IR 05000339/2013008
| ML13303A637 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, North Anna  |
| Issue date: | 10/30/2013 |
| From: | Widmann M Division of Reactor Safety II |
| To: | Nazar M Florida Power & Light Co |
| Linda K. Gruhler 404-997-4633 | |
| References | |
| IR-13-008 | |
| Download: ML13303A637 (12) | |
Text
October 30, 2013
SUBJECT:
ST. LUCIE NUCLEAR PLANT, UNITS 1 AND 2 - NRC INSPECTION REPORT
NO. 05000335/2013008 AND 05000389/2013008
Dear Mr. Nazar:
On October 9, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the St. Lucie Nuclear Plant, Units 1and 2. The enclosed inspection report documents the inspection results that were discussed on October 9, 2013, with Mr. Michael Baughman and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
One NRC-identified finding of very low safety significance (Green) was identified during this inspection. This finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at St.
Lucie Nuclear Plant Units 1 and 2.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its Enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room, or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), which is accessible from the NRCs Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Malcolm T. Widmann, Chief Operations Branch 1 Division of Reactor Safety
Docket Nos. 50-335 and 50-389 License Nos. DPR-67 and NPF-16
Enclosure:
IR 05000335/2013008 and 05000389/2013008 w/Attachment: Supplementary Information
REGION II==
Docket Nos:
50-335 and 50-389
License Nos:
Report No.
0500033/2013008 and 05000389/2013008
Licensee:
Florida Power and Light Company
Facility:
St. Lucie Nuclear Plant, Units 1 and 2
Location:
6501 Ocean Drive Jensen Beach, FL 34957
Dates:
August 26 - 30, 2013
Inspectors:
G. Laska, Senior Operations Examiner D. Lanyi, Operations Engineer N. Lacy, Operations Engineer (In Training)
Approved by:
Malcolm T. Widmann, Chief Operations Branch 1 Division of Reactor Safety
Summary of Findings
IR 05000339/389/2013008; 08/26/2013 - 08/30/2013; St. Lucie Nuclear Plant; Biennial Requalification Inspection
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green: The inspectors identified a finding associated with the licensees failure to meet training program standards in the development of job performance measures (JPMs) for the licensed operator requalification annual operating tests. The inspectors identified five JPMs, which were administered as part of the 2013 annual operating examination, that were incorrectly designated as alternate path JPMs. Inspectors further identified that one of these JPMs only contained one critical step. A minimum of two critical steps are required by the licensees program standard. Overall, five JPMs, out of a total sample size of 15 (33%), were determined to be inadequate. As part of their immediate corrective actions, the facility licensee entered the issue into the corrective action program as AR-01900809.
This performance deficiency (PD) was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, the PD adversely affected the quality of operating tests for licensed operators, such that during the administration of the annual operating examination, operators were potentially not correctly evaluated. This impacted the licensees ability to evaluate and ensure operator performance to assess and maintain the availability, reliability, and capability of mitigating systems. In accordance with Inspection Manual Chapter (IMC) 0609 Appendix I, the Licensed Operator Requalification Significance Determination Process, this finding was determined to be of very low safety significance (Green) because less than 40 percent of the reviewed JPMs were found to be inadequate. The cause of the finding was directly related to the cross-cutting aspect of personnel training and qualifications in the resources component of the cross-cutting area of Human Performance, in that, the licensee failed to ensure the quality of the operating tests used to evaluate the knowledge, skills, abilities, and training provided to operators to assure nuclear safety. H.2(b)
B.
Licensee-Identified Violations
None
Report Details
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness
1.
REACTOR SAFETY
1R11 Licensed Operator Requalification
a.
Inspection Scope
The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of August 26 - 30, 2013, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses. The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. The inspectors also evaluated the licensees simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-1998, American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination. The inspectors observed two crews during the performance of the operating tests. Documentation reviewed included written examinations, job performance measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, licensed operator qualification records, remediation plans, watchstander records, and medical records. The records were inspected using the criteria listed in IP 71111.11. Documents reviewed during the inspection are documented in the Attachment.
b.
Findings
1. Introduction: An NRC-identified Green finding associated with the quality of job performance measures (JPMs) developed by the licensee for the licensed operator requalification annual operating examination was identified.
Description: Facility licensee procedure TR-AA-220-1004, Licensed Operator Continuing Training Annual Operating and Biennial Written Exams, Section 4.5.1, step 1 states: New JPMs shall be developed using TR-AA-230-1003-F10 Job Performance Measure (JPM) and the guidance found in Appendix C of NUREG 1021 Operator Licensing Examiner Standards. TR-AA-220-1004, Section 4.5.2, step (7)
states: When selecting JPMs for Walkthrough Exams, at least 40 percent of those in each five JPM set should be Alternate Path.
NUREG 1021, Appendix C, Job Performance Measure Guidelines, section B 1, Specify Initial Conditions, paragraph 4, states: Take care to ensure that the initial conditions and initiating cue do not reveal the nature of any alternate path JPMs that are planned.
