IR 05000302/1998301
| ML20237B024 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/31/1998 |
| From: | Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20237B020 | List: |
| References | |
| 50-302-98-301, NUDOCS 9808170312 | |
| Download: ML20237B024 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.:
501302
License Nos.:
DPR-72 Report Nos..
50-302/98-301 Licensee:
Florida Power Corporation Far.ility:
Crystal River Unit 3 Location:
Crystal River. FL Dates:
June 26 - July 2. 1998
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Examiners:
P.
Steiner.
Chief License Examiner J.
Bartley Resident Inspector Farley 7//y Approved by:
T. Peet$les. Chief. Operator Licensing Uat'e and Human Performance Branch Division of Reactor Safety l
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EXECUTIVE SUMMARY Crystal River Unit 3 NRC Examinatio1 Report No. 50-302/98-301 During the period June 26 - July 2,1998. NRC examiners conducted an announced operator licensing initial examination in accordance with the Examiner Standards. NUREG-1021. Interim Revision 8.
This examination implemented the operator licensing requirements of 10 CFR S55.41, 555.43, and S55.45.
Doerations Four Senior Reactor Operator Instant (SRO-I) applicants received written e
examinations and operating tests.
The examinations were developed by the facility training staff and the operating tests were administered by NRC operator licensing examiners.
The operating tests were administered June 29 - July 1,1998.
The written examination was administered by the facility licensee on June 26. 1998.
All four applicants passed the examination.
Two of the four candidates demonstrated performance weaknesses during the examination.
e ecolicant Pass / Fail SRO R0 Total Percent Pass
0
100%
Fail
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0%
The examiners identified a training weakness in the area of Siggy-back e
operations during a Small Break Loss of Coolant Accident (SB_0CA)
(Section 05.1).
e The examiners identified several technical inaccuracies in the administered operating examinations (Section 05.2).
The examiners identified several procedure deficiencies during e
validation and administration of the operating examinations (Section 05.3).
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Reoort Details I
Summary of Plant Status l
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During the period of the examinations. Unit 3 was at 100 percent power.
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I. Ocerations
Operator Training and Qualifications (
l 05.1 Initial Doerator Licensino Examinations a.
Examination Scoog
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NRC examiners conducted regular. announced, operator iicensing, initial i
examinations during the Jeriod June 26 - July 2.1998.
The facility i
licensee developed and NRC examiners administered examinations in
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accordance with the Operator Licensing Examiner Standards, NUREG-1021.
j Interim Revision 8.
This examination implemented the operator licensing
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requirements of 10 CFR S55.41. S55.43, and S55.45.
Four SRO-1
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applicants received written examinations and operating tests.
b.
Observations and Findinas
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Rtilten Examination The written examination was administered by the facility licensee on June 26. 1998.
All applicants passed the written examination, with one j
applicant demonstrating a performance weakness with a score of 81.0. The I
facility licensee submitted two post-examination comments. After review I
of the post-examination comments. the NRC char"d the correct answer on
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both questions.
This change resulted in an ap,iicant with a failing grade of 79.0 being regraded to a passing score of 81.0.
l The licensee's post-examination review of the written examination identified 5 generic knowledge weaknesses. A generic weakness is any question where less than 50% of the applicants passed.
It should be noted, that due to the small class size this method may not be effective at identifying generic weaknesses.
A review of lesson plans and training notes should be conducted to identify any weaknesses in
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these topic areas.
Doeratina Iest J
l The operating examination was administered during the period of l
June 29 - July 1, 1998.
All applicants passed the operating examination i
l with one applicant demonstrating performance weaknesses on both the l
l walkthrougi, and scenario portions of the operating examination.
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The examiner's post-examination review of the operating tests identified l
the following generic knowledge weaknesses.
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1)
Picav-back_00erations Durina SBLOCA l
The examiners identified a training weakness during conduct of the I
walkthrough portion of the caerating examinations. All candidates demonstrated performance wea(nesses while performing E0P~14 Enclosure 19. ~ECCS Suction Transfer ~. during a SBLOCA.
Step 19.3 requires the operator to:
Adjust Low Pressure Injection (LPI) flowrate for RB sump operation.
The procedure details state:
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" Throttle and maintain each LPI train to achieve a i
maximum flowrate without exceeding 2200 gpm/ train j
using the following:
DHV-5 I
DHV-6" Because of the SBLOCA. Reactor Coolant System (RCS) pressure was l
at - 220 psig.
