IR 05000255/2014301
| ML14310A470 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/05/2014 |
| From: | Hironori Peterson Operations Branch III |
| To: | Vitale A Entergy Nuclear Operations |
| David Reeser | |
| References | |
| 05000255/2014301 | |
| Download: ML14310A470 (16) | |
Text
November 5, 2014
SUBJECT:
PALISADES NUCLEAR PLANT INITIAL LICENSE EXAMINATION REPORT 05000255/2014301
Dear Mr. Vitale:
On October 14, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Palisades Nuclear Plant. The enclosed report documents the results of those examinations. Preliminary observations noted during the examination process were discussed on September 12, 2014, with Mr. A. Williams, General Manager Plant Operations and other members of your staff. An exit meeting was conducted by telephone on October 17, 2014, between Mr. R. White, Operations Training Superintendent - Palisades Nuclear Plant, and Mr. D. Reeser, Chief Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation NRC resolutions of the stations post examination comments, initially received by the NRC on September 24, 2014, and as amended on October 14, 2014, were discussed.
The NRC examiners administered an initial license examination operating test during the week of September 8, 2014. The written examination was administered by Palisades Nuclear Plant training department personnel on September 15, 2014. Four Senior Reactor Operator (SRO)
and five Reactor Operator (RO) applicants were administered license examinations. The results of the examinations were finalized on October 21, 2014. One applicant failed one or more sections of the administered examination and was issued proposed license denial letter. Eight applicants passed all sections of their respective examinations, two were issued senior operator licenses, and four were issued operator licenses. The license for one RO applicant is being withheld pending completion of a medical review to determine whether the applicants medical condition and general health are satisfactory for licensing. In accordance with NRC policy, the license for the remaining SRO applicant is being withheld pending the outcome of any written examination appeal that may be initiated.
The proposed and final written examinations and answer keys will be withheld from public disclosure for 24 months per your request. However, if an applicant received a proposed license denial letter because of a written examination grade that is less than 80.0 percent, the applicant will be provided a copy of the written examination. For examination security purposes, your staff should consider that written examination uncontrolled and exposed to the public. In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRC's
"Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by B. Palagi Acting For/
Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20
Enclosure:
Operator Licensing Examination Report 05000255/2014301(DRS)
w/Attachment: Supplemental Information
REGION III==
Docket No:
50-255 License No:
DPR-20 Report No:
05000255/2014301 Licensee:
Entergy Nuclear Operations, Inc.
Facility:
Palisades Nuclear Plant Location:
Covert, Michigan Dates:
September 8 through October 14, 2014 Inspectors:
D. Reeser, Operations Engineer; Chief Examiner
D. McNeil, Senior Operations Engineer
R. M. Morris, Senior Operations Engineer Approved by:
Hironori Peterson, Chief Operations Branch Division of Reactor Safety
SUMMARY
OF RESULTS
ER 05000255/2014301; 09/08/2014 - 10/14/2014, Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Initial License Examination Report.
The announced initial operator licensing examination was conducted by regional Nuclear Regulatory Commission (NRC) examiners in accordance with the guidance of NUREG-1021,
Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1.
Examination Summary:
Eight of nine applicants passed all sections of their respective examinations. Two applicants were issued senior operator licenses and four applicants were issued operator licenses. One applicant failed one or more sections of the administered examination and was issued a proposed license denial. The license for one applicant is being withheld pending completion of a medical review to determine whether the applicants medical condition and general health are satisfactory for licensing. The license for the remaining applicant is being held and may be issued pending the outcome of any written examination appeal. (Section 4OA5.1).
REPORT DETAILS
4OA5 Other
.1 Initial Licensing Examinations
a. Examination Scope
The NRC examiners and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, to develop, validate, administer, and grade the written examination and operating test. Members of the facility licensees staff prepared the outlines and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of August 18, 2014, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited two license applications for accuracy. The NRC examiners, with the assistance of members of the facility licensees staff, administered the operating test, consisting of job performance measures and dynamic simulator scenarios, during the period of September 8 through 12, 2014. The facility licensee administered the written examination on September 15, 2014.
b. Findings
- (1) Written Examination The NRC examiners determined that the written examination, as proposed by the licensee, failed to meet the NRCs expectations for a proposed examination. More than 20 percent of the proposed examination questions were determined to be unsatisfactory (required replacement or significant modification); additional attention in this area is warranted. Changes made to the proposed written examination, were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and documented on Form ES-401-9, Written Examination Review Worksheet, which will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS).
