ML17179A346

2017-06-Post Examination Comments

ML17179A346
Person / Time
Site:	Comanche Peak
Issue date:	06/19/2017
From:	Vincent Gaddy Operations Branch IV
To:	Peters K Vistra Energy
References
CP-201700482, TXX-17059
Download: ML17179A346 (38)

Text

CPNPP 2017 NRC WRITTEN EXAM RESULTS 7.1 - CPNPP NRC 2017 Written Exam Analysis Original Grading (As Given).xls 1-75 RO / 75-100 SRO Only VALUE: 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Date: 6/19/17 KEY ANSWERS: D B C A D C A D D A C C A A D B B A A D C B A A D A B C C C A D C C D C C D C B B D B C B C D D A D Name TOTAL% PTS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 RO1 82.7 62.0 B C A B A C RO2 92.0 69.0 B B B RO3 92.0 69.0 B C A C SRO1 88.8 87.0 C D A B SRO2 82.7 81.0 B B D A C C SRO3 88.8 87.0 B B D B Total Missed 1 3 1 1 2 3 3 1 1 1 1 1 2 1 3 2 VALUE: 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 KEY ANSWERS: B A B A B A A C B A B B C C B C C D A A A C D C A A D C B C C D C D C A B C A B D D A B D A C D D C Name SRO % RO % 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 RO1 82.7 D D C D A A C RO2 92.0 A A B RO3 92.0 D C SRO1 78.3 92.0 C A B C A C B SRO2 69.6 86.7 D D D B C B A C B C B SRO3 82.6 90.7 A A D D C B C Total Missed 2 1 2 3 1 1 3 2 1 2 1 1 1 1 2 1 2 1 1 2 2 1 2 1 SRO Total Points = 98 RO Only Points = 75 SRO Only Points = 23 RO Questions Average = 89.3 SRO Questions Average = 76.8 Class Average = 87.8 1 of 1

Question 82 Recommend changing correct answer to C During written examination review of the CPNPP 2017 NRC exam it was identified that Question 82 was incorrectly keyed. In particular:

Reason 1 Part 2 of the question states: In accordance with ABN-712, Section 3, Dropped or Misaligned Rod in Mode 1 or 2 The question construction required the applicants to determine the sequence of events as listed in the bullets from top to bottom. The plant is at 90% power (first bullet) and with no other action the DRPI ROD DEV alarm is lit (second bullet). The DRPI ROD DEV alarm comes in when a rod is 12 steps from the remaining rods which means the rods had to drop into the core Also, informing the applicants that the crew had entered Section 3 caused each SRO applicant to make the determination the rods had dropped to a position of greater than 12 steps from the remaining rods in Control Bank D. Therefore, Section 3, Step 1, RNO sub-step a) would be appropriate for this dropped rod condition (Trip Reactor and enter EOP-0.0A immediately)

Based on the locations of Control Rods D4 and H8, if they had dropped into the core, then flux distribution of the core would be significantly affected. The magnitude of core flux imbalance was not provided to the applicants Per ABN-712, a dropped rod will cause a distortion of the symmetrical flux distribution of the reactor core. This distortion will be reflected as a deviation in the power range and N16 indications. A dropped rod is not defined solely by rod bottom lights Applicants are trained to conservatively trip the reactor per ABN-712, Section 3 if there are indications of two dropped rods rather than questioning the degree of misalignment The correct answer as approved on the worksheet and answer key is D Distractors A and B are incorrect based on Part 1 of the question See attached figures of core flux distribution Reason 2 If the stem had informed the applicants that ABN-712, Section 2 was in progress the correct answer would still be distractor C, as Control Rods D4 and H8 were stationary with demand signals (i.e. insertion) being applied from the Control Room, therefore Section 2, Step 2, RNO sub-step b), 3rd bullet would be appropriate (Trip Reactor and enter EOP-0.0A immediately)

The correct answer as approved on the worksheet and answer key is D Distractors A and B are incorrect based on Part 1 of the question Solution:

CPNPP has determined that Question 82 was keyed incorrectly.

