IR 05000338/2020301
| ML20260H330 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/16/2020 |
| From: | Gerald Mccoy Division of Reactor Safety II |
| To: | Stoddard D Virginia Electric & Power Co (VEPCO) |
| References | |
| 50-338/20-301, 50-339/20-301 | |
| Download: ML20260H330 (12) | |
Text
September 16, 2020
SUBJECT:
NORTH ANNA POWER STATION - NRC OPERATOR LICENSE EXAMINATION REPORT 05000338/2020301, 05000339/2020301
Dear Mr. Stoddard:
During the period August 3 - 7, 2020, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the North Anna Power Station. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating tests with those members of your staff identified in the enclosed report. The written examination was administered by your staff on June 24, 2020.
One SRO failed the SRO portion of the written examination. There was one post-administration comment concerning the written test. The comment, and the NRC resolution of the comment, is summarized in Enclosure 2. A Simulator Fidelity Report is included in this report as Enclosure 3.
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 11.
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: 50-338, 50-339 License Nos: NPF-4, NPF-7
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
ML20260H330 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS
NAME P. Capehart J. Viera N. Lacy J. Bundy G. McCoy
DATE 9/15/2020 9/15/2020 9/15/2020 9/15/2020 9/16/2020
E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Enclosure 1
Docket No.:
50-338, 50-339
License No.:
Report No.:
05000338/2020301, 05000339/2020301
Enterprise Identifier L-2020-OLL-0024
Licensee:
Virginia Electric and Power Company (VEPCO)
Facility:
North Anna Power Station, Units 1 & 2
Location:
Mineral, VA
Dates:
Operating Test - August 3 - 7, 2020
Written Examination - July 24, 2020
Examiners:
P. Capehart, Chief Examiner, Senior Operations Engineer
J. Viera, Operations Engineer
N. Lacy, Operations Engineer J. Bundy, Operations Engineer
Approved by:
Gerald J. McCoy, Chief
Operations Branch 1
Division of Reactor Safety
SUMMARY
ER 05000338/2020301, 05000339/2020301, 000474/05000338/L-2020-OLL-0024, 000474/05000338/L-2020-OLL-0024; operating test August 3-7, 2020 and written examination July 24, 2020; North Anna Power Station; Operator License Examinations.
Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 11 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.
The operating tests and the written examination were developed by the NRC.
The NRC administered the operating tests during the period August 3-7, 2020. Members of the North Anna Power Station training staff administered the written examination on July 24, 2020.
All Reactor Operator (RO) and five Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO failed the SRO portion of the written exam.
All applicants were issued licenses commensurate with the level of examination administered.
There was one post-examination comment.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
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 August 3-7, 2020. The NRC examiners evaluated five Reactor Operator (RO) and six Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. Members of the North Anna Power Station training staff administered the written examination on July 24, 2020. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the North Anna Power 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 North Anna Power 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 11, 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 written examination submittal was within the range of acceptability for the RO exam; however, it was outside the range of acceptable quality for the SRO exam because more than 20% of questions in the SRO Only portion of the exam contained unacceptable flaws. Individual questions were evaluated as unsatisfactory for the following reasons:
- Four questions failed to meet the K/A statement contained in the examination outline.
- Two questions contained two or more implausible distractors.
- Two questions contained other unacceptable psychometric flaws (subset issues).
The NRC regional office worked with the licensee to correct these issues and there was no delay in administration of the exam. Future examination submittals need to incorporate lessons learned.
Administration of the written examination and the operating test diverged by more than 30 days because of issues associated with COVID-19. The NRR operator licensing program office concurred with the NRC regional office decision to administer the operating test and written examination more than 30 days apart.
All applicants passed the operating test. One SRO failed the SRO portion of the written examination. Five RO applicants and five SRO applicants 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 licensee submitted one post-examination comment concerning the written test. A copy of the final written examination and answer key, with all changes incorporated, and the licensees post-examination comment may be accessed not earlier than August 8, 2023, in the ADAMS system (ADAMS Accession Number(s) ML20254A293, ML20254A324, and ML20254A347).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On August 7, 2020, the NRC examination team discussed generic issues associated with the operating test with Mr. James Jenkins, Director of Nuclear Station Safety &
Licensing, and members of the North Anna Power 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. Allen, Senior Instructor (Exam Author)
B. Chang, Supervisor Nuclear Training (Training Support)
T. Fulton, Supervisor Nuclear Training (Operations)
C. Hickory, Senior Instructor (Exam Author)
J. Jenkins, Director Nuclear Station Safety & Licensing J. Russell, Manager Nuclear Training B. Scott, Manager Nuclear Operations A. Stephens, Senior Instructor (Lead Instructor)
E. Vestre, Nuclear Plant Manager (acting)
C. Werneke, Station Licensing Manager (acting)
NRC personnel
M. Tobin, Senior Resident Inspector
FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the licensees post-examination comments can be found in ADAMS under
Accession Number ML20254A347.
Item
SRO QUESTION #95, K/A 2.1.4 - GENERIC - Conduct of Operations
Knowledge of individual licensed operator responsibilities related to shift staffing, such as
medical requirements, no-solo operation, maintenance of active license status, 10CFR55, etc.
(CFR: 41.10 / 43.2)
Question: 95
A Senior Reactor Operator, with a NO-SOLO License due to a medical condition, is
currently providing oversight for a Reactor Operator, also with a NO-SOLO license,
who is performing a control manipulation.
