ML20155F473

Forwards Specific Requests on Several of Util Initial Written Exam Questions,For NRC Consideration,Per NUREG-1021 (Interim Rev 8)

ML20155F473
Person / Time
Site:	Pilgrim
Issue date:	10/28/1998
From:	Ted Sullivan BOSTON EDISON CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
RTR-NUREG-1021 BECO-2.98.140, NUDOCS 9811060040
Download: ML20155F473 (12)

Text

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10 CFR 50.55 o

Boetors %

Pilgrim Nuclear Power Station

' i Rocky Hill Road '

Plymouth, Massachusetts 02360-5599 October 28,1998 BECo Ltr. 2.98.140 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Docket No. 50-293 License No. DPR-35 i

Pilarim Station's 1998 NRC initial License Written Examination Comments The written examination administered on October 16,1998, was considered to be an in-depth examination, which fairly tested the four (4) SRO and five (5) RO candidates  ;

knowledge in the appropriate areas.

In accordance with NUREG-1021 (Interim Rev. 8), Section #5 of ES-402, specific requests on several written exam questions are submitted for your consideration in Enclosure 1.  ;

Enclosure 2 contains the reference documentation associated with each of the requests. 1

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i If you have any questions or comments, please contact Mark Santiago at (508)830-7612 or  !

Scott Willoughby at (508) 830-7638.  !

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• i'.,s4 , Yb T. A. Sullivan  !

V" Vice President Nuclear I Station Director I id298140 KRD/deg I

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cc: Mr. Juli:n Willi ms, NRC Chiaf Extmin:r U.S. Nuclair R gulatory Commission U.S. NRC, Region i ATTN: Document Control Desk 475 Allendale Road Washington, D.C. 20555-0001 4

. King of Prussla, PA 19406 King of Prussia, PA 19406 Mr. Alan B. Wang, Project Manager Senior Resident inspector Project Directorate 1-3 Pilgrim Nuclear Power Station l

' Office Of Nuclear Reactor Regulation Mail Stop: OWFN 14B20 1 White Flint North  !

11555 Rockville Pike i Rockville, MD 20852 l h

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ENCLOSURE 1 4

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ENCLOSURE 1

1. Question # 115 {

SRO Exam Question #91 RO Exam Question # N/A A turbine building sump pump has been cleared for routine maintenance. The tagout has been accepted, and a maintenance Red Tag has been hung. No work has been ,

done to the pump. A problem has developed with the other sump pump, making it l necessary to place the cleared pump back in service. The tagout requestor is NOT

. onsite to remove his Red Tag. 1

- Which ONE (1) of the following Individuals is the MINIMUM level of authority required  !

to authorize removal of the Red Tag? l

a. Operations Department Manager (ODM)

. b. Any Maintenance Supervisor

c. The Nuclear Operations Supervisor (NOS) d.' The Nuclear Watch Engineer (NWE) l ANSWER: d.

DISCUSSION: _

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' Not enough information is provided in the stem of the question to allow the candidate to i properly answer the question. The applicable section of the referenced procedure is '

attached. A review of this reference reveals the following: i Answer "d" allows the NWE to " release" the tagout "if an emergency condition exists and the i individual authorizing the work is unable to be contacted." An " emergency" is clarified to '

mean threatening to the plant or personnel safety. The stem describes a condition involving a turbine building sump pump. Without additional supporting information, it is difficult to assume that this is a true emergency condition. Additionally, the stem states that the tagout

requester is not on-site. It does not specify that the requestor cannot be contacted by telecon, as would be the expected action for a non-emergency condition. Additionally, i distractor "b" could be interpreted as correct since a " responsible" supervisor can also l release the tagout after verifying that the tagout can be safely removed.

REQUEST (Question # 115h The question was intended to test the requirements for clearing a tagout during an emergency. Since the question does not present such a situation, we request that this question be deleted from the examination.

REFERENCE J

NOP 1.4.5,"PNPS Tagging Procedure," p. 42 e

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Enclosura 1

2. Que: tion # 124 SRO/RO Exam Question #96

. You are required to enter an area that contains a radiation source. This source is causing dose rates of 1200 mrem / hour at 30 cm from the surface of the source.

Which ONE (1) of the following is REQUIRED?

a. The NWE must authorize entry.

b. Two persons are required for entry: one must be an RPT.

c. RP Personnel must either establish stay times or provide line of site coverage.

d. One person may enter alone, but another person dressed in the required protective clothing must be standing by.

