ML20276A128
| ML20276A128 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/02/2020 |
| From: | NRC/RGN-II |
| To: | Southern Nuclear Operating Co |
| References | |
| 50-348/OL-20, 50-364/OL-20 50-348/20-301, 50-364/20-301 | |
| Download: ML20276A128 (13) | |
Text
ML20276A128 FA2020-301 Post Exam Comments (Written Exam)
Comment 1 Comment Source: Applicant Comment Exam Item: SRO Written Exam, Question 94 Question:
Keyed Answer: A. (1) IS (2) IS
Reference:
NMP-OS-007-001, Conduct of Operations Standards and Expectation Page 1 of 3
FA2020-301 Post Exam Comments (Written Exam)
Comment:
The first part of the question asks whether the motor-operated valve is operable or is not operable. This cannot be determined from the conditions stated in the stem of the question. The motor-operated valve should be considered inoperable by the SRO until electrically stroked and returned to remote service. The valve may be declared operable by the SRO after it has been placed in its required safety position before electrically cycling the valve. The second part of the two-part question is not challenged.
Recommendation:
Change the Key for the SRO Written Exam. The key change should reflect that both A and B are correct responses for question 94.
Basis:
x NMP-AP-003, Procedure and Work Instruction Use and Adherence, defines the following terms as follows:
o Shall - Denotes a requirement or mandatory activity.
o Should - Denotes a management expectation that is to be performed unless specific conditions preclude it.
o May - Denotes permission, neither a requirement or expectation.
x NMP-OS-007-001, Conduct of Operations Standards and Expectations, contains the following procedural guidance for motor-operated valves (MOV), which have been manually actuated using the hand wheel operator:
o Should normally be manually unseated and stroked using the motor operator prior to returning it to remote service and declaring it operable/functional unless an engineering evaluation is performed.
o May be considered operable/functional if it is in its required safety position, but will require administrative tracking until electrically cycled.
x There are no conditions stated that preclude stroking the motor-operated valve and returning it to remote service prior to declaring the valve operable nor do conditions state than any engineering evaluation has been performed.
x The SRO would be allowed to declare the valve operable prior to electrical cycling since it is stated that the valve is in its required safety position, but declaring the valve operable is not required. Depending on plant conditions, the SRO is most likely to elect to stroke the valve electrically and return it to remote service prior to declaring the valve operable.
x Based on the above information and procedural standards related to MOV operability after manual operation, the correct answer to the first part of the question cannot be determined, and both answers of is operable and is not operable are correct.
Page 2 of 3
FA2020-301 Post Exam Comments (Written Exam)
Facility Position:
FNP agrees with the comment and recommendation. Both answers A and B are correct.
The question does not provide the plant conditions necessary to discriminate between a determination of is operable vs. is not operable for first part of the two-part question. Based on the standards of NMP-OS-007-001 and the definitions of should and may provided in NMP-AP-003, the motor-operated valve may be declared operable but should be manually unseated using the motor operator prior to returning it to remote service and declaring it operable unless plant conditions preclude it. This is consistent with past and current operational practices.
Basis:
x The standards noted by the applicant from NMP-OS-007-001 and NMP-AP-003 are stated correctly for motor-operated valves that have been manually operated:
o Should normally be manually unseated and stroked using the motor operator prior to returning it to remote service and declaring it operable/functional unless an engineering evaluation is performed.
o May be considered operable/functional if it is in its required safety position, but will require administrative tracking until electrically cycled.
o Should - Denotes a management expectation that is to be performed unless specific conditions preclude it.
o May be considered operable/functional if it is in its required safety position, but will require administrative tracking until electrically cycled x The standards require the Senior Reactor Operator (SRO) to determine whether or not plant conditions preclude stroking the valve prior to declaring the valve operable. The most likely factor influencing this decision is the availability of the power supply to the motor-operated valve. For example, it is likely that the valves power supply would be returned to service on the same clearance, but also plausible that it is held on a separate clearance and therefore unavailable. The operational context provided in the question (clearance return-to-service) is limited and does not provide this information.
o If the candidate assumes that the valves power supply is available, then the valve should be stroked electrically prior to declaring it operable.
o If the candidate assumes that the valves power supply is not available, then it is permitted to declare the valve operable once the valve is in its safety position, but this is not required.
x The question required the candidates to make a definitive statement that a motor-operated valve that has been manually operated to its safety position either is or is not operable. The standards referenced and the limited plant conditions provided in the stem of the question do provide sufficient information to make this determination.
x NUREG-1021, ES-403, D.1.b, states that a question that did not provide all the necessary information can result in a post-examination change if identified and adequately justified by the facility licensee or applicant.
x Based on the above information, it is the facilitys position that the question did not provide the necessary information to determine the correct answer for the first part of the two-part question. The second part of the question is valid and is not challenged.