On September 24, 2014, the licensee submitted documentation noting that there were two post-examination comments for consideration by the NRC examiners when grading the written examination. The NRC requested additional information for one of the post-examination comments and an amended submittal was received on October 14, 2014.
The post-examination comments and the NRC resolution for the post-examination comments are attached in the
SUPPLEMENTAL INFORMATION
section of this report.
The proposed (ADAMS Accession No. ML14307B696) and final as-administered
(ADAMS Accession No. ML14307B702) written examinations and answer keys will be
available in 24 months electronically in the NRC Public Document Room or from the
Publicly Available Records component of NRC's ADAMS.
The NRC examiners graded the written examination on October 15, 2014, and
conducted a review of each missed question to determine the accuracy and validity of
the examination questions.
(2) Operating Test
The NRC examiners determined that the operating test, as originally proposed by the
licensee, was within the range of acceptability expected for a proposed operating test.
Changes made to the proposed operating test, were made in accordance with NUREG-
21, "Operator Licensing Examination Standards for Power Reactors, and were
documented in a document containing Operating Test Comments (or similar phrase) in
the title, which will be available electronically in the NRC Public Document Room or from
the Publicly Available Records component of NRC's ADAMS.
The final as administered dynamic simulator scenarios and JPMs, will be available
electronically in the NRC Public Document Room or from the Publicly Available Records
component of NRC's ADAMS.
The NRC examiners completed operating test grading on October 16, 2014.
(3) Examination Results
Four applicants at the Senior Reactor Operator (SRO) level and five applicants at the
Reactor Operator (RO) level were administered written examinations and operating
tests. Six applicants passed all portions of their examinations and were issued their
respective operating licenses on October 23, 2014.
One applicant failed one or more sections of the administered examination and was
issued a proposed license denial. One RO applicant passed all portions of the
examination, but the applicants license is being withheld pending completion of a
medical review to determine whether the applicants medical condition and general
health are satisfactory for licensing. One SRO applicant passed all portions of the
license examination, but received written test grades below 74 percent on the SRO Only
section of the examination and below 82 percent overall. In accordance with NRC
policy, the applicants license will be withheld until any written examination appeal
possibilities by other applicants have been resolved. If the applicants grade is still equal
to or greater than 70 percent on the SRO Only section and still equal to or greater than
percent overall after any appeal resolution, the applicant will be issued an operating
license. If the applicants grade has declined below 70 percent on the SRO Only section
or below 80 percent overall, the applicant will be issued a proposed license denial letter
and offered the opportunity to appeal any questions the applicant feel were graded
incorrectly.
.2
Examination Security
a.
Scope
The NRC examiners reviewed and observed the licensee's implementation of
examination security requirements during the examination validation and administration
to assure compliance with Title10 of the Code of Federal Regulations, Section 55.49,
Integrity of Examinations and Tests. The examiners used the guidelines provided in
NUREG 1021, "Operator Licensing Examination Standards for Power Reactors, to
determine acceptability of the licensees examination security activities.
b.
Findings
None
4OA6 Management Meetings
.1
Exit Meeting Summary
Debrief
The chief examiner presented the examination team's preliminary observations and
findings on September 12, 2014, to Mr.
- A. Williams, General Manager Plant Operations,
and other members of the Palisades Nuclear Plant Operations and Training Department
staff.
.2
Interim Exit Meetings
The chief examiner conducted an exit meeting, by telephone, on October 17, 2014, with
Mr.
- R. White, Operations Training Superintendent. The NRCs final disposition of the
stations post-examination comments were disclosed and discussed during the
telephone discussion. The examiners asked the licensee whether any of the material
used to develop or administer the examination should be considered proprietary. No
proprietary or sensitive information was identified during the examination or debrief/exit
meetings.