This was above the shutoff head of the LPI aumps.
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resulting in 0 gpm LPI flow.
DHV-5 & -6 were full OPEN.
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required action, given the SBLOCA conditions, was to go on to the q
next step.
The applicants attempted either to shut DHV-5 & -6 or to reduce RCS pressure in order to achieve LPI flow.
Reducing RCS pressure results in a loss of subcocling margin.
The applicants did not demonstrate the ability to complete the procedure step or to understand its basis.
Follow-up questioning of the applicants revealed that they had only faced this step during a large break LOCA when there was a high volume of LPI flow. this condition required DHV-5 & -6 to be throttled closed.
2)
ftservation of Precautions and Limitations J
b The examiners identified an applicant performance weakness during a walkthrough examination Job Performance Measure (JPM). This JPM j
required the applicant to perform procedure SP-356 section 4.1.
ES "A" RBIC. Refueling Manual Actuation Test.
Four com)onents failed to respond as required by the test procedure, macing this
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an alternate path JPM.
Step 4.1.3.5 required the operator to
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confirm proper system response by verifying the indicating lights were not lit.
Four lights remained on.
Limits and Precautions 3.5-.1 stated. "Do not proceed past a step if any of the status (Normal. Bypass or Test) indicating lights at the Test light panel fail to operate as specified by the applicable test step. To back out of the procedure, see Enclosure 2.~
Enclosure 2. of section 4.1. directed the applicant to:
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" Reset manual actuation by momentarily depressing the ES
~A" RB ISO MAN TEST RESET ~ push button.
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e Perform Section 4.1.5 l
Perform Section 5.0 as applicable."
e The applicants correctly identified the four components that did i
not properly respond: however, they failed to implement Enclosure l
2 as required.
The applicants incorrectly performed the next
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sequential ste). 4.1.3.6.
which directed performing step 4.1.5.
l As a result, t1e manual actuation was not reset and section 5.0.
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was not completed.
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Identification and Diagnesjs of RCP_ Seal Failures The examiners identified an applicant knowledge weakness during walkthrough questioning.
The applicants were asked to evaluate a table of second and third stage seal pressures for the RCPs.
The
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applicants were able to identify that the RCP-1C seal
]ressures were abnormal but incorrectly determined which seals lad failed.
c.
Conclusions All of the applicants passed the initial operator licensing examination.
However, there were several individual performance weaknesses.
Some of these weaknesses were accentuated by poor procedures and poor examination materials.
05.2 Examination Develcoment a.
Insoection Scooe The NRC e.xaminers worked with the Crystal River training staff for three months prior to administration of the examination.
The licensee sent a team of training staff members to the Region II office in Atlanta in May of 1997 to discuss examination content with the chief examiner.
This meeting was helpful in identifying and rectifying weak areas in the proposed examination.
The training staff was cooperative in
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incorporating the examiner's feedback into the final examination product.
b.
Observations and Findings Written Examinatjna The NRC examiners reviewed and validated the written examinatici over a period of six weeks.
After an initial review. Operator Licensing management made the decision to continue with the validation of the submitted material, based on the overall quality of the original questions.
However, many changes to the examination were required prior to receiving final NRC a] proval on June 25, 1998.
The training staff l
was very responsive to t1e examiner's comments and were prompt in making
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the necessary corrections.
The quantity of comprehension / analysis questions met NRC standards.
The following is a brief summary of changes:
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100 Questions were submitted to the NRC for review.
Questions were re-written entirely, per NRC requost.
Questions were modified technically.
Questions were administratively changed.
Although the examination was not acceptable for admiriistration as submitted. the number of modifications required to meet NRC standards was consistent with other Region II licensees.
Two post examination comments were submitted for the written examination.
These comments were accepted after NRC review.
Doeratina Examination The examiners reviewed and validated all portions of the operating test during the prep-week of June 5.1998, using the Crystal River simulator and walking down in-plant JPMs.
While administering the walkthrough examination and during the post-examination phase, the examiners identified several deficiencies in the examination material which resulted in questions being deleted, or multiple answers accepted.
Some of the questions had information that was confusing to the applicants and created undue stress.
The following is a compilation of the weaknesses:
1)
JPM NRC10. Question 2, was a gra) hic of the diamond control panel with highlighted indications.