CPNPP recommends changing the correct answer to C

NUREG-1021 justification: The proposed revision is in agreement with NUREG-1021 Rev. 10 ES-403 D.1.b 3rd bullet which states newly discovered technical information that supports a change in the answer key.

Supporting Documentation:

Simulation of Control Rods D4 and H8 dropped 195 steps into the core Rod Control in manual, D4 and H8 at 20 steps with the remainder of CBD at 215. Note the significant radial flux shift in the quadrants as noted on N43 and N44. Tave/Tref deviation is -9.55°F causing an RCS pressure reduction to 2192 psig and pressurizer level reduction of greater than 10% from program prior to systems responding and recovering the parameters

Simulation of Control Rods D4 and H8 dropped 15 steps into the core Rod Control in manual, D4 and H8 at 200 steps with the remainder of CBD at 215. Radial flux shift is minor as is the temperature deviation and limited effect on pressurizer pressure and level.

Comments /

Reference:

ABN-712, Section 3 Revision: 11

Comments /

Reference:

ABN-712, Section 2 Revision: 11

Original Question:

Examination Outline Cross-reference: Level RO SRO Rev. Date: Rev. 1 Tier 1 Group 2 K/A 005 AA2.03 Level of Difficulty: 2 Importance Rating 4.4 Inoperable/Stuck Control Rod: Ability to determine and interpret the following as they apply to the Inoperable / Stuck Control Rod: Required actions if more than one rod is stuck or inoperable.

Question # 82 Unit 1 plant conditions:

Reactor power = 90%

1-ALB-06D, Window 3.5, DRPI ROD DEV is lit 1-ALB-06D, Window 3.7, ANY ROD AT BOT is dark Control Rod D4 and H8 (both in Control Bank D) will not respond to demand signals from the Control Room Troubleshooting has determined the Rods are mechanically bound ABN-712, Rod Control System Malfunction has been entered SDM has been verified Based on the above plant conditions, complete the following statements.

1. Control Rods D4 and H8 ___(1)___ considered OPERABLE per TS 3.1.4, Rod Group Alignment Limits.

2. In accordance with ABN-712, Section 3, Dropped or Misaligned Rod in Mode 1 or 2, the crew is required to ___(2)___.

A. (1) are (2) trip the reactor immediately and GO TO EOP-0.0A, Reactor Trip or Safety Injection B. (1) are (2) shut down to Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> using IPO-003A, Power Operations C. (1) are NOT (2) trip the reactor immediately and GO TO EOP-0.0A, Reactor Trip or Safety Injection D. (1) are NOT (2) shut down to Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> using IPO-003A, Power Operations Answer: DC

K/A Match:

This question matches the KA by requiring the ability to determine the correct actions for two stuck control rods.

SRO Only:

NUREG 1021, ES-401, Attachment 2:

E. Assessment of facility conditions and selection of appropriate procedures during normal, abnormal, and emergency situations. [10 CFR 55.43(b)(5)]

This 10 CFR 55.43 topic involves both 1) assessing plant conditions (normal, abnormal, or emergency) and then 2) selecting a procedure or section of a procedure to mitigate, recover, or with which to proceed. One area of SRO level knowledge (with respect to selecting a procedure) is knowledge of the content of the procedure versus knowledge of the procedures overall mitigative strategy or purpose.

B. Facility operating limitations in the TS and their bases. [10 CFR 55.43(b)(2)]

Some examples of SRO exam items for this topic include: 1) Application of Required Actions (Section 3) and Surveillance Requirements (SR) (Section 4) in accordance with rules of application requirements (Section 1). 2) Application of generic Limiting Condition for Operation (LCO) requirements (LCO 3.0.1 thru 3.0.7; SR 4.0.1 thru 4.0.4). 3) Knowledge of TS bases that are required to analyze TS required actions and terminology. 4) Same items listed above for the Technical Requirements Manual (TRM) and Offsite Dose Calculation Manual (ODCM).

While not asking the section in ABN-712 to be performed, the actions contained in the answers are from different sections in the procedure.