Page 3 of 3
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FA2020-301 Post Exam Comments (Operating Exam)
Comment 1 Comment Source: Applicant Comment Exam Item: Simulator Scenario 1, Event 5
References:
FNP-1-AOP-100, Instrumentation Malfunction, Revision 23.0 Comment: The ESD-2 for Scenario 1, Event 5 did not use the correct revision for AOP-100, Section 1.4, Step 3. The exam evaluator guidance did not align with the procedural requirement.
Recommendation: Revise Simulator Scenario 1, Event 5 ESD-2 to align with AOP-100, Version 23.0, Section 1.4, Step 3, as follows:
REPLACE: IF a ramp is in progress place the turbine on HOLD.
WITH: IF desired to stabilize the plant and a ramp is in progress, place turbine on HOLD.
Facility Position: FNP agrees with the comment and recommendation. Applicants were not required to stop the ramp unless they determined it was necessary to stabilize the plant. This is allowed by the conditional statement included in AOP-100, Version 23.0, Section 1.4, Step 3. Additionally, the facility found the same error repeated in the ESD-2 for Scenario 2, Event 5.
Page 1 of 3
FA2020-301 Post Exam Comments (Operating Exam)
Comment 2 Comment Source: Applicant Comment Exam Item: JPM D, Element 6
Reference:
FNP-1-ESP-1.1, Revision 27.0 Comment: The Task Standard for Element 6 of JPM D does not align with the procedural requirements in ESP-1.1, Revision 27.0, Step 14.1.4, which states, Open letdown orifice isolation valve(s). Based on the step 14.1.4 specifying valve (singular) or valves (plural), opening only one letdown orifice isolation valve meets the action/expected response for the step and would prevent application of the response not obtained column to place excess letdown in service.
Recommendation: Revise the Task Standard for Element 6 to align with ESP-1.1 as follows:
REPLACE: Open HV8149A and HV8149B OR HV8149C WITH: Open letdown orifice isolation valve(s). HV8149A AND HV8149B OR HV8149C.
Facility Position: FNP agrees with the comment and recommendation. Step 14.1.4 of ESP-1.1 is written to allow valve (singular) or valves (plural) to satisfy the action/expected response. The purpose of the step per FNP-0-ESB-1.1, SI Termination Plant Specific Background Information, is to establish a controlled bleed path from the RCS for lowering and control of PRZR level. Any one of the letdown orifices provide sufficient flow to establish an RCS bleed path, maintain seal injection, establish charging, and control PRZR level. This intent is confirmed by the fact that it would not be expected or desired to perform the response not obtained column, Step 14.1 to establish excess letdown if only one orifice is placed in service. The intent of the AND and OR connectors in the bullets of step 14.1.4 is to ensure that if two letdown orifices are place in service that the two include the 45 gpm orifice (HV8149A) and one of the 60 gpm orifices (HV8149B or HV8149C) vs. two 60 gpm orifices. Based on actual plant data, two 60 gpm orifices can result in greater than the allowed flow through the CVCS demineralizers. The AND and OR connectors are not intended to imply that two letdown orifices are required to satisfy the action/expected response of the step. A procedure change for ESP-1.1 has been entered into the Corrective Action Program to enhance the step in question.
Page 2 of 3
FA2020-301 Post Exam Comments (Operating Exam)
Comment 3 Comment Source: Applicant Comment Exam Item: SRO ONLY ADMIN JPM A.3, Element 2
Reference:
NMP-HP-302, Restricted Area Classification, Postings, and Access Control, Revision 10.11.
Comment: Additional compensatory options are available to ensure only authorized individuals can gain access to the LHRA per NMP-HP-302; the task standard for Element 2 does not allow for all available options.
Recommendation: Revise SRO A.3 JPM, Element 2 Task Standard and key to add allowance for use of a flashing light and barrier in lieu of a locked barricades with approval of the Radiation Protection Manager or designee per NMP-HP-302 guidance.
Facility Position: FNP agree with applicants comment and recommendation. The additional compensatory measures stated by the applicant are allowed by NMP-HP-302 for the stated conditions of the JPM. Based upon station practices a guard would be required unless the RP Manager gives permission and a justification for using the flashing red light and barrier. This option of utilizing flashing red lights in lieu of a guard has been utilized by the site in the past, however, not on a routine basis.
Page 3 of 3
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