T1e applicants were given plant conditions and required to determine the basis for the Auto inhibit light.
The correct answer was a loss of ICS auto power.
Although this answer was technically correct the graphic provided to the applicants was not representative of indications an operator would expect to see at the given plant conditions.
This resulted in the applicants providing the examiners with incorrect answers and, in general, created confusion. This question was deleted from the examination.
2)
Administrative JPM Al required the applicants to perform an RCS boron change calculation in accordance with OP-304. ' Soluble Poison Concentration Control. Rev.11.
The applicants were given initial and final plant conditions and were required to determine the amount of boric acid needed for the change.
Data for initial and final values for Saxon Xenon Worth were given. The values were -0.013 delta k/k and -0.012 delta k/k respectively.
OP-304 refers to Saxon Xenon L'arth in % delta k/k.
One applicant correctly converted the value to a percentage, hnwever the answer key did riot. The examiners had to work through the calculation manually to determine that the applicant's answer was correct.
The examiners then had to determine whether or not the other three applicants should be downgraded for not providing the correct answer.
The examiners determined that, for examination grading
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purposes, both answers would be accepted.
All applicants
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demonstrated the proper technique for performing a boron change Calculation.
However, during actual plant operations, a mistake of this nature could result in a significant reactivity error, and subsequent undesired reactor plant transient.
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3)
JPM NRC03. question 1. required the applicants to describe the control room indications and Technical Specification (TS)
implication.s following a service water leak into the spent fuel pool which resulted in a final pool level of 158 ft 9 inches.
The answer key stated that annunciators for Spent Fuel Pool Level High and Cask Area Level High would be in alarm and TS 3.9.1 actions should be taken.
The answer key was inaccurate in that no annunciators would be in alarm at this level.
The annunciator should not alarm until +0.5 ft on SF-1-LI1/LI2 which corresponds to 159 ft.
This confused the applicants.
The examiners eventually realized the error and either modified the question or asked follow-up questions regarding when the annunciators should alarm.
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JPM NRC02 question 2. required the applicants to perform a leak
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rate calculation given plant conditions. After the examination.
the examiners questioned why all the applicants came up with the wrong answer.
The chief examiner immediately requested that the I
training staff perform the calculation again.
The next day, the
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training shff informed the chief examiner that the calculation was accurate as stated on the answer key.
Five days later, a post-examination comment was submitted to the NRC describing that the answer key was in error. The answer key was changed to represent the comment.
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Administrative JPM A2 required the applicants to approve a i
clearance order which contained four prescripted errors.
One of l,
the errors was in an item description which read. "FWV-3B" vice the required "FWP-3B~.
Identification of the error was a critical task per the JPM standard.
Although this may be a good trairiing tool, it is a poor evaluation tool.
Failure to perform a critical i
step results in failure of the JPM.
Because of the high weighting of the administrative section of the initial examination, three of the four applicants could have been denied a license based on i
failure to identify a typing error.
The examiners deleted this
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task as a critical step.
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Conclusions l
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The quality of the written examination as an evaluating tool improved
over previous licensee generated examinations. The simulator scenarios
l were modified during 3 rep-week into acceptable evaluating tools. The l
l areas of greatest wea(ness were the walkthrough and administrative
examinations.
The number of errors that were discovered during l'
examination review and administration was high.
Also, several direct look-up questions were submitted initially.
During prep-week, these
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questions were identified by the examiners.
The replacement questions and tasks were not validated and reviewed to the level of detail
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required for an NRC initial examination final submittal.
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t 05.3 Licensee Procedures t
a.
Scope The examiners reviewed licensee procedures during the validation of examination materials, and after the administration of the operating examinations.
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b.
Observations and Findings During the pre-week. and while administering the o)erating examination, the examiners came across six procedure problems tlat could present a challenge to operators.
One of the procedure problems resulted in all i
applicants demonstrating a performance weakness.
This resulted in the failure of a critical task (See section 05.1.b.2).
The examiners
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discussed the task arid procedure problem with NRC management.
It was l
determined that both the applicants and the procedure were deficient.
l However, the applicants would not receive a failir.g grade for the JPM.
Licensee Precursor Card number 3-C98-3185 has been generated to track
the procedure weaknesses.
