IR 05000269/2014302
| ML15041A533 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/09/2015 |
| From: | Gerald Mccoy Division of Reactor Safety II |
| To: | Batson S Duke Energy Corp |
| References | |
| 50-269/14-302, 50-270/14-302, 50-287/14-302 50-269/14-302, 50-270/14-302, 50-287/14-302 | |
| Download: ML15041A533 (11) | |
Text
UNITED STATES ary 9, 2015
SUBJECT:
OCONEE NUCLEAR STATION - NRC OPERATOR LICENSE EXAMINATION REPORT 05000269/2014302, 05000270/2014302, AND 05000287/2014302
Dear Mr. Batson:
During the period December 8 - 11, 2014, the Nuclear Regulatory Commission (NRC)
administered operating tests to employees of your company who had applied for licenses to operate the Oconee Nuclear Station. 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 December 17, 2014.
All applicants passed both the operating test and written examination. There were two post-administration comments concerning the written examination. 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) 997-4551.
Sincerely,
/RA/
Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Docket Nos: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55 Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
__ML15041A533_____________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRS RII:DRS SIGNATURE MKM3 * GJM1 DVB2 VIA EMAIL * AXT6 VIA EMAIL *
NAME MEEKS McCOY BACON TOTH DATE 2/5/2015 2/ 9 /2015 2/5/2015 2/5/2015 2/ 2/ /2015 2/ /2015 E-MAIL COPY? YES NO YES NO YES NO YES NO /2015 YES YES NO YES NO
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-269, 50-270, 50-287 License No.: DPR-38, DPR-47, DPR-55 Report No.: 05000269/2014302, 05000270/2014302, 05000287/2014302 Licensee: Duke Energy Carolinas LLC Facility: Oconee Nuclear Station, Units 1, 2, and 3 Location: Seneca, SC Dates: Operating Test - December 8-11, 2014 Written Examination - December 17, 2014 Examiners: M. Meeks, Chief Examiner, Senior Operations Engineer D. Bacon, Senior Operations Engineer A. Toth, Operations Engineer Approved by: Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1
SUMMARY
ER 05000269/2014302, 05000270/2014302, and 05000287/2014302; December 8-11, 2014 &
December 17, 2014; Oconee Nuclear Station, Units 1, 2, and 3; 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 Oconee Nuclear Station staff developed both the operating tests and the written examination. The NRC developed the written examination outlines. The initial operating test, written Reactor Operator (RO) examination, and written Senior Reactor Operator (SRO)examination submittals met the quality guidelines contained in NUREG-1021.
The NRC administered the operating tests during the period December 8-11, 2014, to 3 RO applicants and 5 SRO applicants. Members of the Oconee training staff administered the written examination on December 17, 2014. All RO and SRO applicants passed both the operating test and written examination. All applicants were issued licenses commensurate with the level of examination administered.
There were two post-examination comments submitted on the written examination.
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 (Reactor Operator (RO) and Senior Reactor Operator (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 questions that were deleted during the grading process, or for which the answer key had to be changed, were 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 tests during the period December 8-11, 2014. The NRC examiners evaluated three RO and five SRO applicants using the guidelines contained in NUREG-1021. Members of the Oconee Nuclear Station training staff administered the written examination on December 17, 2014. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Oconee Nuclear Station, 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 tests.
b. Findings
No findings were identified.
The NRC developed the written examination sample plan outline. Members of the Oconee Nuclear Station 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, using NUREG-1021, that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.
All applicants passed both the operating test and written examination and were issued licenses.
Copies of all individual examination reports were sent to the facility Training Manager for evaluation of weaknesses and determination of appropriate remedial training.
The facility licensee submitted two post-examination comments concerning the written examination. A copy of the final written examinations and answer keys, with all changes incorporated, may be accessed not earlier than January 10, 2017, in the ADAMS system (ADAMS Accession Numbers ML15009A337 and ML15009A338). A copy of the post-examination comments may also be accessed in the ADAMS system (ADAMS Accession Number ML15009A342).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On December 11, 2014, the NRC examination team discussed generic issues associated with the operating test with Mr. S. Batson, Site Vice President, and members of the Oconee Nuclear Station 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. Batson, Site Vice President T. Doss, Initial Licensed Training Supervisor P. Fisk, Operations Manager T. Grant, Assistant Operations Manager S. Lark, Senior Operations Specialist T. Lawson, Exam Development Supervisor L. Nowell, Exam Development Supervisor T. Patterson, Organizational Effectiveness Director T. Ray, Plant Manager C. Rop, Operations Training Manager J. Smith, Regulatory Affairs Specialist J. Steely, Nuclear Training Manager C. Wasik, Regulatory Affairs Manager C. Witherspoon, Senior Operations Specialist NRC personnel None
FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the licensees post-examination comments can be found in ADAMS under
Accession Number ML15009A342.
Item
Question 78, K/A 038EA2.17
Comment
The facility licensee recommends that the question be deleted from the examination based on
insufficient information being provided to determine the correct answer.
The licensee asserts that in the second part of question 78, the applicants were required to
make assumptions about plant conditions in order to proceed through Emergency Operating
Procedure (EOP) Enclosure 5.6 (RCP Restart) and reach the diagnostic step to determine
minimum pressurizer (PZR) level requirements needed to restart a RC
- P. Specifically, step 6 of
5.6 states, Ensure all SCMs are >0 °
- F. However, the current condition of SCM is
not provided to the applicant for the second part question, and the first part question (timed 30
minutes earlier) provides the condition of core SCM = 0 °F and stable.