ATTACHMENT: SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Corbin, Operations Manager
- W. Nelson, Training Manager
- R. White, Operations Training Superintendent
- S. Botimer, Operations Training Exam Lead
Nuclear Regulatory Commission
- A. Garmoe, Senior Resident Inspector
- A. Scarbeary, Resident Inspector
- D. Reeser, Chief Examiner
- D. McNeil, Examiner
- R. M. Morris, Examiner
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed
None
LIST OF ACRONYMS USED
Agency-Wide Document Access and Management System
CFR
Code of Federal Regulations
Division of Reactor Safety
NRC
U.S. Nuclear Regulatory Commission
Reactor Operator
Significance Determination Process
Senior Reactor Operator
SIMULATION FACILITY REPORT
Facility Licensee:
Palisades Nuclear Plant
Facility Docket No:
50-255
Operating Tests Validated/Administered:
August 18 - 22 and September 8 - 12, 2014
The following documents observations made by the NRC examination team during the initial
operator license examination. These observations do not constitute audit or inspection findings
and are not, without further verification and review, indicative of non-compliance with 10 CFR 55.45(b). These observations do not affect NRC certification or approval of the simulation
facility other than to provide information which may be used in future evaluations. No licensee
action is required in response to these observations.
During the conduct of the onsite validation and simulator portion of the operating tests, the
following items were observed:
ITEM
DESCRIPTION
None
N/A
POST EXAM COMMENTS AND RESOLUTIONS
There were two Candidate comments regarding the 2014 NRC Written Exam. The comments
are for RO Question No. 46 and SRO Question No. 81.
Question No. 46 Comment
Per the exam key, (a) is the correct answer; however, (b) should be the correct answer.
Question:
Given the following conditions:
The Plant is operating at full power
FI-0703 (Steam/Feed Flow Indicator - Main Feed) indicates
o Main Feedwater Flow at 4.0 E6 lbm/hr and lowering
o Main Steam Flow at 5.6 E6 lbm/hr and stable
Based on the above conditions, the immediate actions to be taken by the NCO, using
LIC-0703 (E-50B Level Indicating Controller) should be to (1), and (2).
a. (1)
transfer controller to MANUAL
(2)
lower controller output signal to lower S/G level
b. (1)
transfer controller to MANUAL
(2)
raise controller output signal to raise S/G level
c. (1)
leave controller in AUTO
(2)
lower level setpoint to lower S/G level
d. (1)
leave controller in AUTO
(2)
raise level setpoint to raise S/G level
Per NUREG-1021, Appendix E, Policies and Guidelines for Taking NRC Examination, Section
8.7, "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."
No failures were given in the stem of the question so no failures can be assumed. Also, Steam
Generator levels were not given in the stem of the question, so level/trend assumptions (failure
method) would have to be based on the indications given.
Based on the conditions given, with Feedwater flow less than Steam flow, it can be assumed
that Steam Generator level is lowering.
With Steam Generator level lowering, the NCO is expected to take MANUAL control, and take
actions to RAISE Steam Generator level.
Therefore, answer (b) is the most correct answer.
Facility Position:
The facility agrees that Question No. 46 answer should be changed from distractor (a) to
distractor (b) due to the information given in the question stem, and the Appendix E briefing
given prior to the start of the examination.
NRC Response:
The NRC contacted the facility examination author and the NRC examination reviewer to
discuss the basis for the selection of answer choice (a) as the original answer. Both the
examination author and the NRC reviewer made the unstated assumption that the lowering
Main Feedwater Flow indication was due to the failure of the Main Feedwater Flow instrument
(controller input) and not an actual decrease in flow. Such a failure would have caused the
control circuit to raise Main Feedwater Flow, from the steady state value, resulting in rising
steam generator level, with choice (a) being the appropriate response. However, as pointed out
by the applicant, the stem does not provide any information to indicate, or support the
assumption, that the lowering feed flow indication is due to a flow instrument failure. Based on
the information provided in the stem, the only valid assumption is that Main Feedwater Flow is
actually lowering. If the actual Feedwater flow is less than Steam flow and still lowering, then
Steam Generator level must be lowering due to inability of the control system to automatically
maintain the Steam Generator level; therefore, answer choice (b) is the expected operator
response.
Based on the above assessment, the answer key will be changed to reflect that choice (b) is the
correct answer.
Question No. 81 Comment
Per the exam key, (b) is the correct answer; however, answers (a) and (d) are also correct
answers.
