IR 05000250/2013301
| ML13120A261 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/29/2013 |
| From: | Widmann M Division of Reactor Safety II |
| To: | Nazar M Florida Power & Light Co |
| References | |
| ER-13-301 | |
| Download: ML13120A261 (18) | |
Text
UNITED STATES ril 29, 2013
SUBJECT:
TURKEY POINT NUCLEAR POWER PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000250/2013301 AND 05000251/2013301
Dear Mr. Nazar:
During the period March 4 - 11, 2013, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the Turkey Point Nuclear Power Plant. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating tests and the written examination submittal with those members of your staff identified in the enclosed report. The written examination was administered by your staff on March 15, 2013.
Five Reactor Operator (RO) and four Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One RO applicant failed the written examination.
There were three post-administration comments concerning the written examination. The post examination comments were identified in a letter dated March 22, 2013. These comments, and the NRC resolution of these comments, are summarized in Enclosure 2. A Simulator Fidelity Report is included in this report as Enclosure 3.
The initial examination submittal was within the range of acceptability expected for a proposed examination. All examination changes agreed upon between the NRC and your staff were made according to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm.adams.html (the Public Electronic Reading Room). If you have any questions concerning this letter, please contact me at (404) 997-4550.
Sincerely,
/RA/
Malcolm T. Widmann, Chief Operations Branch 1 Division of Reactor Safety Docket Nos. 50-250 and 50-251 License Nos. DPR-31 and DPR-41
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
REGION II==
Docket No.: 50-250, 50-251 License No.: DPR-31, DPR-41 Report No.: 05000250/2013301, 05000251/2013301 Licensee: Florida Power & Light Company (FP&L)
Facility: Turkey Point Nuclear Plant, Units 3 & 4 Location: 9762 S. W. 344th Street Florida City, FL 33035 Dates: Operating Test - March 4 - 11, 2013 Written Examination - March 15, 2013 Examiners: Gerry Laska, Chief Examiner, Senior Operations Examiner Phil Capehart, Senior Operations Engineer Amanda Toth, Operations Engineer Newton Lacy, Operations Engineer (Training)
Approved by: Malcolm T. Widmann, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1
SUMMARY OF FINDINGS
ER 05000250/2013301, 05000251/2013301, 03/4 - 11/ 2013; Turkey Point Nuclear Station;
Operator License Examinations.
Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 9, Supplement 1, of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." This examination implemented the operator licensing requirements identified in 10 CFR §55.41, §55.43, and §55.45, as applicable.
Members of the Turkey Point Nuclear Plant staff developed both the operating tests and the written examination. The NRC developed the written examination outlines.
The NRC administered the operating tests during the period March 4 - 11, 2013. Members of the Turkey Point Nuclear Station training staff administered the written examination on March 15, 2013. Five Reactor Operator (RO) and four SRO applicants passed both the operating test and written examination. Four RO applicants and four SRO applicants were issued licenses commensurate with the level of examination administered. One RO applicant passed the operating test, but passed the written examination with an overall score between 80% and 82%.
The one RO applicant was issued a letter stating that he passed the examination and issuance of his license has been delayed pending any written examination appeals that may impact the licensing decision for their application. One RO applicant passed the operating test, but failed the written examination.
There were three post-examination comments.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
Members of the Turkey Point staff developed both the operating tests and the written examination. All examination material was developed in accordance with the guidelines contained in Revision 9, Supplement 1, of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." The NRC examination team reviewed the proposed examination. Examination changes agreed upon between the NRC and the licensee were made per NUREG-1021 and incorporated into the final version of the examination materials.
The NRC reviewed the licensees examination security measures while preparing and administering the examinations in order to ensure compliance with 10 CFR §55.49, Integrity of examinations and tests. One security event occurred when a procedure was left out after exam security was taken down. On 02/12/2013, the NRC exam team along with the Turkey Point training staff validated a scenario on the simulator. The next day, 02/13/2013, while validating another (different) scenario, a procedure normally used for boration and/or dilution was found on a shelf in the simulator. This procedure had been used on the previous day and had been marked up and signed. Exam security had been removed on 02/12/2013 to allow just in time (JIT) training for shift operations staff, allowing anyone to view the procedure. Examiners discussed the significance of the particular procedure that was left out. It was determined that this procedure was used in almost every training and exam scenario conducted at Turkey Point. The chief examiner discussed options with the Operation Branch Chief and it was decided that the procedure being left out did not compromise exam security. The licensee wrote AR01847933 to document the occurrence and help prevent reoccurrence.