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Conclusions The examiners were concerned with the number of procedure deficiencies encountered during the initial examination. The number of deficiencies l
discovered is high relative to other Region II initial examinations.
l This was compounded by the fact that, because of the small class size.
l there was a relatively small amount of examination material generated.
Also, this was a repeat experience from the previous examination in June
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of 1997.
The examiners were concerned that the training staff is teaching the applicants how to interpret the procedures and work around problems, instead of revising them.
The procedure deficiency problem l
was particularly significant when applicants became confused or failed l
task.s because of poorly written procedures.
The examiners have opened i
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an inspector follow-up item to track the progress of the procedure modifications.
The hility is tracking these modifications urider Licensee Precursor Card number 3-C98-3185 (IFI-302/98-301-1).
V. Management Meetings XI.
Exit Meeting Summary l
At the conclusion of the site visit, the examiners met with representatives of the plant staff listed below to discuss the results of the examinations and other issues.
The topics of poor applicant performance on the walkthrough questions, piggyback operations during a SBLOCA and the large number of procedure deficiencies were discussed.
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f None of the material provided to the examiners was identified by the licensee as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee J.
Baumstark. Director. Engineering S.
Bernhoft. Licensing T.
Catchpole. Licensing J.
Cowan, Vice President R.
Davis. Operations Director
B.
Hickle. Director. Training I
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Holden. Site Director M.
Kelly. NSS T.
Klyder. Regulatory Compliance J.
Lind. Manager. Operations Training C.
Pardee. Plant Manager W.
Pike. Regulatory Compliance J.
Smith. Supervisor. Operations Training J.
Springer. Supervisor. Nuclear Simulator Training i
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Wilson. Manager Nuclear Plant Operations MC S.
Cahill. Senior Resident Inspector J.
Jaudon, Director. Division of Reactor Safety S.
Sanchez. Resident inspector ITEMS OPENED. CLOSED. AND DISCUSSED OPENED
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302/98-301 01 IFI Various procedure deficiencies
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outlined in PC-C98-3185 (Section l
05.3)
i CLOSED
NONE l
DISCUSSED None I
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LIST OF ACRONYMS USED
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AOP Abnormal Operating Procedure AFW Auxiliary Feedwater ARP Annunciator Response Procedure
CFR Code of Federal Regulations COLR Core Operating Limits Report E0P Emergency Operating Procedure
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EFW Emergency Feedwater DG Diesel Generator IFI Inspector Followup Item JPM Job Performance Measure KA Knowledge and Ability LOCA Loss of Coolant Accident LPI Low Pressure Injection NI Nuclear Instrument NRC Nuclear Regulatory Commission
NRR Office of Nuclear Reactor Regulation I
OTSG Once Through Steam Generator I
RCS Reactor Coolant System RCP Reactor Coolant Pump R0 Reactor Operator RIL Rod Insertion Limits SB Small Break SI Safety Injection SR0 Senior Reactor Operator SRO-I Senior Reactor Operator Instant TS Technical Specification
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SIMULATION FACILITY REPOR1 Facility Licensee:
Florida Power and Light - Crystal River Unit 3 Facility Docket Nos.
50-302 i
Operating Tests Administered on:
June 29 - July 1. 1998
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i This form is to be used only to report observations.
These observatioris do
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not constitute audit or inspection findings and are not, without further j
verification and review. indicative of noncompliance with 10 SCFR 55.45(b).
I These observations do not affect NRC certification or a] proval of the simulation facility other than to provide information tlat may be used in future evaluations.
No licensee action is required in response to these observations'.
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While conducting the simulator portion of the operating tests, the following items were observed -(if none, so state);
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IIf2 DESCRIPTION l
1)
The simulator was not equipped with the licensee's PSAM software. This restricted evaluating the applicant's ability to use the PRA software to the Main Control Room space.
2)-
The RCP vibration monitoring equipment in the simulator does not match the installed equipment in the plant. This created difficulty when evaluating an applicant's ability to respond to a high vibration.
annunciator after starting a RCP.
The annunciator response procedure required the applicant to monitor indications that were not installed on the simulator.
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Enclosure 2
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WRITTEN EXAMINATION AND ANSWER KEY Enclosure 3 J
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Pcwcr CORPORATION oo"cU EoYa"c"2
Operatmg Ucense No. DPR 72 July 6,1998 3F0798-10 Mr. Paul Steiner U.S. Nuclear Regulatory Commission Atlanta Federal Center, Region 11 61 Forsyth Street SW, Suite 23T85 Atlanta, GA 30303 Subject:
Crystal River Unit 3 June 1998 SRO Examination
Dear Mr. Steiner:
Attached you will find the post examination comments for the Senior Reactor Operator (SRO)
examination given at Crystal River Unit 3 (CR-3) the week of June 29, 1998.
