ML20112F576

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Submits Comments Re Written Exam Administered at Licensee Facility on 960506
ML20112F576
Person / Time
Site: Catawba  Duke energy icon.png
Issue date: 05/16/1996
From: Mccollum W
DUKE POWER CO.
To: Peebles T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20112F006 List:
References
NUDOCS 9606100011
Download: ML20112F576 (9)


Text

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Doe Power Company (803)S31J000 Catawba Nuclear Station 4800 Concord Road York, SC 29745 1 DUKEPOWER May 16,1996 l

Mr. Thomas Peebles, Chief Operations Branch Division of Reactor Safety ,

U.S. Nuclear Regulatory Commission ' '

l 101 Marietta Street, NW Atlanta, GA 30323 i

SUBJECT:

Catawba Nuclear Station Senior Reactor and Reactor Operator Exams (5/6/96) Comments The following comment is offered concerning the written exams administered at Catawba Nuclear Station on May 6,1996. Our exam review did not identify two correct responses for question 009 of the Reactor Operator Exam and question 004 of the Senior Reactor Operator Exam:

QUESTION: 009 (1.00) Reactor Operator Exam l QUESTION: 004 (1.00) Senior Reactor Operator Exam WHICH ONE of the following describes who can make changes to Block Tag Out (BTO) boundaries besides the BTO Coordinator?

a. The Shift Work Manager I l
b. The Operational Control Group Supervisor
c. The Work Group Supervisor
d. The Work Control Center SRO ANSWER: b

REFERENCE:

NSD 500, pg. 500-31, OMP 2-18, Attachment 7, Pg. 3.

KA 194001K102 [3.7/4.1) 9606100011 960603 PDR ADOCK 05000413

.. V PDR naimwm

, -- . . ~ .

. 1 Mr. Thomas Pceblas O O l CNS SRO & SRO Exam Comments (5/6/96) l Page 2 l

i COMMENT:

Per the reference given above and shown on the attached highlighted copy, the responsibility for BTO boundary changes lies with the Operational Control Group.

The Operational Control Group Supervisor is a member of the Operational Control Group. The Work Control SRO is a member of the Operational Control Group. ,

l There are two Operational Control Groups; Chemistry and Operations. The Work Control Center SRO is a member of Operations.

l RECOMMENDATION:

Change answer keys to accept b or d as a correct answer and modify the exam bank for future use. ,

1 We apologize for any inconvenience this may cause.

Sincerely,

\ l  %  %

William R. McCollum 4

Site Vice President Catawba Nuclear Station SRF/ jet cc: Mr. Paul Steiner Gail Addis Steve Frye Attachments: Justification l

l I

', REACTOR OPERATOR Page 11 QUESTION: 009 (1.00)

WHICH ONE of the following describes who can make changes to Block Tag Out (BTO) boundaries besides the BTO Coordinator?

a. The Shift Work Manager
b. The Operational Control Group Supervisor
c. The Work Group Supervisor
d. The Work Control Center SRO QUESTION: 010 (1.00)

WHICH ONE of the following lists the two-way radio channel (s) that MUST be used for direct communications with Catcwba Nuclear Station Safety Department?

a. Channel #1
b. Channel #2
c. Channel #2 and #3
d. Channel #3 QUESTION: 011 (1.00)

WHICH ONE of the following describes a Containment space with a condition that at N0 time will entry be allowed into that space?

a. The Annulus during Mode 1 operations at greater than 80% power.
b. The Annulus during Mode 4 operations with an Incore Instrumentation detector in motion.
c. Lower Containment, outside the Crane Wall, during Mode 1 operations at 40% power.
d. Lower Containment, inside the Crane Wall, during Mode 1 operations at 20% power. ,

. SENIOR REACTOR OPERATOR A Page 8 U

QUESTION: 003 (1.00)

WHICH ONE of the following constitutes a Hazardous Atmosphere as defined in the Confined Space Entry Directive? (Nuclear System Directive 109,

" Confined Space Entry," is available for reference.)

a. An atmospheric oxygen concentration of 19.9 percent,
b. An atmospheric hydrogen concentration of 0.9 percent.
c. Airborne combustible dust at a concentration that obscures vision at a distance of 19 feet.

l

! d. An atmospheric concentration of a substance that could cause an operator to exceed 10% of the Permissible Exposure Limit for that substance in an extended exposure.

l QUESTION: 004 (1.00)

WHICH ONE of the following describes who can make changes to Block Tag Out (BTO) boundaries besides the BTO Coordinator?

a. The Shift Work Manager I
b. The Operational Control Group Supervisor
c. The Work Group Supervisor
d. The Work Control Center SRO l

O O d V Nuclear Policy Manual Volume 2 l NSD 500.3 Definitions

. Providing a tag for use.