ANSWER: d.

DISCUSSION:

The keyed answer is not correct. There is no requirement in station procedures for this.

The selection of "d" as the correct answer was determined to be a " typo". The proposed correct answer was "c". However, further review reveals that regarding entry to a high RAD area, distractor "b" is also correct (see the explanation below). The applicable section of procedure 6.2-014 is attached and is quoted below.

Per procedure 6.1-014, Section 6.0 (3), p. 8:

"At least two people are required to effect entry into a LHRA or VHRA, one of which must be an RP person." This makes answer "b" correct.

Per procedure 6.1-014, Section 8.2 (5), p.11:

.... stay times....shall be established by RP prior to entries into LHRAs. In lieu of stay times, line of sight RP coverage may be provided." This makes answer "c" correct.

No procedural basis justifying answer "d" could be located.

REQUEST (Question # 124): i i

Answer key should be changed to accept either "b" or "c" as the correct answer.

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REFERENCE:

PNPS Procedure 6.1-014, Rev. 5, p. 8 and 11

Enclosura 1

3. Cuestion # 69 SRO Exam Question #37 -

RO Exam Question #50 The plant is operating at 100% power.

Which ONE (1) of the following conditions would cause automatic closure of the condenser vapor valves and subsequent loss of main condenser vacuum?

a. 70 psig steam pressure to the SJAE inlet.

b. 10 psig downstream of the SJAE Condenser,

c. 6000 lbm/hr steam flow to the jet compressor.

d. 280 degrees F downstream of the SJAE Condenser.

ANSWER: a.

DISCUSSION:

The proposed answer "a" is incorrect. The applicable page of the reference text is attached and an excerpt follows:

Main Condenser and Offgas System reference text, Rev.1, p. 9 of 33 states:

"These vapor valves will auto-close if a hydrogen exploolon condition, (temo. areater than 259* or pressure greater than 35 psig), is sensed in the off-gas system piping downstream of the After-Condenser. Auto-closure of the vapor valves also occurs if either air ejector steam supply pressure decreases to 40 psig, or if A.O.G. jet compressor flow decreased to 2750 lbm/ hour."

. The applicable operating procedure is also attached and an excerpt follows:

" Low main steam pressure to the SJAE inlet regulator of less than 50 psi and the OVERRIDE LOW DRIVE STEAM PRESSURE switch in " PRESS" will close the four vapor

. valves to the SJAE and annunciate the alarm on Panel CP600." This makes answer "a" incorrect, since pressure is greater than the setpoint.

"High temperature upstream of the 30 minute holdup pipe of greater than 250' will close the four vapor valves to the SJAE and annunciate the alarm on Pane CP600." This makes answer "d" correct.

REQUEST (Question # 69):

Change correct answer to "d".

REFERENCE:

Main Condenser Vacuum and Air Removal reference text, p. 9.

Procedure 2.2.93, Rev. 35, p. 9 of 64.

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. ENCLOSURE 2 5

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~ 6.7.2 Normal Tegout Continued) i

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Block 27 (TAGOUT RELEASED A tagout may be released by the BY/DATE/ TIME) individuals / designees signed onto the tagout when any of the following conditions are met:

These conditions shall be verified by the individual releasing the tagout (i.e., if Responsible Supervisor A has performed the work, Responsible Supervisor B may release the work as long as he or she has personally verified one of the following).

(1) All work for which the individual

, accepting the tagout was responsible

for has been completed. 1 (2) All work has not been completed, the MR is to remain outstanding, but the ,

work is completed to the point where i isolation is no longer required. )

1 Tagout release via telecon with the individual performing the physical work is permitted as long as the conversation is held with the NWE or the NOS and witnessed by one other i

Control Room Operations person. Both '

Operations personnel involved with the telecon shall sign the TAGOUT RELEASE portion of the Tagout.

(1) If an emergency condition (threatening to the plant or personnel safety) exists, the NWE may sign off the tagout for an individual not able to be contacted.

[7] When all jobs performed under a tagout are complete, the tagout may be closed out through the completion of the TAGOUT REMOVAL section of the Tagout Sheet.