Question:
The Plant has just entered MODE 3 for a forced outage to repair a Main Condenser
Vacuum leak when the following occurs:
A loss of Left Train 125V DC Bus (more specifically ED-10R and ED-10L) occurs
The Control Room Supervisor directs entry into...
a. AOP-18, "Loss of Left Train DC power" only
b. AOP-18, "Loss of Left Train DC Power" and EOP -9.0, "Functional Recovery
Procedure"
c. AOP-18, "Loss of Left Train DC Power," AOP-13, Loss of Preferred AC Bus EY-20,"
and AOP-15, "Loss of Preferred AC Bus EY-40"
d. EOP-9.0, "Functional Recovery Procedure" only
Summary: Based on the initial condition of a deliberate and controlled entry into MODE 3 for
repair of a Condenser Vacuum leak followed by the loss of the Left Train of 125VDC, both the
Abnormal Operating Procedure (AOP-18) and the Functional Recovery Procedure (EOP-9.0)
will provide the same guidance on how to mitigate the effects of this event. The preferred
procedural path is to use the Abnormal Operating Procedure since it was developed specifically
for this event following the actual loss of DC power event at Palisades in September of 2011.
Entry into an Optimal Recovery EOP or the Functional Recovery EOP from a lower mode is
always allowed if the entry conditions for that procedure are met. For the scenario presented in
the stem of this question, AOP-18 would be the preferred procedural guidance used to mitigate
the event while entry into and use of EOP 9.0 in parallel with AOP-18 or by itself would
successfully address the scenario. Use of EOP 9.0 with or without AOP-18 is completely
discretionary. The basis for the decision is explained below.
AOP-18 does not require EOP-9.0 entry
AOP-18, Section 6.0, Operator Actions, Step 2 states, "Refer to EOP-9.0 'Functional Recovery
Procedure' for lower mode entry. The scenario provided by this question is specifically
addressed in the AOP-18 Basis document as follows (emphasis added)
This is a branching step to EOP-9.0. Transition to EOP-9.0 is required following a
reactor trip and event diagnosis in EOP-1.0. EOP-9.0 entry for all other plant conditions
is discretionary. In most cases, unless Shutdown Cooling is in service, EOP-9.0 entry is
highly recommended.
AOP-18 intentionally uses the language of "REFER TO" rather than "ENTER" to allow the CRS
discretion, based on plant conditions, the use of EOP-9.0 to combat the event. Further
clarification from Operations Senior Leadership Team reinforces the guidance that Referring to
another procedure does not mean the entire procedure must be entered and implemented.
Therefore entry into EOP 9.0 is a discretionary decision to be made by the CRS, based on plant
conditions at the time of event initiation.
EOP-9.0 entry criteria not met
A review of the EOP-9.0 entry criteria reveal entry is not required (emphasis added):
2.0 ENTRY CONDITIONS
1. EOP-1.0, "Standard Post Trip Actions," has been performed.
The event initiated from a lower mode when the Shutdown Cooling System is NOT
initially in service.
[AND]
2. ANY of the following conditions may be present:
a. A Reactor trip with unusual concurrent symptoms and diagnosis of one event
NOT immediately apparent.
b. Any conditions/symptoms which a licensed operator considers serious and for
which other Emergency/Off-Norma/ Procedures can NOT be identified.
c. Actions from an in-use Optimal Recovery EOP do NOT result in acceptance
criteria for in-use Optimal Recovery EOP Safety Function Status Check Sheet
being satisfied.
d. An Optimal Recovery EOP step directs implementation of EOP-9.0, "Functional
Recovery Procedure."
In this scenario, the plant was shutdown to Mode 3 in a deliberate and controlled fashion which
precluded a Reactor Trip. Since there was no reactor trip, EOP 1.0 entry and/or subsequent
EOP entry is not required. Since the event was initiated from a lower mode without shutdown
cooling in service, Step 2.2.b (above) is the only other EOP 9.0 entry condition which could
apply. Since the event is obviously serious the CRS would determine that there is an Abnormal
Operating Procedure that has been identified for this event, therefore none of the Functional
Recovery Procedure entry conditions are met. From the EOP 9.0 basis document, Section 1.0
Introduction (emphasis added):
Entry conditions are chosen to identify those conditions which will necessitate
implementation of the FRP. Following the performance of the SPTAs for events initiated
during Power Operations or Hot Standby with the reactor critical, or from lower modes
for which the FRP entry conditions are met, the operator may not be able to diagnose
one unique event taking place. This could happen if more than one event is taking
place (multiple casualties) or a condition exists for which abnormal or emergency
guidance cannot be identified. During the course of the event, actions taken in an
ORP may not satisfy the Safety Function Status Check acceptance criteria. Also,
actions taken in an AOP (if entering from a lower mode) may not be adequately
responding to mitigate the consequences of the event. Implementation of the safety
function based FRP would then be evaluated.