These comments are being submitted in accordance with NUREG 1021 ES 501 Section C.I.a.
Florida Power Corporation (FPC) recognizes that this shows short falls in our review process.
We will perform a root cause analysis, prior to August 7,1998, to identify corrective actions to improve our process.
Attachment A contains the requested answer key corrections. Attachment B contains the written examination grading quality assurance checklist.
Attachment C contains the post-examination comment documentation. Attachment D contains the commitment made in this letter.
If you have any questions regarding this letter, please contact Mr. Johnie G. Smith at (352) 795-0504, extension 6107.
Sincerely o n Paul Cos an Vice President Nuclear Operations JPC/jgs Attachments ENCLOSURE 4 CRYSTAL RIVER ENERGY COMPLEX: 15760 W. Power Line Street. Crystal River, Florida 344284708. (352)7954488 A Florida Progress Company
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U.S. Nuclear Regulatory Commission Attachment A 3F0798-10 Page 1 of 2 ATTACHMENT A Requested Answer Key Corrections Justification for Florida Power Corporation's (FPC) requested answer key corrections to two (2) written exam questions and one (1) Job Performance Manual walkthrough question.
1.
Question #54, Correct answer should be "C".
The question originally submitted for NRC approval contained RCS pressure values in each of the four choices. Detail 1 of Step 3.32 of Emergency Operadng Procedure (EOP) 6 requires the operator to maintain minimum adequate SCM.
For the RCS pressure value:; originally supplied, distractors "C" and "D" would have been incorrect due to creating a condition of less than adequate subcooling margin. Answer "A" would havc been incorrect due to no reactor coolant pumps available resulting in no available pressurizer spray. The correct answer would have been "B" under these circumstances.
By removing the RCS pressure values from the choices, the correct answer, per Detail 5 of Step ' 32, is choice "C".
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The answer key should have been changed to reflect this prior to administering the exam.
RECOMMENDATION:
Accept choice "C" as correct answer.
2.
Question #74, Correct answer should be "C".
When determining how far Rod 7-3 was below the group average, API PI panel indication was used instead of API computer indication. This resulted in a value of 6.625% below group average instead cf the correct value of 6.386%.
l While a rough calculation can be made from PI panel indications, the panel lights (PI and Diamond) are actuated from the direct voltage signal supplied to a group average amplifier and an H/L limiter. This signal is displayed on the plant computer and is more accurate than PI panel indication.
API computer values should have been used for this calculation.
RECOMMENDATION:
Accept choice "C" as correct answer.
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U.S. Nuclear Regulatory Commission Attachment A 3F0798-10 Page 2 of 2 3.
Question #NRC02Q2, Correct answer should be 395 gpm.
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. Leak rate estimate should cor.sist of all water being injected into the RCS minus all water being letdown (or removed in a controllable manner) from the RCS.
l This question has Iv.down isolated so all the water _ leaving the RCS is due to the OTSG
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tube leak This calculation should consist only of the following:
a.
MUV-31 flow 130 gpm j
b.
Seal injection now '
41 gpm c.
MUV-24 Dow 200 gpm
d.
Level change in the PZR 2 x 12.2 = 24.4 gpm TOTAL leakage of 395 gpm Contrary to this, the answer key included the change in MUT level as another source of water injection into the RCS. This was in error as the MUT and/or the BWST serve only as a suction source for the Makeup Pumps.
Correct leak rate estimate value should be > 395 gpm.
RECOMMENDATION:
Accept > 395 gpm as correct answer.
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Page 1 of 1 SRO 54)
Licensee Recommendation: The correct answer is C.
NRC Response:
The NRC agrees with the licensee's discussion and accepts answer C as the only correct answer.
SRO 74)
Licensee Recommendation: The correct answer is C.
NRC Response:
The NRC agrees with the licensee's discussion and accepts answer C as the only correct answer.
JPM NRC02 Licensee Recommendation: The answer is 395 gpm.
Question 2 NRC Response:
The answer is 395 gpm.
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Enclosure 5
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