NRC Resolution
The licensees recommendation was partially accepted.
The first part of the question statement provides the information that at the time of 1200, the
Steam Generator Tube Rupture (SGTR) tab of the EOPs was in progress and that a natural
circulation cooldown had been approved by management and was in progress. Therefore,
based on the conditions at time 1200, operators had to be (i) at step 103, or (ii) beyond step
103 of the SGTR tab, which states: WHEN natural circ cooldown is approved by Station
Management, THEN commence cooldown to cooldown plateau at <25 °F/ 1/2 hr.
Consider case (i). If the operators were just beginning to perform step 103, the last specified
minimum PZR level would still apply. In this case, the minimum PZR level would have been set
at step 46 of the SGTR tab, which states in part Maximize cooldown rate limited only by the
ability to maintain Pzr level > 100 [180 acc]. Therefore, if case (i) applied, then the minimum
required PZR level was specified as >100 by the applicable procedure. Consider case (ii). As
the operators began to perform the natural circulation cooldown and continued in the procedure,
they would perform step 124, which directs the operators to Maintain Pzr level 100 - 300.
Therefore, if case (ii) applied, the minimum required PZR level would be 100 as required by the
applicable procedure.
The second part question statement reads: If EOP Enclosure 5.6 is being used at 1230 but
does not specify which step of Enclosure 5.6 is applicable. In the most limiting case, if the
applicant believed that Enclosure 5.6 had just been entered, then they would proceed to step 5
of Enclosure 5.6, which states Verify all of the following: - Boiler condenser cooling has NOT
occurred [and] -Nat Circ cooling exists in at least one RCS loop. Step 5 is preceded by a
NOTE that states Engineering should be consulted to help determine if boiler condenser
cooling has occurred. However, the applicants are not given any information in the question
stem to determine whether or not boiler condenser cooling has occurred. If boiler
condenser cooling had not occurred, the applicant could continue in Enclosure 5.6 and
determine the minimum PZR level for RCP restart was >200 based upon the information given
in the question stem. This was the initial answer as specified in the exam answer key.
However, if boiler condenser cooling had occurred and the TSC did not concur with RCP restart
(another condition that was not given in the stem), then Enclosure 5.6 directs the operators to
EXIT this enclosure. In this case (operators exiting Enclosure 5.6), then, as previously
discussed, the minimum PZR level of >100 would still apply.
Therefore, it is technically correct that the minimum PZR level requirement could either be
>100 or >200 based upon plant conditions that were not clearly stated in the question stem.
Both of these technically correct answers were provided as answer choices. In accordance with
NUREG 1021 ES-403 D.1.b, it appears that this was a question with an unclear stem that
did not provide all the necessary information. Furthermore, the two answers do not contain
conflicting information.
Therefore, in accordance with ES-403 D.1.c, the NRC will accept both answers B and D as
correct answers for Question 78.
Item
Question 99, K/A G 2.4.35
Comment
The licensee recommends that the correct answer for this question be changed from C to D.
The licensee asserts that the second part of question 99 asks that applicant if Rule 2 (Loss of
[Subcooling Margin] SCM) is, or is not, required to be performed in parallel with the Blackout tab
of the EOPs during a Station Blackout condition (i.e., before restoration of electrical power).
The facility believes that there is a difference between performing actions in the procedure, vice
initiating a procedure where no operator actions are required.
NRC Resolution
The licensees recommendation was rejected.
The facility licensee concurs that it is a requirement to initiate Rule 2 if loss of SCM conditions
occur during a Station Blackout. When Rule 2 is entered with no electrical power available,
operators are required to perform steps 1-4 of the Rule. At step 4 of Rule 2 (Verify Blackout
exists.), operators are expected to suspend performance of Rule 2 until power is restored.
Step 5 of Rule 2 directs the operator that: WHEN power has been restored, THEN continue. It
is therefore self-evident from the language of steps 4 and 5 of Rule 2 that the EOPs envisioned
performance of Rule 2 in parallel with the Blackout tab. More specifically, during performance of
Rule 2 steps 1-3, (1) operators are required to verify plant conditions and compare those
conditions to what is stated in the Rule, (2) operators may be required to operate RCP switches
or electrical breaker switches, and (3) operators are required to notify the control room Senior
Reactor Operator (SRO) of RCP status.
The NRC agrees with the facility licensee that it is possibledepending on the circumstances
and plant conditions in effectfor an operator to perform Rule 2 during a blackout and not
perform any verifiable operator action (i.e., switch manipulation). However, this particular
circumstance would be contingent upon the plant conditions and the timing of the operators
actions, and is not assured. In any case, the verification of plant conditions and notification to
other operators does constitute performance of the procedure.
Based on the above discussion, the one technically correct answer for Question 99 remains D,
which is in accordance with the previously agreed-upon answer key.
SIMULATOR FIDELITY REPORT
Facility Licensee: Oconee Nuclear Station
Facility Docket No.: 50-269, 50-270, 50-287
Operating Test Administered: December 8-11, 2014
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 B PCB-20 During performance of a Job Performance Measure (JPM) in
Synchronizing Switch Simulator B, NRC inspectors identified that the PCB-20
Synchronizing Switch (P2204) was intermittently binding such that
it was not correctly operating when applicants attempted to turn
the switch to the one oclock position. This condition was
reported to the facility licensee, and simulator Deficiency Report
No. 2530 (dated 12/10/2014) was generated to troubleshoot and
correct the issue.
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