ML23221A329

Post Examination Comments from Applicants and Facility.Pdf

ML23221A329
Person / Time
Site:	Farley
Issue date:	08/09/2023
From:	NRC/RGN-II
To:
References
Download: ML23221A329 (1)

Text

Post Exam Comments (Written Exam)

Comment 1 Comment Source: Applicant Comment Exam Item: SRO Written Exam, Quest ion 89 Question:

89. Given the following:

• A loss of all AC power has occurred on Unit 2.

At 1000:

The 28 DG is started from the EPB and power has been restored to the 2G, 2L, and 2J Susses.

At 1005:

The Shift Supervisor is preparing to exit ECP-0.0, Loss of ALL AC Power, and is at the step to "Evaluate plant conditions".

SCMM is 39°F.

Pressurizer level is 16% and slowly falling.

CTMT pressure is 5.8 psig.

SI equipment did NOT automatically actuate when power was restored. Which one of the following completes t he statements below?

Based on the condit ions at 1000, the 28 DG output breaker _(1}_.

Based on the conditions at 1005, the Shift Supervisor is required to transition to _(2}_.

Nomenclature: ECP-0.1, Loss of All AC Power Recovery Without SI Required.

ECP-0.2, Loss of All AC Power Recovery With SI Required.

A. (1) closed automatically (2) ECP-0.1 B. (1) was manually closed (2) ECP-0.1 C. (1) closed automatically (2) ECP-0.2 D. (1) was manually closed (2) ECP-0.2 Keyed Answer: C. (1) closed automatically (2) ECP-0.2 Page 1 of 3 ML23221A329

Post Exam Comments (Written Exam)

Comment:

Since there was no information given tc; identify the reason for the failure of 2B DG to start and the output breaker close to automatically, an assumption must be made on the failed component to determine whether the breaker would automatically close.

1. Per drawing D207032 (LOGIC DIAGRAM DIESEL 2B AUTO START & LOADING) if UV relays do not sense the undervoltage condition on the 2G Bus, t he 2B DG w ill neither automatically start nor will the output breaker automatically close. Once the DG is started from the EPB, the output breaker would have to be closed manually per ECP-0.0.

2.

Per drawing D207654 (ELEM ENTRY DIAGRAM SEQUENCER B2G LOAD SHEDDING CIRCUIT) and D202778 (ELEMENTARY DIAGRAM - DIESEL GEN 28 START, STOP &SHUTDOWN) if relay 27XG failed, the start signal would not be sent to the 2B DG, but would not affect the manual start from the EP8. Once started from the EPB per ECP-0.0, as shown on D207032, the LOSP sequencer would then close the 28 DG output breaker automatically.

3. Per FNP-2-ECP-0.0 Step 5.12 checks DG08 closed for unit two and if not, you go to the RNO column of the procedure and close the breaker. The procedure is written for situations where the breaker may not automatically close and gives guidance for the operator to manually close the output breaker to restore power to the bus.

References:

D207032 (LOGIC DIAGRAM DIESEL 2B AUTO START & LOADING)

D207654 (ELEM ENTRY DIAGRAM SEQUENCER B2G LOAD SHEDDING CIRCUIT)

D202778 (ELEMENTARY DIAGRAM - DIESEL GEN 2B START, STOP &SHUTDOWN)

FNP-2-ECP-0.0 LOSS OF ALL AC POWER Recommendation: Remove question 89 from the SRO Written Exam.

Page 2 of 3

Post Exam Comments (Written Exam)

Facility Position: FNP agrees with the comment and recommends that this question be removed from the exam based on ES-4.4 C.3.e. The question does not provide the plant conditions necessary to determine the failure mechanism that caused the diesel to not automatically start and re-energize the B train class lE AC bus.

NUREG-1021, ES-4.4, C.3.c, supports a post exam change when a question does not provide all necessary information.

Post exam change in accordance with ES-4.4 is clearly justified given the fact that the stem did not provide the necessary information to determine the failure mode of the diesel generator and associated output breaker.

Page 3 of 3

2023 Farley NRC Written Exam Comment l Comment Source: Applicant Comment Exam Item: SRO Written Exam, Question 91

91. Given the following:

On May 1, at 1000:

Unit 1 was operating at I 00% power FG5, GFFD SYS TRBL, ala1med.

AOP-32, High RCS Activity, is in progress.

Chemistry reported the following:

Dose Equivalent f-1 31 (DEI) is I uCi/gm.

Gross Specific Activity is.55uCi/gm.