Explanation:

A. Incorrect. 1st part is incorrect because IAW T.S. 3.1.4, to be operable, the affected rods must be trippable and with the rod mechanically bound it is not trippable. It is plausible because one must know that the operability of the rod is specifically tied to trippability, it is a common misconception that rods may still be operable even though they cannot be tripped as the SDM of the core has remained unchanged as long as power and boron concentration has not changed. 2nd part is incorrect because you are not required to trip the reactor. It is plausible because if the two rods had dropped, it would be correct.

B. Incorrect. 1st part is incorrect but plausible (see A). 2nd part is correct. With 2 rods misaligned from the step counter by > 12 steps (as verified by the alarm), the plant is required to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> using IPO-003A.

C. Incorrect. 1st part is correct. IAW ABN-712, if the control rods are not capable of motion (i.e.

mechanically bound), they are not considered trippable; if they are not trippable they are not operable per TS 3.1.4. 2nd part is incorrect but plausible (see A).

D. Correct. 1st part is correct (see C). 2nd part is correct (see B).

Technical Reference(s) ABN-712 Attached w/ Revision #

See Comments /

1-ALB-6D Reference TSB 3.1.4 Proposed references to be provided during examination:

Learning ANALYZE the response to a Dropped or Misaligned Rod in MODE 1 or 2 in

Objective: accordance with ABN-712, Rod Control System Malfunction.

(LO21.ABN.712.OB02)

Question Source: Bank #

Modified Bank # (Note changes or attach parent)

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

Comprehension or Analysis X 10 CFR Part 55 Content: 55.41 55.43 43.5

Comments /

Reference:

ABN-712 Revision: 11 Section 2.0 Definition for Trippable as stated in ABN-712

Section 3.0 (the correct section)

Comments /

Reference:

1-ALB-6D Revision: 6 Definition of OPERABLE per TS 3.1.4 Question 93 Recommend changing correct answer to C During written examination review of the CPNPP 2017 NRC exam it was identified that the approved answer of Question 93 is contrary to the guidelines provided to Operations Department personnel and how business is conducted at the plant.

In particular:

Reason:

The approved answer on the worksheet and the key is A Distractors B and D are incorrect based on Part 2 of the question Per Operations Guideline 3, Section 3.2, SRO Expectations, all discharge permits are to be authorized by the Control Room SRO with Command Function and documented in the Station Log The question stem does NOT state that the Unit Supervisor has relieved the Shift Manager of the Command Function, leading to 2 of the 3 applicants incorrectly selecting C as the correct answer. The standard operations protocol is only an SRO with Command Function may authorize a release Command Function is the responsibility of the Shift Manager and can be turned over to an SRO in the Control Room. However, this is a formal process and must be documented in the Station Log Per ODA-102, in order for an SRO to relieve the Shift Manager of Command Function he/she must have an active license and be a member of management Per Nureg-1021, Appendix E, Policies and Guidelines for Taking NRC Examinations:

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.

The applicants stated while taking the examination they did not assume the Unit Supervisor had Command Function and answered the question accordingly Solution:

CPNPP has determined the approved answer to Question 93 is contrary to the Operations Guidelines and applicants would have to make inappropriate assumptions to answer per the approved exam key.

CPNPP recommends changing the correct answer to C NUREG-1021 justification: The proposed revision is in agreement with NUREG-1021 Rev. 10 ES-403 D.1.b 3rd bullet which states newly discovered technical information that supports a change in the answer key.

Supporting Documentation:

Comments /

Reference:

Nureg-1021, Appendix E Revision: 10

Comments /

Reference:

OPGD 3 Revision: 2/20/17 Comments /

Reference:

ODA-102 Revision: 27 Original Question:

Examination Outline Cross-reference: Level RO SRO Rev. Date: Rev. 1 Tier 2 Group 2 K/A 068 G2.2.38 Level of Difficulty: 2 Importance Rating 4.5 Liquid Radwaste: Knowledge of conditions and limitations in the facility license.

Question # 93 Plant conditions:

A Batch Liquid Radioactive Effluent Release is planned Based on the above plant conditions, complete the following statements.

