N a ran ge or tolerance (e.g., 5-15 % ) is provided, it is understood to mean extr a attentio n should be paid to maintain the param eter w ithin this ran ge.

WHEN a single va lue is given, it is assumed the value is an ideal value. WHEN an ideal valu e (e.g., at no load or 350 psig) is provided, it is understood to mean att ention should be paid to maintain the param eter at the ideal value but NOT be ove rly co nce m ed if the exact value is NOT ach ieved .

Examination Outline Cross- Level RO SRO reference :

Tier# 2 Group # 1 KiA #

-026-- A2 .03 Importance Rating -4.4---

Rev. 1 to the package Ability to (a) predict the impacts of the following malfunctions or operations on the CSS: and (b) based on those predictions, use procedures to correct control, or mitigate the consequ ences of those malfunctio ns or operations: Failure of ESF Proposed Question: SR087 Given the following:

• A Main Steam Break has occurred on Unit 1.

• The Train "A" Load Sequencer is de-energized.

• "B" NS Pump did NOT automatically start.

• The crew has transitioned to E-2, Faulted Steam Generator Isolation ,

when the following conditions are observed :

o NC SYSTEM pressure 1400 psig and lowering .

o Containment Pressure 13 psig and rising.

Which ONE (1) of the following describes (1) the proper Status Tree entry and (2) the criteria for exiting FR-Z.1?

A. (1) ORANGE CSF Status Tree (2) Early transition out of FR-Z.1 is allowed after the NC Pumps and RV pumps are off and at least ONE NS Pump is running.

B. (1) ORANGE CSF Status Tree (2) Early transition out of FR-Z.1 is allowed ONLY if a higher priority ORANGE or RED condition occurs.

C. (1) RED CSF Status Tree (2) Early transition out of FR-Z.1 is allowed after the NC Pumps and RV pumps are off and at least ONE NS Pump is running.

D. (1) RED CSF Status Tree (2) Early transition out of FR-Z.1 is allowed ONLY if a higher priority RED condition occurs .

Proposed Answer: A Explanation (Optional) :

A. Correct. After step 8, procedure is treated as a yellow path for conditions such as a steam line break. This is determined by the SRO B. Incorrect. SRO should know that a steam break is occurring and note will apply that procedure may be treated as a yellow path after initial actions are performed C. Incorrect. Red path is 15 psig, but actions are correct D. Incorrect. Red path is 15 psig and procedure is treated as a yellow path after step 8 Technical FR-Z.1 (Rev 14) (Attach if not previously Reference( s) _ _ _ _ _ _ _ _ _ _ provided)

EP-FRZ Rev 15 OMP 4-3 p17, 18 Proposed references to be provided to applicants during None examination:

Learning Objective: EP-FRZ Obj 2 & 4 Question Source: Bank#

Modified Bank (Note changes or attach

1. parent)

New -X - --

Question History: Last NRC Exam - - - -- - - - - - -- -- -

Question Cognitive Memory or Fundamental Knowledge Level:

Comprehension or Analysis X 10 CFR Part 55 55.41 Content:

55.43 -

Comments:

KA is matched because a containment spray failure has occurred . The impact is the result on CSF status, and the action required is also tested. SRO level because the SRO must select the appropriate strategy for procedure use, including a judgment of when the Containment Orange condition may be treated

l:: .

as a yellow condition RFA Concurs 4/17/08

.. " . -:-_ ', ": .:.~ - ,.." .- ,- ,. . ..~~-

Attachment 4 SRO Question 87 After further investigation we propose that Question 87 be deleted due to two correct answers that contain conflicting information.

The question uses the term "early transition out" , this is not a defined term in OMP 4-3, Use of Abnormal and Emergency Procedures. This term can have two different meanings to the operators.

1) Leaving the procedure prior to reading "RETURN TO procedure and step in effect". In this case application of the Note prior to step 8 and use of step 8 would meet the definition of "early transition".

2) Leaving the procedure prior to a procedural exit point. Step 8 could be seen as a structured exit path. Leaving the only option of "early transition" for use to apply a higher priority status tree.

One interpretation can mean the operator uses the note prior to step 8 which states that the procedure may be completed as a yellow path procedure if a faulted S/O break occurs.

The stem of the question states a Main Steam Break has occurred. The operator can evaluate that exiting the procedure using this note is an "early transition" out of the procedure since the remainder of the procedure has not been completed. This would lead the operator to select choice A. This was the original correct answer for this question .

Another interpretation can mean for the operator to temporarily suspend the procedure prior to a structured transition out of the procedure. Since step 8 states to "Perform the remainder of this EP as time allows" this could be considered a procedural transition out of FR-Z.1 since FR-Z.l is now considered a yellow path procedure. An example is listed in OMP 4-3 sections 7.15.1.4 and 7.15.1.5 (pages 17 &18) of a higher priority red or orange path procedure, the operator is required to immediately implement the corresponding EP. Any recovery EP previously in progress shall be discontinued. The operator has not completed the steps in FR-Z.1. This may be evaluated as an "early transition" out of the procedure. This would lead the operator to select choice B as the correct answer. With this interpretation of "early transition" choice B would be correct.

Based on the operator interpretation of "early transition" this leads to two correct answers that contain conflicting information. Based on NUREO-1 021 ES-403 guidance this question should be deleted .

The Post-exam Item Analysis indicated that 3 of 9 applicants missed this question.

• All 3 chose "B" - This is consistent with the confusion of what is considered an "early" transition in the FRP.

One applicant asked for clarification on this question while taking the exam. He asked "Is this question asking just for the set of circumstances as stated or anytime" He was told to just consider the question as stated. This applicant went on the miss the question picking distracter "B". I consider this occurrence to be consistent with the lack of clarity as described above.

How did this question get through Validation?

Question 87 was revised to its current state after the final validation prior to first submittal. Earlier validations for the question were not going well and we continued to refine it up through this date. In the final validation both operators picked distracter "B" which prompted me to raise the issue during our review in Atlanta . This resulted in a change in Distracter "B" to add the word "ONLY" in an attempt to address the clarity issue. At the time, all felt this should be sufficient. The question was revalidated prior to our final submittal with 4 operators with 2 of them still picking distracter "B". At this point we were 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> away from our deadline for the final submittal and this issue was not raised again due to the overall scores being acceptable and our lack of time to address every issue that came up.