E BAR= l75 Chemistry sample has detennined that there is a fuel element leak.

On May 2, at 2200 The plant is in Mode 3 with RCS Tavg at 475F.

Chemistry reports conditions unchanged as follows:

Dose equivalent I-131 (DEi) is 1 uCi/gm.

Gross Specific Activity is.55 uCi/gm.

E BAR= l75 Which one of the following completes the statements below?

On May 2, at 2200, RCS Tavg _ (l)_ meets the requirement of LCO 3.4. 16, RCS Specific Activity, BASES to limit the release of radioactivity in the event of a Steam Generator Tube Rupture(SGTR).

Per NMP-EP-141-001-F0 l, Farley - Hot initiating Condition Matrix, SU3 _ (2)_ applicable.

A.

B.

C.

D.

Keyed Answer:

Reference Provided (l)_

(2)_

Does NOT IS DOES

[S Does NOT is NOT Does is NOT D. (l) Does (2) is NOT

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2023 Farley NRC Written Exam Comment:

The EAL Basis states that SU3 is applicable in Mode 3 which is the mode you are in for the question above per NMP-EP-141-00 I, Farley Emergency Action Level and Basis.

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!. 200 tj 1_Hd,11* 1~19 NA NA NA The dictionary definition of applicable per ("Webster New Collegiate Dictionary Copyright 1977 by G. & C. Merriam Co.") IS "capable of or suitable for being applied". "Capable of or suitable for being applied" also supports the challenge that SU3 is applicable, and Choice B is correct vice Choice D.

2023 Farley NRC Written Exam NMP-EP-141-00 1 Section 4.2 states:

"If an EAL has been met or exceeded, the IC is met and the associated ECL (Emergency Classification level) is declared in accordance with plant procedures."

Farley Emergency Action Levels and Basis (NEI 99-01 Revision 6)

NMP-EP-141-001 SNC I

Version 5.0 Unit s

-I------P-a-Qe_1_5_o_f _12-2-;

Although the EALs have been developed to address a lull spectrum or possible events and conditions that may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 scheme provides the emergency director with the ability to classify events and conditions based upon judgment using EALs consistent with the emergency classification level (ECL) definitions (refer to Category H). The emergency director will determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition. A similar provision is incorporated into the Fission Product Barrier Tables, judgment may be used to determine the status of a fission product barrier.

4.2 Classification Methodology To make an emergency class,hcation, the user will compare an event or condition (1.e.*

the relevant plant indications and reports) to an EAL(s) and determine 1f the EAL has been met or exceeded An EAL(s) evaluation must be consistent with the related operating mode apphcab,lily and notes If an EAL has been met or exceeded. the IC is met and the associated ECL is declared in accordance with plant procedures.

Based on the question asking if SU3 is "applicable" versus asking if you "met or exceeded" the EAL threshold for classification, answer B is the correct answer since it is applicable in Modes 1-4. Answer choice D is not correct since SU3 is applicable in the current mode of operation. If the question was intended to ask if a EAL threshold is met it should have stated:

"Per NMP-EP-141-001-F0I, Farley - Hot Initiating Condition Matrix, SU3 threshold criteria_ (has)(has not)_ been exceeded."

Recommendation: Change the key for the SRO written exam for question 91. The key should be changed to reflect that Bis correct based on the question asking if SU3 is applicable versus asking if you met or exceeded the EAL threshold for classification. If the question was intended to ask if a EAL threshold is met it should have stated:

"Per NMP-EP-141-001-F0 I, Farley - Hot Initiating Condition Matrix, SU3 threshold criteria (has) or (has not) been exceeded."

2023 Farley NRC Written Exam Facility Response:

Based on the question asking "Per NMP-EP-141-00 l-F0l, Farley-Hot Initiating Condition Matrix, SU3 (is) or (is not) applicable", the correct answer should be B. The word applicable as outlined in NMP-EP-141-001 pertains to when a specific EAL applies for a given plant mode. From the stem of the question, on May 2 at 22:00 the plant is in Mode 3 and EAL SU3 is applicable in modes l-4; therefore, the correct answer should be B instead of D.

NUREG-102 1, ES-4.4, C.3.c, supports a post exam change when a question's answer is incorrect based on the stem of the question.

A post exam change in accordance with ES-4.4 is clearly justified given the question asked in the stern whether a specific EAL was applicable instead of whether a specific EAL was met or exceeded. It is clear that based on the stem of the question, answer B is correct.