The NRC examiners evaluated Six Reactor Operator (RO) and four Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. The examiners administered the operating tests during the period March 4 - 11, 2013.
Members of the Turkey Point Nuclear Power Plant training staff administered the written examination on March 15, 2013. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Turkey Point Nuclear Power Plant, met the requirements specified in 10 CFR Part 55, Operators Licenses.
b. Findings
No findings were identified. The NRC determined, using NUREG-1021, that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.
Five RO applicants and four SRO applicants passed both the operating test and written examination. One RO applicant passed the operating test but did not pass the written examination. Four RO applicants and four SRO applicants were issued licenses. One
RO applicant passed the operating test, but passed the written examination with an overall score between 80 percent and 82 percent. The one RO applicant was issued a letter stating that they passed the examination and issuance of their license has been delayed pending any written examination appeals that may impact the licensing decision for their application.
Copies of all individual examination reports were sent to the facility Training Manager for evaluation of weaknesses and determination of appropriate remedial training.
The licensee submitted three post-examination comments concerning the written examination. A copy of the final written examination and answer key, with all changes incorporated, may be accessed not earlier than March 16, 2015, in the ADAMS system (ADAMS Accession Numbers ML13113A151 and ML13113A157).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On March 12, 2013, the NRC examination team discussed generic issues associated with the operating test with Mr. Michael Kiley, Site Vice President, and members of the Turkey Point Staff. The examiners asked the licensee if any of the examination material was proprietary. No proprietary information was identified.
KEY POINTS OF CONTACT Licensee personnel S. Bloom, Senior Reactor Operator P. Czaya, Licensing Engineer R. Hess, Assistant Operations Manager M. Jones, Operations Director M. Kiley, Site Vice President S. Russ, Maintenance Training Supervisor M. Similey, Initial Training Supervisor B. Stamp, Training Manger M. Wilson, Training Instructor NRC personnel M. Barillas, Turkey Point resident inspector
FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the licensee's post examination comments can be found in ADAMS under
Accession Number ML13113A145.
RO QUESTION # 8:
Comment: Question 8: This question requires the operator to determine the most effective
method of reducing RCS pressure in mode 3 with the 3C RCP running. 3-NOP-041.02,
Pressurizer Operation, does not allow the use of Auxiliary Spray with any RCPs running. FPL
recommends accepting distracter B ONLY as the only correct answer.
Question # 8 provides the operator with a scenario with RCP 3C in service, and asks
which set of conditions would be the most effective at lowering PZR pressure.
Distracter A is incorrect, as opening PCV-3-455B, thereby short-cycling spray, thus
making spray flow from PCV-3-455A ineffective.
Distracter B will provide effective spray as PCV-3-455A is open delivering full available
spray flow, without short-cycling spray through PCV-3-455
- B.
Distracter C is incorrect, as the open spray valve is from the secured RCP, there will be
no spray.
Distracter D would provide effective spray, however it is not allowed by plant procedures.
Recommend accept B as the only correct answer.
NRC DISCUSSION:
The initial conditions of the stem do state that RCP 3C is operating, and procedure 3-
NOP-041.02, Pressurizer Operation, step 5.1.2 states: Check NO RCPs Running. With
C RCP running, the auxiliary spray valve cannot be used. In light of this new information,
it appears that answer D is incorrect, and answer B is the only correct answer.
NRC RESOLUTION:
The NRC accepts the licensees comment and question 08 will be graded with only
answer B being correct.
RO QUESTION # 34
Question 34: This question requires the candidate to identify the maximum allowable ICW flow
rate to each CCW HX under normal conditions and to state the reason why. Distracters B and
D properly identify the need to minimize long-term tube side erosion in the CCW HXs. Two
maximum flow rates are specified in 3-NOP-019, Intake Cooling Water System, dependent on
plant configuration, both of which are considered normal alignments. During operations with no
other evolutions in progress for ICW, the maximum allowable flow rate is 10,000 gpm as
specified by distracter B. The maximum allowable flow rate during basket strainer back flush is
2,850 gpm as specified by distracter D. Approved plant documentation identifies both of these
system alignments as normal. Therefore distracter D is also correct as it describes the
maximum allowable flow rate as 12,850 gpm. FPL recommends accepting both answers B and
D as correct.
Question # 34 requires the candidate to identify the maximum allowable ICW flow rate to
each CCW HX under normal conditions and why. Distracters B and D properly identify
the need to minimize long-term tube side erosion. The second determination is the
maximum flow rate.
