IR 05000250/2015301
| ML15083A055 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/20/2015 |
| From: | Gerald Mccoy Division of Reactor Safety II |
| To: | Nazar M Nextera Energy |
| References | |
| 50-250/15-301, 50-251/15-301 50-250/OL-15, 50-251/OL-15 | |
| Download: ML15083A055 (14) | |
Text
UNITED STATES rch 20, 2015
SUBJECT:
TURKEY POINT NUCLEAR PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000250/2015301 AND 05000251/2015301
Dear Mr. Nazar:
During the period January 19 - 22, 2015, the Nuclear Regulatory Commission (NRC)
administered operating tests to employees of your company who had applied for licenses to operate the Turkey Point Nuclear Plant. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating test and written examination submittal with those members of your staff identified in the enclosed report. The written examination was administered by your staff on February 18, 2015.
Three Reactor Operator (RO) and three Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One RO applicant failed the written examination.
There were four post-administration comments concerning the written examination. These comments, and the NRC resolution of them, are summarized in Enclosure 2. A Simulator Fidelity Report is included as Enclosure 3.
The initial RO and SRO written examinations submitted by your staff failed to meet the guidelines for quality contained in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, as described in the enclosed report.
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) 997-4551.
Sincerely,
/RA/
Gerald J. McCoy, 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.: 05000250/2015301, 05000251/2015301 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 - January 19 - 22, 2015 Written Examination - February 18, 2015 Examiners: Mark A. Bates, Chief Examiner, Senior Operations Examiner Michael G. Donithan, Operations Engineer Newton T. Lacy, Operations Engineer Mahdi O. Hayes, Operations Engineer (Region IV Training Observer)
Approved by: Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1
SUMMARY OF FINDINGS
ER 05000250/2015301, 05000251/2015301, 01/19 - 22/2015 & 02/18/2015; Turkey Point
Nuclear Plant; 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 staff developed both the operating test and the written examination. The NRC developed the written examination outlines. The initial written RO and SRO examination submittal did not meet the quality guidelines contained in NUREG-1021.
The NRC administered the operating test during the period of January 19 - 22, 2015. Members of the Turkey Point training staff administered the written examination on February 18, 2015.
Three Reactor Operator (RO) and three Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One RO applicant and three SRO applicants were issued licenses commensurate with the level of examination administered. Two RO applicants passed the operating test, but passed the written examination with an overall score between 80% and 82%. The two RO applicants were 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. One RO applicant passed the operating test, but failed the written examination.
There were four post-examination comments.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
The NRC evaluated the submitted operating test by combining the scenario events and JPMs in order to determine the percentage of submitted test items that required replacement or significant modification. The NRC also evaluated the submitted written examination questions (RO and SRO questions considered separately) in order to determine the percentage of submitted questions that required replacement or significant modification, or that clearly did not conform with the intent of the approved knowledge and ability (K/A) statement. Any question, for which the answer key had to be changed, was also included in the count of unacceptable questions. The percentage of submitted test items that were unacceptable was compared to the acceptance criteria of NUREG-1021, Operator Licensing Standards for Power Reactors.
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.
The NRC administered the operating test during the period of January 19 - 22, 2015.
The NRC examiners evaluated four Reactor Operator (RO) and three Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. Members of the Turkey Point training staff administered the written examination on February 18, 2015. 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 Plant, met the requirements specified in 10 CFR Part 55, Operators Licenses.
The NRC evaluated the performance or fidelity of the simulation facility during the preparation and conduct of the operating test.
b. Findings
No findings were identified.
The NRC developed the written examination sample plan outline. Members of the Turkey Point training 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. 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 determined that the licensees examination submittal was outside the range of acceptable quality specified by NUREG-1021. The initial RO and SRO written examination submittals were outside the range of acceptable quality because more than 20% of questions sampled for review contained unacceptable flaws. For the RO written examination, 29% (22/75) of the questions were determined to contain unacceptable flaws and for the SRO written examination, 56% (14/25) were determined to contain unacceptable flaws. Individual questions were evaluated as unsatisfactory for the following reasons, and some questions were evaluated as unsatisfactory for multiple reasons:
- 3 questions failed to meet the K/A statement contained in the examination outline.