Section B 4, Develop Examiner Cues, in part, states: Response cues are particularly important in the following situations: Alternate path JPMs that require the examinee to perform auxiliary procedures when equipment, or instrumentation, fails during use.
Appendix C of NUREG 1021 section C, DEVELOPING ALTERNATE PATH JPMs, (1)
Success Path states: Each JPM should have a valid facility-endorsed success path.
This path may require analyzing initial conditions to determine an alternative method for completing the task, mitigating a system-related problem that occurs during the task, or realigning the system.
In summary, an alternate path JPM should be a task that has a failure of a component, or instrument, that fails during use or system realignment, and the initiating cues do not reveal that an alternate path is required.
TR-AA-220-1004, Section 4.5.2, step (6) states: A minimum of two critical steps is required in any JPM.
Analysis: Contrary to St. Lucie training procedures, TR-AA-220-1004 and NUREG 1021, Appendix C, five JPMs used during the 2013 Biennial Requalification Examination were not alternate path JPMs, as described in Appendix C. The JPMs instructed the applicants to verify automatic alignments of equipment using a table from the Emergency Operating Procedures. The tables directed the operator to place equipment in the designated position/condition, if it was not originally correctly aligned. This essentially cued the applicants that something was out of position, or the JPM would have no action, and therefore nothing to evaluate. All of these JPMs would cue the operator of mispositioned components. Furthermore, one of the JPMs designated as alternate path also contained only 1 critical step.
Contrary to St. Lucie training procedures, TR-AA-220-1004, for one JPM used during the 2013 licensed operator requalification examination, the licensee failed to ensure that the JPM contained an appropriate level of difficulty, in that it only contained 1 critical step.
The inspectors determined these deficiencies represented a performance deficiency (PD). The PD was determined to be more than minor because it was associated with the Human Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, the PD adversely affected the quality of operating tests for licensed operators. This impacted the licensees ability to evaluate and ensure operator performance to assess and maintain the availability, reliability, and capability of mitigating systems.
The instructions block of the Requalification Job Performance Measure Review Worksheet in Appendix C of IP 71111.11, directs that the inspectors verify at least 40 percent of the JPMs, per JPM set, are alternate path. This block was checked NO.
Appendix C of IP71111.11 states: If any block in this checklist is checked NO, these items shall be considered a performance deficiency against the expected quality standards for a licensed operator requalification operating test required by 10 CFR 55.59(a)(2), and as a possible finding.
The significance determination was performed in accordance with IMC 0609, Significance Determination Process, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP). Question 6, in Appendix I, asked if the finding was related to annual requalification operating test quality. The answer to this question was YES because, in accordance with section Appendix C of IP 71111.11, two out of five JPMs, in each JPM set, are required to be alternate path. Four out of the seven sets of JPMs would have contained less than 40 percent alternate path JPMs.
Block 7 asked if greater than 40 percent of the reviewed JPMs flawed, and this was answered NO. Block 8 asked if greater than 40 percent of the reviewed simulator scenarios flawed, and this was answered NO. Consequently, this finding was characterized as having very low safety significance (Green).
The cause of the finding was directly related to the cross-cutting aspect of personnel training and qualifications in the Resources component of the cross-cutting area of Human Performance, in that the licensee failed to ensure the quality of the operating tests used to evaluate the knowledge, skills, abilities, and training provided to operators to assure nuclear safety. H.2(b)
Enforcement: NRC regulations require that licensed operators pass an annual operating examination and a biennial written examination; however, the regulations do not specify the quality of examination material. Therefore, no violation of regulatory requirements occurred. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. The facility licensee entered this issue into their corrective action program (AR-01900809). Because this finding does not involve a violation of regulatory requirements, and has very low safety significance (Green), it is identified as a Finding (FIN). (FIN 050000395/2013008-01, Failure to Meet Training Program Standards on Job Performance Measures for the Annual Licensed Operator Requalification Operating Examination)
4OA6 Exit
An exit meeting was initially conducted on August 30, 2013, to discuss the findings of this inspection. On October 9, 2013, the inspectors conducted a phone exit to discuss changes in the original findings due to new IOLB interim guidance for IP 71111.11, and additional information provided by the licensee. The inspectors confirmed that no proprietary information was reviewed during this inspection.