1. In accordance with STA-603, Control of Station Radioactive Effluents, review and approval of the batch release ___(1)___ be delegated to the Unit Supervisor.

2. If the quantity of radioactive material in the Liquid Holdup Tank to be released is 11 Curies, it ___(2)___exceed the limit stated in TR 13.10.33, Explosive Gas and Storage Tank Radioactivity Monitoring Program, Liquid Holdup Tanks.

A. (1) can (2) does B. (1) can (2) does NOT C. (1) can NOT (2) does D. (1) can NOT (2) does NOT Answer: AC

K/A Match:

The question is a match to the K/A as it requires knowledge of conditions in the facility license.

SRO Only:

NUREG 1021, ES-401 Attachment 2 D. Radiation hazards that may arise during normal and abnormal situations, including maintenance activities and various contamination conditions. [10 CFR 55.43(b)(4)]

Some examples of SRO exam items for this topic include:

• Process for gaseous/liquid release approvals, i.e., release permits.

• Analysis and interpretation of radiation and activity readings as they pertain to selection of administrative, normal, abnormal, and emergency procedures.

• Analysis and interpretation of coolant activity, including comparison to emergency plan criteria and/or regulatory limits.

Explanation:

A. Correct. 1st part is correct. The responsibility may be delegated by the Shift Manager to the Unit Supervisor. 2nd part is correct per TR 13.10.33, the limit is 10 Curies.

B. Incorrect. 1st part is correct (see A). 2nd part is incorrect but plausible because per TR 13.10.33, the limit is 10 Curies and it were 1 Curie less it would be within the limit.

C. Incorrect. 1st part is incorrect because this responsibility can be designated to a Unit supervisor. It is plausible because what can and cannot be designated varies on the responsibility of the Shift Manager. 2nd part is correct (see A).

D. Incorrect. 1st part is incorrect but plausible (see C). 2nd part is incorrect but plausible (see B).

Technical Reference(s) STA-603 Attached w/ Revision #

See Comments /

TRM Reference Proposed references to be provided during examination:

Learning DESCRIBE the components of the Spent Fuel Pool Cooling and Cleanup Objective: system including interrelations with other systems to include interlocks and control loops. (LO21.SYS.SF1.OB03)

Question Source: Bank #

Modified Bank # (Note changes or attach parent)

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

Comprehension or Analysis 10 CFR Part 55 Content: 55.41 55.43 43.1

Comments /

Reference:

STA-603 Revision: 21 Comments /

Reference:

TR 13.10.33 Revision: 65 Question 99 Recommend removing question from exam Problem: During written examination review of the CPNPP 2017 NRC exam it was identified that the approved answer of Question 99 Part 1 has been removed from all Station Administrative procedures and the change management process failed to address the Operations Department Administrative procedures.

In particular:

Reason:

The term Controlled in reference to copies of procedures is no longer used and has been removed from CPNPP station administrative procedures The procedure used to develop Question 99 Part 1 (ODA-407) has not been properly updated. This information was discovered during exam review and was not known during development An Issue Report (IR) has been generated to document and correct the Issue associated with the change management process in regard to STA-306, Document Control (which was updated) and other department procedures not being updated properly The approved answer on the worksheet and the key is D Distractors A and C are incorrect based on Part 2 of the question Distractors A and B are incorrect based on Part 1 of the question Distractor D is incorrect as the term Controlled is no longer correct with regards to Station Administrative procedures The question has no correct answer as written The term Controlled Copy was used in the past to identify hard copy procedures which were maintained to the latest Rev/PCN. They were for procedure sets located in areas such as the Control Room and Simulator. These procedures were stamped on the cover page to identify them as controlled copies.

The current revision of STA-306, Document Control, dated 12/3/15, identifies the location for these procedure sets as Hard Copy Locations (HCL), defined as Recipients of paper reproductions of documents for which distribution is tracked and for which revision control is maintained. The documents in these locations are referred to as distributed documents. They are no longer stamped nor considered as controlled copies.