- 26 questions contained two or more implausible distractors.
- 3 questions contained other unacceptable flaws.
Three RO applicants and three SRO applicants passed both the operating test and written examination. One RO applicant passed the operating test but did not pass the written examination. One RO applicant and three SRO applicants were issued licenses.
Two RO applicants passed the operating test, but passed the written examination with overall scores between 80% and 82%. Each of these applicants 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 four 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 15, 2017, in the ADAMS system (ADAMS Accession Numbers ML15068A031 and ML15068A035).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On January 22, 2015, the NRC examination team discussed generic issues associated with the operating test with 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 M. Kiley, Site Vice President C. Cashwell, Training Manager M. Coen, Operations S. Mihalakea, Licensing R. Hess, Training F. Banks, Nuclear Oversight C. Domingos, Engineering M. Glander, Training M. Wilson, Training R. Baird, FPL Corporate Training NRC personnel M. Endress, Resident Inspector
Facility Post-Exam Comments and NRC Resolutions
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 ML15068A037.
RO QUESTION #42:
Comment:
The question solicited required operator actions in response to conditions provided in the stem
of the question. The question statement solicited the answer in accordance with 4-ONOP-
041.1, Reactor Coolant Pump Off-Normal; however, the intended answer was actually
supported by 4-ARP-097.CR.B, Control Room Response - Panel B.
The licensee requests that the question be deleted from the exam because the required
operator actions are supported by the ARP and not the ONOP.
NRC DISCUSSION:
The question statement provides abnormal indications for the reactor coolant pump. The
question clearly asks for required response in accordance with 4-ONOP-041.1. When 4-ONOP-
41.1 is applied with the conditions provided in the stem, it does not direct the operators to trip
the RCP or reduce load; therefore, answer A is the only technically correct answer because it
states that no action is required.
The originally intended correct answer of C contains the correct actions to be performed,
which is a reactor trip without an RCP trip; however, these actions are directed by the ARP, not
the ONOP as solicited by the question.
Because A is the technically correct answer, NRC views this as an alternate correct answer for
this question. Furthermore, because C contains the correct actions based on the condition in
the stem, NRC views this as correct, as it was originally intended.
Deleting the question was not appropriate because there was a correct answer to the question,
although the technically correct answer was different than originally intended.
NRC RESOLUTION:
A and C are both correct answer choices.
Facility Post-Exam Comments and NRC Resolutions
RO QUESTION #53:
Comment:
The licensee argues that the RHR leak location, between the 3B RHR Heat Exchanger and
HCV-3-758 (RHR HX Outlet Flow Control Valve), was not required knowledge absent a
reference. The licensee claims that the applicants needed print 5613-M-3050 Sheet 1 for
determining the RHR leak location.
NRC DISCUSSION:
The NRC believes this information to be required knowledge and that the question remained
valid with no reference, namely print 5613-M-3050 Sheet 1. The knowledge required to answer
this question contained an appropriate level of content, operational, and discrimination validity
as defined by NUREG-1021, Revision 9, Supplement 1.
The NRC held numerous discussions with the licensee to ensure that the examination met the
requirements of NUREG-1021, Revision 9, Supplement 1. At no time during this review process
did members of licensees examination development team, or members of management, state
that this question tested material that was outside the scope of what they require their operators
to know without references provided. It may also be worth noting that this question also
appeared, with minor formatting differences, on the Turkey Point 2010 initial license exam. The
question was administered in 2010 and no post-exam comments were submitted.
On February 12, NRC sent a letter to the licensee Training Manager granting permission for
them to administer the exam. Within this letter the NRC provided instruction for actions to be
taken if the test was determined to be inappropriate for licensing operators at Turkey Point:
This examination has undergone extensive review by my staff and representatives
responsible for operator training at your facility. Based on this review, I have concluded
that the examination meets the guidelines of NUREG-1021 for content, operational, and
discrimination validity. By administering this examination, you also agree that it meets
NUREG-1021 guidelines, and is appropriate for measuring the qualifications of licensed
operators at your facility. If you determine that this examination is not appropriate for
licensing operators at your facility, do not administer the examination and contact me at
(404) 997-4551.