[8] Tagout Removal - Section 5 (a) Block 28 (ALL JOBS This question is a reminder to verify all RELEASED) applicable work packages / Procedures and ,

tagouts (if this was a Master) hsve been l released from this tagout.

1 (b) Block 29 (EQUIPMENT VENT The NOS shall determine whether the closeout IAW PNPS 2.1.11.1) of the tagout will require a system fill and vent. Instructions for determining the need to I fill and vent systems are contained in PNPS 2.1.11.1.

Procedure 1.4.5 Rev. 45 Page 42 of 79 Enclosure 2 Question #115 Reference

5.0 SPECIAL TOOLS AND EQUIPMENT

[1] Appropriate keys and key lockers

[2] Appropriate locking systems which function to the standards listed in Attachment 4

[3] Radiation survey instruments and alarming dosimeters as required by applicable  !

Radiation Work Permits

.[4] Flashing lights, when applicable 6.0 PRECAUTIONS AND LIMITATIONS

[1] Each LHRA and VHRA shall be locked or guarded at all times.

[2] - Only Radiation Protection (RP) personnel may admit a person to an LHRA or VHRA.

[3] At least two people are required to effect entry to an LHRA or VHRA, one of which must be an RP person.

[4] Equipment and material, (e.g., hoses, cords, etc.) will not be positioned between the door and frame of an LHRA or VHRA unless approved by Radiation Protection.

[5] Two persons, one of whom is a Radiation Protection Technician (RPT) or Radiological ,

Operations Supervisor (ROS), shall check doors used to access or exit an LHRA or  ;

VHRA upon leaving the area and verify them locked.

[6] An RPT shall check all accessible doors to an LHRA or VHRA upon leaving the area and verify them locked. [NRC LER 89-005-00]

[7] When exiting an' area secured by an earess restricting device (e.g., chain and lock),

verify that all personnel have left the area prior to locking the door. Control of Locked High Radiation Areas (LHRAs) shall be maintained such that no individual is prevented i from leaving the area.

[8] An RPT or an ROS who has been issued a VHRA key shall not give the key to anyone except the RPDM/ designee.

[9] An RPT or an ROS who has been issued an LHRA or VHRA key shall return the key to i the Radiological Operations office or the RPDM/ designee, as appropriate, and ensure that it is signed in before he or she leaves site.

Procedure 6.1-014 Rev. 6 Page 8 of 29 Enclosure 2 Question 124 Reference

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8.2 LOCKED HIGH RADIATION AREA (LHRA) ACCESS / EGRESS

[1] in, addition to the access requirements for HRAs, areas classified as LHRAs shall be

. locked or guarded.

[2] Prior to entering an LHRA, the RP person who has been issued the "R" key shall perform the following:

(a) Obtain an LHRANHRA Verification Record (Attachment 5) which lists all accessible entrances for the area to be entered. Those areas not entered shall be marked "N/A" on Attachment 5.

.(b) Carry this LHRANHRA Verification Record to the area.

NOTE LHRAs under constant visual observation and control of Radiation Protection personnel are exempt from the requirements of Attachment 6.

[3] A door guard (normally supplied by the work group) is required for all entries into LHRAs. The door guard shall be briefed and shall perform his/her duties in accordance with Attachment 6.

[4] Only RP personnel may allow entry into an LHRA.

[5] The RWP shall specify the maximum stay time for each LHRA. In addition, stay times l based on individual's available exposure or the RWP ADA shall be established by RP prior to entries into LHRAs. In lieu of stay times, line of sight RP coverage may be provided. Remote continuous coverage (TV camera) with continuous communication (head sets) should be used when practical.

[6] The work crew shall exit the LHRA via the same door they used to enter unless otherwise directed by RP.

[7] The doors to the LHRA shall be verificd to be closed and locked in accordance with Section 8.7 after exit. [NRC LER 89-00640)

[8] For individual High Raaiation Areas with radiation levels of ;t 1000 mrem /hr accessible to personnel that are located within large areas such as Reactor containment, where no enclosure exists for purposes of locking or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning device unless otherwise authorized by the RPM.

Procedure 6.1-014 Rev.6 Page 11 of 29 Enclosure 2 Question 124 Reference

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- 4,I SYSIEM AUTOMATIC RESPONSE (1) oow noin steam pressure to the SJAE inlet regulator of less than 60 us1 anc tne OVERRIDE LOW ORIVE STEAM PRESSURE switch in ' PRESS" will close I/ie four vacor valves to the SJAE and annurciate the alarm on Perel CD600.