. Venfymg the entries on the tag and tagout log.

. Signing the tag for approvsl to place.

Lockable An energy isolating device is lockable ifit has a built in locking mechamtm, a hasp, or another way to attach a lockout device.

Lockout Placement of a lockout device on an energy isolating device. 'Be lockout device ensures that the energy-isolating device and the controlled equipment cannot be operated until the device is removed.

Lockout /BloeWe Device Device with a positive means to hold an energy isolating device in a safe

) position. Examples, red colored padlocks, red colored tie wraps (see Appendtx G).

l Multiole Tanaine - Placement of one work group's red safety tag over a tag placed by the group with operational control.

Not Used - Issued and placed tag which employees determme is not required to perform the work or the work is not to be done.

! Occurrence Having a red safety or white equipment protection tagsmg problem which does not affect i personnel safety (i.e. lost, contaminated, illegible, mutilated tag or stub).

Ooerational Control Groue Group responsible for positioning and taggmg the equrpment to be tagged,

as defmed by a list or database. Operational Control Group is synonymous with ' Group with
Operational Control."

Ownershin Clearly defmed area of responsibility.

Placement Doing the following:

. Initiating the tag and tagout log entries.

  • Determmmg the isolation sequence.
  • Operating the device to the tagged position.

. Attaching the tag to the energy isolating device Recall Doing the following-

. Venfymg that a tag is no longer needed.

  • Receiving the tag's completed stub.

. Authorizing the tag's removal.

Red Safety Tan - Tag used for personnel safety which is attached to any device (e.g., valve, electrical circuit breaker or disconnect) which, if repositioned or operated, could result in personal injury or expose an employee (s) to a hazardous energy source.

Removal Doing the following:

l . Obtaining approval from the operational control group.

l . Determmmg the restoration sequence.

. Removing the tag from the operating device.

. Completing the tag removal and tagout log entries.

Filing the tag, with the stub stapled to it.

  • Retaining the tag in accordance with operational control groups requirements.

I (14 JUN 1995) 500-5 l

l

O O Nuclear Policy Manual Volume 2 NSD 500.7 Block Tagouts

500.7 BLOCK TAGOUTS 500.

7.1 DESCRIPTION

A Block Tagout (BTO) is a systematic tagout of a defined group of energy isolating devices. The scope of a BTO can vary from including only a few energy isolating devices which isolate and de-energize a small l portion of a system, to involving many energy isolating devices which de-energize complete systems or trains of components. The control of the BTO is vested in a single individual called the BTO Admmistrator. When implemented, the BTO allows for multiple work activities to take place under a single tagout. The BTO is used to enhance safety, work plannmg, and work execution activities during outages and periods of major maintenance Multiple tagging (Ref section 500.4.2.4) may be used in j conjunction with BTO taggmg when deemed appropriate by a work group supervisor or designee 500.7.2 SPECIFIC RESPONSIBILITIES The Block Tagout (BTO) AdmmAator:

Is cosmzant of the work within the Block Tagout boundaries

  • Verifies BTO remami in effect until all work is complete.
  • Assist work groups in verifymg safe working conditions.
  • Maintains control of the red safety tag stubs.

The Operational Control Group:

Prepares and initiates BTO.

  • Makes BTO boundary changes The Work Group (Supervisor or Designee):
  • Verifies safe working conditions.

500.7.3 BLOCK TAGOUT REQUIREMENTS 500.7.3.1 Initiation 1

In order to initiate a bicek tagout the operational control group supervisor or designee shall:

  • Develop and maintain accurate flow diagrams and electrical drawings of the BTO which clearly identify BTO boundaries and what equipment is within the BTO. These drawings are usually marked up flow diagrams and electrical one lines.
  • Develop and maintain any required BTO procedures.
  • Follow all applicable procedures (Removal and Restoration, OP's etc.) while implementing the BTO.
  • Issue red safety tags required for the BTO.

. Place BTO energy isolating devices in the required position in accordance with applicable procedures.

  • Place red safety tags on BTO energy isolating devices.

)

+ Relieve or restrain hazardous stored energy within the BTO boundaries (i.e. opens vents and drains). j Provide all red safety tag stubs associated with the BTO to the BTO administrator.