The licensee did not contact the NRC after receiving the letter that contained the above
paragraph, so at that time, it is presumed that the licensee agreed that this question met the
requirements of NUREG-1021. Therefore, based on the question being technically accurate,
and providing the licensee with adequate notice to discuss concerns with the examination
materials, the NRC views this question as an acceptable test item that meets the requirements
of NUREG-1021.
NRC RESOLUTION:
Question and answer key remain unchanged.
Facility Post-Exam Comments and NRC Resolutions
RO QUESTION #66:
Comment:
The question asked for turnover responsibilities for the RCO. The applicant was then required to
choose the answer that contained items that the RCO was required to review prior to assuming
his responsibilities. Among the items in answer choice A was to review the Schedule of Plant
Checks and Surveillances (Red Book). The licensee proposes that the question contained
confusing information because two Red Books existed in the control room.
Due to the confusion, the licensee is proposing that the question be deleted.
NRC DISCUSSION:
Based on the licensees post-exam challenge, it appears that the correct answer remains D.
The licensee did not provide information that would suggest that D is not a correct answer.
Furthermore, the licensee suggests that A is also a correct answer, yet they are suggesting
that the question be deleted. As long as answers are not contradictory in nature, then two
answers can be accepted as correct choices, but that would not necessitate deleting the test
item.
The licensee claims that the existence of two red books in the control room invalidates the test
item. It is noteworthy to mention that the item listed in answer choice A is the Schedule of
Plant Checks and Surveillances. (Red Book) was included in parentheses to add additional
description to the answer choice, but it did not trump the descriptive title which preceded it.
Lastly, the licensee did not provide evidence that reviewing the schedule of plant checks and
surveillances was a required RCO activity in accordance with 0-ADM-202, Shift Relief and
Turnover. In order for A to be correct, RCOs would need to perform this review as required
by 0-ADM-202.
The licensee claimed in their question documentation that reviewing the Schedule of Plant
Checks and Surveillances was not a responsibility of the RCO. Their documentation read as
follows:
A. Incorrect. Plausible to believe that the RCO needs to review Schedule of Plant Checks
and Surveillances (Red Book), however this is the responsibility of the SM/US/WCC
- S.
Therefore, when considering the arguments and documentation supplied by the licensee, it
appears that not enough evidence exists for changing the answer key or deleting the question.
NRC RESOLUTION:
Question and answer key remain unchanged.
SRO QUESTION #76:
Facility Post-Exam Comments and NRC Resolutions
Comment:
The licensee claims that the correct answer is actually C and not D, as stated in the answer
key. The licensee claims that the questions second statement discusses the Containment
Average Air Temperature hours requirement, but does not specify what type of hours. The
licensee contends that LCO 3.6.1.5 employed equivalent hours, but the design of the question
employed actual hours.
The licensee claims that the correct choice is C, which states that the 336 hour0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> per calendar
year time limit for containment average air temperature between 120 oF and 125 oF is NOT
allowed to be extended. The licensee claims that the 336 equivalent hour limit cannot be
extended.
NRC DISCUSSION:
The Technical Specification Basis, as stated by the licensee in their question documentation,
states that if the 336 hour0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> limit is approached, an evaluation may be performed to extend the
limit if some of the hours have been spent at less than 125 oF.
The question draws a distinction between equivalent and actual hours within the context of
the wording, which is similar to that stated in the Technical Specification Bases. The question
asks for whether 336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> can be extended to credit times when containment temperatures
are lower. The purpose for having the equivalent hours designation is that time greater than
336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> can be accumulated if temperatures do not go over a maximum limit and there are
periods of lower temperatures that can be credited.
The question did not ask if the equivalent hours could be extended. The question asked if the
336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> could be extended IF credit was taken for time at lower temperatures. Due to the
clarity provided by the context of the question and the information provided in the Technical
Specification Bases, a change to the answer does not appear to be warranted.
NRC RESOLUTION:
Question and answer key remain unchanged.
SIMULATOR FIDELITY REPORT
Facility Licensee: Turkey Point Nuclear Plant
Facility Docket No.: 05000250 and 05000251
Operating Test Administered: January 19-22, 2015
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.
No simulator fidelity or configuration issues were identified.
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