There are two maximum flow rates, 10,000 gpm and 12,850 gpm.
As both distracters are correct values in accordance with 3-NOP-019, the student must
discern which normal to use.
Either the normal operation within the context of 3-NOP-019 step 2.2.4.2:
-OR-
Normal Operations as defined by the Turkey Point Plant Radiological Emergency Plan:
If a competent operator understands that the plant routinely backwashes basket strainers on a
near-weekly basis, he should identify this as a normal evolution, and that under these
conditions, the plant is allowed to raise ICW flow rate to the maximum flow rate to 12850 gpm.
Recommend accept B and D as correct answers.
NRC DISCUSSION:
The initial conditions of the stem do not state a backwash is in progress.
NUREG 1021 Revision 9, supplement 1, Appendix E, part B (7) states:
If you have any questions concerning the intent or the initial conditions of a question, do
not hesitate to ask them before answering the question. Note that questions asked
during the examination are taken into consideration during the grading process and
when reviewing applicant appeals. Ask questions of the NRC examiner or the
designated facility instructor only. A dictionary is available if you need it.
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. For example, you should not assume that any alarm has
activated unless the question so states or the alarm is expected to activate as a result of
the conditions that are stated in the question. Similarly, you should assume that no
operator actions have been taken, unless the stem of the question or the answer choices
specifically state otherwise. Finally, answer all questions based on actual plant
operation, procedures, and references. If you believe that the answer would be different
based on simulator operation or training references, you should answer the question
based on the actual plant.
If the applicant chose D as an answer, the applicant would have had to make an
assumption that the basket strainer was being backwashed. This is not in accordance
with the NUREG; therefore the comment will not be accepted.
NRC RESOLUTION:
The NRC does not accept the licensees contention and question number 34 will be
graded with B as the only correct answer.
Question 62: This question requires the candidate to verify RIL TS Limits and determine the
required action for boration based on an event causing a Turbine Runback. The question did
not provide distracters for required actions from 3-ONOP-089, Turbine Runback. Since the
ONOP takes precedence over other ARP actions per 0-ADM-211, Emergency and Off-Normal
Operating Procedure Usage, the operator would use the procedural guidance within 3-ONOP-
089 to borate in 50 gallon increments, withdraw control rods, and clear the TS RIL issue. FPL
recommends deleting question 62 from the exam.
Question 62 gives the event of a runback followed by Annunciator B 8/2 in alarm. Bank
D rods past the Rod Insertion Limit would happen as a result of the runback. 3-ONOP-
089, Turbine Runback, has Immediate Operator Actions and would be entered directly.
During the subsequent actions, the RIL condition would be addressed in step 3.3.10.
Per the rules of use specified in 0-ADM-211, the ARP actions would not be used since
the operator is already in the correct procedure to address the RIL condition caused by
the runback.
NRC DISCUSSION:
The initial conditions of the stem do state that a Runback is in progress, and 0-ADM-211
Emergency and Off-Normal Operating Procedure Usage, Section 5.2, Procedure
Hierarchy step 5.2.3 states: Entry into ONOPs (AOPs) takes precedence over action
specified in ARPs unless specifically exempted. With no exemptions listed in the ONOP
or ARP, Therefore the actions of 3-ONOP-089, Turbine Runback, would take
precedence over the actions of the ARP. The NRC agrees with the licensee that there is
not a correct answer to question 62 as written.
NRC RESOLUTION:
The NRC accepts the licensees comment and question 62 will be deleted from the
exam.
SIMULATOR FIDELITY REPORT
Facility Licensee: Turkey Point Nuclear Power Plant
Facility Docket No.: 05000250/2013301 AND 05000251/2013301
Operating Test Administered: March 4 -11, 2013
This form is to be used only to report observations. These observations do not constitute audit
or inspection findings and, without further verification and review in accordance with Inspection
Procedure 71111.11, are not indicative of noncompliance with 10 CFR 55.46. No licensee
action is required in response to these observations.
While conducting the simulator portion of the operating test, examiners observed the following:
Item Description
Simulator RCS During an exam scenario RCS temperature dropped from 570 -
temperature dropped very 547°F very quickly. There was no apparent cause for the
quickly from 570 - 547 °F temperature reduction; it appeared the simulator was
during an exam scenario chronologically uncoupled. AR 01857943 was written to address
this issue.
Simulator did not respond During an exam scenario an unexpected response was received
during the exam as it did when a dilution malfunction was inserted. This response was
during validation. much different than the response received on validation week.
AR 01857943 was written to address this issue.
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