I (14 JUN 1995) 500 31 i

9 9 ,

NSD 500.7 Block Tagoats Nuclear Policy Manual - Volume 2 l

l

  • Notify BTO adnunistrators when two or more BTO's share a common boundary (an energy isolating i l device is part of more than one BTO boundary). His notification shall include identi6 cation of the '

BTO under which the red safety tags are issued and placed.  !

l

  • Receive approval from the BTO ndmmistrator of each affected BTO before recalling or removing a

, red safety tag on a common boundary energy isolating device, j l

' Before work may begin under the protection of the BTO, the BTO admmittrator shall:

  • Ensure that all required lockout / blocking devices are placed (Reference section 500.4.2.8 of this directive).
  • Ensure they have possession of all red safety tags stubs associated with the BTO or that the red tag stubs for BTO common boundary devices are held by another BTO admmistrator.
  • Ensure all work orders requring work to be performed unde the protection of the BTO are listed on the BTO sheet.
  • Ensure that work order task packages for work which is to be performed under the protection of the BTO have "BTO TAGOUT (BTO number hereY written, printed or stamped on them. De BTO number shall be included.

Before begmmng work under the protection of a BTO, the work group supervisor or designee shall:

  • Ensure the BTO Admmistrator is aware that the work is to be performed under the protection of the BTO.
  • Ensure that clearance to begin work and the BTO number are documented on the work order package.
  • Verify safe working conditions.

500.7.3.2 Work Execution When a work group supemsor or designee is to begin work, they shall obtain the work order package from the Work Control Group /WCC.

The work group supemsor or designee shall ensure the proper cle.r.-ce to begin work has been d==-ated on the work prder package and the BTO number is documented.

The work group supervisor or dengnee shall verify safe working conditions.

After the work group supervisor or designee determmes that the work is complete, work orders shall be delivered to the Work Control Group /WCC or BTO Admmistrator/ designee.

500.7.3.0 Block Tagout Boundary Change Reduction of a block tagout boundary may be considered for a system that has been closed up (pressure boundary intact) to allow testing, partial retum to service, etc.

l If a block tagout boundary ch.nge is required, the group with operational control and the BTO l Admmistrator shall agree on the .hange. Any dependent block tagouts or outstanding work must be carefully reviewed.

The group with operational control shall update the BTO diagrams to reDect the BTO revision.

500-32 (14 JUN 1995)

r 1 O O 4

Nuclear Policy Manual Volume 2 NSD 500.7 Block Tagouts 1 l If additional tags are required or tags must be cleared to implement the change, the group with operational control shall implement the tag changes.

l The BTO Administrator / designee shall ensure lockout / blocking devices are placed as required of a i boundary change Prior to a boundary change the BTO Admmistrator/ designee shall review the status of work in progress and contact affected work group (supervisor or designee). These individuals shall agree the change will l allow work to continue safely.

I 500.7.3.4 Temporarily Lifting BTO Tags for Testing "TLFT"(Tags Lifted for Testing)

If a tag or tags associated with a BTO need to be lifted for testing, the work group supervisor or designee .

shall contact the group with operational control and the BTO Admmatrator, l l The group with operational control shall document the tags needed and mason for hitmg the tags on l TLFT Request Form (Appendix F) and provide this to the BTO Admmatrator/ designee i

l l The BTO Admmistrator shall verify that no other work groups safety will be affected when tags are lifted l for testing.

l When ready to lift for testing the BTO Adnumstrator/ designee removes the locking / blocking device (s), as l appropriate and signs approval to Lift for Testing on the red tag stub (s). The stub is delivered to the l Operational Control Group for operation of the component.

l Tags should agt be lifted for extended periods (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) without a reevaluation of the need to rehang or clear the tags.

The group with operational control and the BTO Adnumstrator/ designee shan ensure no work which would be affected by a lifted tag is allowed to besm.

When the work requinns the lified tag is complete, the work group supervisor or designee shall notify se l group with operational control and the BTO Adddidstistor/ designee that the red tag may be rehung or i cleared as appropriate.

l =

l . If the tags are to be' rehung the isolating device shall be placed in the required position indicated on the l red safety tag by the group with operational control I lockout / blocking devices shall be reinstalled as appropriate and reverification of safe working conditions i shall be performed by the BTO Ac'ministrator/ designee.

500.7.3.5 Clearance Prior to clearing the BTO, consideration shall be given to interdependent BTOs and outstanding work, and these items shall be resolved.

When the BTO is ready to be cleared, the group with operational control and the BTO

! Administrator / designee shall agree the BTO is no longer required.

i When all work is documented as complete, the BTO Administrator / designee shall ensure all locks are removed and then sign, date and time all BTO red safety tag stubs. The BTO Administrator / designee shall then return all signed stubs to the group with operational control for BTO red safety tag clearance.

(14 JLN 1995) 500-33

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