Based on the above conditions (No Solo) another SRO is required to be ___(1)___
and another RO is required to be ___(2)___.
A.
(1) in view of the no solo SRO
(2) in view of the no solo RO
B.
(1) on site
(2) on site
C.
(1) on site
(2) in view of the no solo RO
D.
(1) in view of the no solo SRO
(2) on site
Answer: C
Comment:
The candidates contest the lack of clarity in the stem of the question and recommend deleting
the question from the exam due to multiple correct answers.
Basis:
1. This question asks the examinee to identify what requirement must be met for a NO-
SOLO licensed RO to perform control manipulations in the control room when the SRO
is also a NO-SOLO licensed and also ask for the requirements for the NO-SOLO SRO in
the control room observing the NO-SOLO RO.
2. The correct answer is taken directly from NUREG-1021 ES-605C.3.c, bullet 3:
An RO who is at risk of sudden incapacitation may have a no-solo restriction that
requires another licensed operator to be in view when the restricted operator is
performing control manipulations and someone capable of summoning assistance to be
present at all other times while the restricted operator is performing licensed duties.
The analogous SRO restriction would require another licensed operator to be in view
when the restricted operator is performing control manipulations and another senior
operator to be present on site at all other times while the restricted operator is
performing SRO licensed duties or someone capable of summoning assistance to be
present at all other times while the restricted operator is performing RO licensed duties.
Facility Licensee Position:
1. The licensee and applicants argue that the other answer choices could be considered
correct. The other answer choices are a combination of both the RO and SRO having
another RO and SRO in view of them (Choice A), having another RO and SRO on
site (Choice B), or to have another SRO in view of the no-solo SRO and another RO
on site (Choice D). Listed below is a compilation of remarks stated by the applicants
with agreement by the licensee as to why there are multiple correct answers:
i)
Per NRC Guidelines, an SRO is also qualified to perform RO Duties.
ii) OP-AA-300, Reactivity Management, requires an extra SRO for planned control
manipulations.
iii) The Stem of the Question does not specify whether the control manipulation is a
simple Boration or Dilution for Temperature control, a Plant Ramp, taking the
reactor critical, or a performance test. Since all of these are activities are associated
with normal plant operations the answer must be universally acceptable.
iv) If the NO-SOLO SRO overseeing control manipulations becomes incapacitated, the
RO cannot assume the License Duties of the NO-SOLO SRO while the NO-SOLO
RO completes the control manipulation and the On-Site SRO is called to the Main
Control Room. If the plant were in a condition where additional control
manipulations were required due to Xenon, Equipment Failures, or Operator Error,
the lack of an SRO for the period of time it would take to arrive in the Main Control
Room (assume < 15 minutes) could place the unit in a more unstable condition.
v) The Stem of the Question does not specify whether the question is testing the
minimum federal requirements or the station requirements. Normally it would be
assumed to test plant standards.
vi) Answer A could be correct since the stem specified that both the RO and SRO have
a NO-SOLO designation. NUREG-1021, Rev. 11 requires another licensed operator
to be in view when the restricted operator is performing control manipulations. This
could be understood to mean that another SRO must be in view of the individuals
performing and observing the control manipulation.
vii) Answer B could be correct if the NO-SOLO SRO is considered the licensed
operator in view of the NO-SOLO RO performing the control manipulation.
Additionally, NUREG-1021, Rev.
allows another SRO to be present on site at all other times while the restricted
operator is performing SRO licensed duties, providing oversight for a RO would be
considered a licensed duty for an SRO.
viii) Answer D could be correct considering 10 CFR 55.59 precludes control
manipulations from being made without an SRO present. If a NO-SOLO RO
becomes incapacitated with an extra NO-SOLO SRO in sight and an extra RO on
site, then one of the SROs could fill the licensed RO duties while still maintaining an
SRO available for oversight.
NRC Resolution:
The licensees recommendation was rejected. The NRC disagrees with the licensee that the
question should be deleted.
In the cases denoted in the above contentions, the applicant would need to make assumptions
outside of the question to make the other choices plausible. NUREG Appendix E states that
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. The applicants should NOT assume that the control manipulation was of a
specific size or duration that mandated another SRO be present; the stem of the question
specified that the context of the question was only related to no-solo requirements, not the
magnitude of the control manipulation.
The licensee stated that they have no lesson objective that covers this specific K
Section D.2.g states A technical reference,. And a cross-reference to the facility licensees
exam question bank, if applicable, shall be noted for every question. If the facility licensee has
a learning objective applicable to the question, it should also be referenced. However, the
absence of a learning objective does not invalidate the question, provided that it has an
appropriate K/A and technical reference. The site does not have a plant standard that covers
the no-solo topic and wrote the question using NUREG-1021 as the technical reference for this
question.
Answer A cannot be considered correct because the no-solo SRO is required only to have
another SRO on site assigned to fulfill his duties if he becomes incapacitated. He does not
have to be in view of the no-solo SRO.
Answer B cannot be considered correct because the no-solo RO is required to have another
RO in view as a minimum criterion.
Answer D cannot be considered correct for the same reason as given in choice A. The no-
solo SRO is only required to have another SRO on site, not another SRO in view of him.
SIMULATOR FIDELITY REPORT
Facility Licensee: North Anna Power Station
Facility Docket No.: 50-338, 50-339
Operating Test Administered: August 3-7, 2020
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.