Safety Function comparison in AOP-18 and EOP 9.0
AOP-18 was written specifically to stabilize the plant following this event. From the AOP-18
basis document:
The need for a procedure dealing with a complete loss of one train of 125V DC became
evident during the automatic reactor trip that occurred on [September 25, 2011].
AOP-18, Section 6.0, Step 24 (and 24.1) addresses restoration of available preferred AC buses
per SOP-30, "Station Power" (see attached).
Following restoration of one preferred AC bus to the bypass regulator performed in Step 24, and
no other events in progress, all applicable Safety Functions will be met. This is further evidence
that entry into EOP 9.0, under these circumstances, is not required and will provide no
additional assistance in addressing this event.
EOP 9.0 implementation is based on the determination of Safety Function status. For this
scenario, the highest priority Safety Function that would be challenged or jeopardized is MVAE-
DC, therefore MVAE-DC-1 would be the entry point for implementing Operator Actions in EOP
9.0. Success path MVAE-DC-1, Step 6.1 addresses restoration of all available preferred AC
buses per the appropriate AOP (see Attached).
Facility Position:
The facility agrees that for Question No. 81, answers (a), (b) and (d) are correct answers based
on the discussion above. Although the preferred path for mitigation of this specific event is to
use Abnormal Operating Procedure AOP-18 (Loss of Left Train DC Power), the CRS could
choose to enter both procedures and implement them in parallel or choose to implement EOP
9.0 by itself. The mitigating strategy to expeditiously repower one of the Preferred AC Busses
from the Bypass Regulator is addressed and directed by both AOP-18 and EOP 9.0, using
steps contained in other procedures (specifically AOP-12, AOP-14, and SOP-30). Completing
actions to restore a preferred AC bus in either AOP-18 or EOP 9.0 will result in satisfying all
safety functions; therefore, entering AOP-18 to mitigate the event is preferred while entering
EOP 9.0 by CRS discretion is acceptable.
NRC Response
The applicant contends, and the facility agrees, that three answer choices, (a), (b) and (d),
should be considered correct answers based on the following:
Both the Abnormal Operating Procedure (AOP-18) and the Functional Recovery
Procedure (EOP-9.0) will provide the same guidance on how to mitigate the effects
of this event;
The preferred procedural path is to use AOP-18; and
Use of EOP 9.0 with or without AOP-18 is completely discretionary.
The NRC staff conducted a detailed review of AOP-18, the applicable portions of EOP-9, and
the associated bases documents. The NRC staff also reviewed the Facilitys Administrative
Procedures: 4.06, Emergency Operating Procedure Development and Implementation, 4.16,
Abnormal Operating Procedure Development and Implementation, and 10.51, Writer's
Guideline for Site Procedures, as well as Entergy Fleet Procedures: EN-HU-106, Procedure
and Work Instruction Use and Adherence and EN-OP-115, Conduct of Operations (including
the Progeny Procedures), for expectations related to integrated use of Abnormal Operating
Procedures and Emergency Operating Procedure, in particular the use of the branching term
REFER TO.
Based upon this review, REFER TO, means to reference information in another location (e.g.,
another section of the in use document or another document) for applicability and possible use.
Referring to another document does not automatically require entry into and implementation of
that document.
After the detailed review of the above information, the NRC agrees that based on the initial
conditions stated in the stem of the question that answer choice (a) is the most correct answer,
but that answer choices (b) and (d) cannot be ruled out as possible answers since the use of
EOP-9 is discretionary and could be used in parallel with, or in lieu of, AOP-18.
Since there are three possible answers for Question 81, the answer key will be amended to
delete the question.
A. Vitale
-2-
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRC's "Rules of
Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records System (PARS) component of
NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from
the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by B. Palagi Acting For/
- H. Peterson, Chief
Operations Branch
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Operator Licensing Examination Report 05000255/2014301(DRS)
w/Attachment: Supplemental Information
cc w/encl:
Distribution via LISTSERV
cc w/encl:
- W. Nelson, Training Manager, Palisades Nuclear Plant