ATTACHMENT: Supplementary Information
Attachment
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
M. Baughman, Training Manager D. DeBoer, Operations G. Blinde, Fleet Operations Training C. Bible, Director Engineering D. Cecchett, Licensing R. Coffey, Plant General Manager S. Feemster, Operations Training Supervisor J. Fern, Operations J. Jensen, Site Vice President E. Katzman, Licensing Manager J. Owens, Operations Training Manager P. Rasmus, Assistant Operations Manager M. Snyder, NOS Manager M. Page, Outage R. Webber, Operations Assistant Operations Manager Support
NRC personnel
T. Morrissey, Senior Resident Inspector R. Reyes, Resident Inspector
Items Opened, Closed, and Discussed
Opened and Closed 05000395/2013008-01 FIN Failure to Meet Training Program Standards on Job Performance Measures for the Annual Licensed Operator Requalification Operating Examination
List of Documents Reviewed
Records:
License Reactivation Packages (6)
LORP Training Attendance records Medical Files (14)
Remedial Training Records (3)
Remedial Training Examinations (2)
Simulator Problem Reports & Design Change Requests (7)
Written Examinations:
0820BWEA-R RO Exam A, Revision 0, 11/11/2012 0820BWEA-S SRO Exam A, Revision 1, 11/08/2012 0820BWED-R RO Exam D, Revision 0, 12/03/2012 0820BWED-S S RO Exam D, Revision 0, 12/03/2012 0820BWER-R RO Remedial Exam Revision 0, 12/12/20012 0820BWER2-R RO Second Remedial Exam Revision, 2/15/2013
Procedures:
TG-004, Examination Development, Administration, and Control, Revision 30 TR-AA-104, Nextera Energy Fleet Licensed Operator Continuing Training Program, Revision 3 TR-AA-220-1002, NRC Licensed Operator Exam Security, Revision 0 TR-AA-220-1004, Licensed Operator Continuing Training Annual Operating and Biennial Written Exams, Revision 0 TR-AA-230-1007, Conduct of Simulator Training and Evaluation, Revision 0 TR-AA-230-1008, Simulator Scenario Based Testing and Evaluation, Revision 0 TR-AA-230-1009, Training Examination Security, Revision 0 NAP-408, License Maintenance and Activation, Revision 10 SEI-01, Simulator Fidelity and Performance Standards, Revision 3 SEI-07, Simulator Operability Testing and Evaluation, Revision 6
Simulator ARs:
Closed:
AR-01866458, A LBLOCA with LOOP Caused Simulator to Abort AR-01866460, Delta T Power is too low on the Simulator
Open:
AR-01888248, Simulator-Throttle Valve Stuck Open During Training Session AR-01875182, Simulator-2A S/G Level Rises with No Feed Flow AR-01822492, Simulator-Reactor Trip During Rod Swap Testing AR-01894458, Simulator-The B CR A/C Unit Does Not Start On A CIAS Signal
Simulator Transient Tests:
TRN-001, Revision 9, Reactor Trip TRN-002, Revision 9, Loss of Main Feed Water pumps from 100% power with failure of all Emergency Feed Water TRN-003 Revision 8, Simultaneous Closure of Both MSIVs
Scenario Based Tests:
SBT for 0821010, Revision 20 (8/15/2013)
SBT for 0821024, Revision 15 (8/15/2013)
SBT for 0815007, Revision 13 (8/09/2013)
Scenarios Reviewed:
0815006, Feedwater Break, Partial Loss of Power, Revision 20 0815007, Station Blackout, Revision 13 0815008, Loss of Offsite Power, Small Break LOCA, Revision 17 0815009, LOOP, Total Loss of Feedwater, Once Through Cooling, Revision 18 0815010, Feed Water Issues, SGTL, SGTR, Revision 20 0815011, RCS Leak, Complicated Post Trip ESDE, Revision 9 0815021, ESDE with a Loss of RCS Inventory, Revision 13 0815024, CCW N Header Leak, LOOP and Feed Line Break in Containment, Revision 15 0815034, Small Break LOCA with Partial LOOP, Loss of HPSI, Revision 8 0815048, Station Blackout Recoverable, Revision 3
JPMs Reviewed:
0821009A, Verify RAS-Unit 1, Revision 10 0821010A, Verify RAS - Unit 2, Revision 19 0821013A, Verify CSAS - Unit 1, Revision 12 0821014A. Verify CSAS - Unit 2, Revision 11 0821016A, Verify MSIS - Unit 2, Revision 16.
0821025, Align ECCS for Hot and Cold Leg Injection - Unit 1, Revision 15 0821026A. Manually Initiate RAS - Unit 2, Revision 15 0821033, Locally Close MSIV During CRI - Unit 1, Revision 18.
0821044, Respond to Abnormal Pressurizer Level Control - Unit 2, Revision 17 0821048, Respond to a Leaking Power Operated Relief Valve - Unit 2, Revision 19 0821054, Locally Operate 1C Auxiliary Feedwater Pump - Unit 1, Revision 20 0821055, Check 2C AFW Pump for Steam Binding, Revision 19 0821064,Operate Local Power Supplies to Isolate Safety Injection Tanks - Unit 2, Revision 17 0821112T, Respond to CEA Continuous Gripper Hi Voltage Alarm - Unit 2, Revision 11 0821191,Locally Close 1A MSIV - Unit 1, Revision 7
Other documents Reviewed:
AR-01836258, Licensed Operator Exceeded Annual Training Requirements Apparent Cause Evaluation for Condition Report #01836258 SL-2 WCAP-17489-NP, Combustion Engineering Emergency-Procedure-Guideline-Based Simulator Critical Tasks, Revision 0