Solution:

CPNPP has determined the approved answer to Question 99 is contrary to Station Administrative procedures and there are no other distractors that are correct.

CPNPP recommends removing Question 99 from the exam.

NUREG-1021 justification: The proposed revision is in agreement with NUREG-1021 Rev. 10 ES-403 D.1.b 3rd bullet which states newly discovered technical information that supports a change in the answer key.

Supporting Documentation:

Comments /

Reference:

STA-306 Revision: 29

Original Question:

Examination Outline Cross-reference: Level RO SRO Rev. Date: Rev. 2 Tier 3 Group K/A G2.4.11 Level of Difficulty: 3 Importance Rating 4.2 Knowledge of abnormal condition procedures.

Question # 99 Unit 1 plant conditions:

Unit 1 is responding to a plant transient in an ABN Shift Manager is in the daily POD meeting at the MSC The Unit 1 US has been assigned Command Function In accordance with ODA-407, Operations Department Procedure Use and Adherence complete the following statements.

1. When using the ABN during the plant transient, it is desirable to write on the

___(1)___ copy.

2. A deviation from the ABN is required; the Unit 1 US has approved the deviation.

The Unit 2 US ___(2)___ authorized to concur with the deviation.

A. (1) working (2) is NOT B. (1) working (2) is C. (1) controlled (2) is NOT D. (1) controlled (2) is Answer: D

K/A Match:

This question matches the KA by requiring knowledge of how to physically utilize abnormal procedures in the control room and if SM approval is required to deviate from the ABN during use.

SRO Only:

NUREG 1021, ES-401 Attachment 2 E. Assessment of facility conditions and selection of appropriate procedures during normal, abnormal, and emergency situations. [10 CFR 55.43(b)(5)]

This 10 CFR 55.43 topic involves both 1) assessing plant conditions (normal, abnormal, or emergency) and then 2) selecting a procedure or section of a procedure to mitigate, recover, or with which to proceed. One area of SRO level knowledge (with respect to selecting a procedure) is knowledge of the content of the procedure versus knowledge of the procedures overall mitigative strategy or purpose.

The applicants knowledge can be evaluated at the level of 10 CFR 55.43(b)(5) by ensuring that the additional knowledge of the procedures content is required to correctly answer the written test item, for example:

• Knowledge of when to implement attachments and appendices, including how to coordinate these items with procedure steps.

• Knowledge of diagnostic steps and decision points in the emergency operating procedures (EOP) that involve transitions to event specific sub-procedures or emergency contingency procedures.

• Knowledge of administrative procedures that specify hierarchy, implementation, and/or coordination of plant normal, abnormal, and emergency procedures.

Explanation:

A. Incorrect. 1st part is incorrect because per ODA-407, ABN Rules of Usage: During performance of Abnormal Operating Procedures, it is desirable to write on the control copy as a log or place keeping tool. It is plausible because this is not the normal practice. 2nd part is incorrect because when a deviation is required, an SRO must approve the deviation and a second SRO must concur. It is plausible because the Shift Manager is preferred, but not required. Therefore, if thought the shift manager was required then Unit 2 US would not be authorized to concur.

B. Incorrect. 1st part is incorrect but plausible (see A). 2nd part is correct. The Unit 2 US is authorized to concur with the deviation. Shift Manager permission for a deviation, while preferred, is not a requirement.

C. Incorrect. 1st part is correct. For Abnormal Operating Procedures, it is desirable to write on the control copy. 2nd part is incorrect but plausible (see A).

D. Correct. 1st part is correct (see C). 2nd part is correct (see B).

Technical Reference(s) ODA-407 Attached w/ Revision #

See Comments /

Reference Proposed references to be provided during

examination:

Learning Objective: STATE requirements for Conduct of Operations in accordance with ODA-102, ODA-407 and Ops Guideline 3 Question Source: Bank #

Modified Bank # (Note changes or attach parent)

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

Comprehension or Analysis 10 CFR Part 55 Content: 55.41 55.43 43.5

Comments/

Reference:

ODA-407 Revision: 16