[2] H1Qn te00erature upstream of the 30 minute holcup pipe of greater uien 250*F will c'ese the four vapor volves to the SJAE and annuncidte the alarn on Panel CP000.

(3) liigh pressure upstream of the 30 minute nolaup pipe of gredt.er than 35 psi Will close the four vapor valves to the 5.1AE and arnancidle :Fe alarm en Panel C2000.

[4] Low stesm flow to Offges Jet Compressors and the CFF GAS LOW F10W AYPAS$

sMtch in 'NORPAL Will close the four vapor valves to the S,1AF ond annunciate the alarm on A0G Centrol Panel CP500.

(5) If the rechanical vacuum puno is in service and an isclal.lon signal ts received from the main steam lire radiation monitors. Ltp mechanical vacuum pump will trip and its discharge valve 8-AO-3712 will close.

(6) ine mechanical vacuum pumo will trip on low seal water fitw of 15 GPM.

[7] On decreasina vacuum in the condenser, less thar 25" Hg causes low vacuum alarm ,

valves, less than 22' Hg causes turbine trip. and less than 7" cduses cypass trip, i

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[8] If the radiation monitors upstrean of the chorcedl beds (RM 1705 3A/38) a*e selected and BOTH these monitors receive o high radiation signal, 98 If the radiation monitors dcwnstream of the charcoal beds (RM 17C5-5A/53) are selected and QQld these monitors receive d high radiation sigral, THEN l

(a) Offges stack isolation valve B A0-3751 closes after 15 minute t1 mar has I timed out.

(b) Offgas 30 minde loop seal holdup 'ine caain valve 6 A0 3750 c1cses.

[9] The offges holdup line loop sedl drain valve 8 AO 3750 will close or low level in tne 1000 sen1 drain ret anc alarm en pane' CP600.

[10: The SJAE after concenser 'oup seal drain valve 8-AO 9071 will c'ese en low level in tne ' cop seal drain pet and #11 alarm on Panel C5500.

rll) If of the air ejectnr vnpor velves are rot fur y cpen, annanciater

'V VALVE NOT FULL OPEN' (CF600:. A1) will alarm.

Procedure 2.7.93 Rev. 35 Page 8 of 54 Enclosure 2 Question d69 Reference l

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r O'. CO'MbNENT DESCRIPTION

1. Main Condenser Vapor Valves (Figure 2)

The air removal system draws from condensers "A" and "B". Each condenser has two suction lines with 12 inch butterfly type air operated isolation valves. AO-3703 and AO-3710 i for condenser "A"; and AO-3704 and AO-3711 for condenser "B". The vapor valves are l controlled from panel C 10 by control switches CS-SV-3703,10,04 and 11, using control power from Y 1, (valves fait closed upon loss of control power). These vapor valves will auto-close if a hydrogen explosion condition, (temp. greater than 2500, or pressure greater than 35 psig), is sensed in the off-gas system piping downstream of the After-Condenser.

Auto closure of the vapor valves also occurs if either air ejector steam supply pressure decreases to 40 psig, or if A.O.G. jet compressor flow decreases to 4500 lbm/ hour.

l During a plant startup, it is necessary to bypass both the low S.J.A.E. steam supply pressure auto-closure feature, and the low A.O.G. jet compressor flow auto-closure feature, l to open the vapor valves and provide a suction path for our mechanical vacuum pump to be

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used to draw the initial condenser vacuum. Consequently, both a "AOG Stm Dilution Low l Flow Bypass Switch" and a " Ejector Low Press Override Switch" are provided on Panel C-l

10. These switches also enable or disable associated control room alarms. The two condenser suction lines join to form one line for each condenser.

A vacuum breaker line is connected to main condenser "A" just upstream of AO 3710.

This line has two isolation valves (AO-3707 and AO 3708) between the condenser and room air. The air to open and air-to close valves are in series, and are controlled with pushbuttons on panel C 2. The valves are opened when it is desired to rapidly decrease vacuum (ie., to stop the turbine quickly as on a turbine vibration problem, or to prevent damage to turbine seals when no steam is being supplied).

i MAIN CONDENSER VACUUM AND AIR REMOVAL Page 9 Enclosure 2 Question #69 Reference

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