IR 05000348/2005301
| ML050680173 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/08/2005 |
| From: | Moorman J Division of Reactor Safety II |
| To: | Stinson L Southern Nuclear Operating Co |
| References | |
| 50-348/05-301, 50-364/05-301 | |
| Download: ML050680173 (13) | |
Text
rch 8, 2005
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC EXAMINATION REPORT 05000348/2005301 AND 05000364/2005301
Dear Mr. Stinson:
During the period January 10 -14, 2005, the Nuclear Regulatory Commission (NRC)
administered operating examinations to employees of your company who had applied for licenses to operate the Farley Nuclear Plant. At the conclusion of the examination, the examiners discussed the examination questions and preliminary findings with those members of your staff identified in the enclosed report. The written examination was administered by your staff on January 18, 2005.
Two Reactor Operator (RO) applicants and three Senior Reactor Operator (SRO) applicants passed the examination. Three SRO applicants failed the written examination. One SRO applicant failed the operating test. A Simulation Facility Report is included in this report as Enclosure 2. There were four post examination comments. These comments are summarized in Enclosure 3. The NRC Form 398 applications submitted prior to the examination contained numerous errors. Corrected copies of these forms were resubmitted on January 10, 2005. The operating tests were delayed in starting for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to allow for the NRCs final review and approval of the applications.
In accordance with 10 CFR 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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this letter, please contact me at (404) 562-4647.
Sincerely,
/RA/
James H. Moorman, III, Chief Operator Licensing Branch Division of Reactor Safety Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8
Enclosures:
(See page 2)
SNC 2 Enclosures: 1. Report Details 2. Simulation Facility Report 3. Response to Post Exam Comments
REGION II==
Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8 Report No.: 050000348/2005301 and 050000364/2005301 Licensee: Southern Nuclear Operation Company, Inc. (SNC)
Facility: Joseph M. Farley Nuclear Plant Location: 7388 N. State Highway 95 Columbia, AL 36319 Dates: Operating Tests - January 10 - 14, 2005 Written Examination - January 18, 2005 Examiners: R. Aiello, Chief License Examiner S. Rose, Senior Operations Engineer M. Bates, Operations Engineer C. Moore, Examiner Trainee, R III Approved by: J. Moorman, Chief Operator Licensing Branch Division of Reactor Safety Enclosure 1
SUMMARY OF FINDINGS ER 050000348/2005301 and 050000364/2005301; 1/10 -14/2005 and 1/18/2005; Joseph M.
Farley Nuclear Plant; Licensed Operator Examinations.
The NRC examiners conducted operator licensing initial examinations in accordance with the guidance of NUREG-1021, Revision 9, 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.
The NRC administered the operating test January 10 - 14, 2005. The Farley training staff administered the written examination on January 18, 2005. All of the outlines, the written examination, Job Performance Measures (JPMs) and scenarios were developed by the Farley training staff. Two Reactor Operator (RO) applicants and three Senior Reactor Operator (SRO)
applicants passed the examination. Three SRO applicants failed the written examination. One SRO applicant failed the operating test. One RO and two SRO applicants who passed both the operating test and the written examination with overall written scores greater than 82 percent were issued operator licenses commensurate with the level of examination administered. One RO applicant and one SRO applicant passed the operating test and scored between 80 and 82 percent on the written examination. These applicants were issued letters notifying them that they passed the examination and that issuance of their license has been delayed pending any written examination appeals that may impact the licensing decision for their application.
Enclosure 1
Report Details 4. OTHER ACTIVITIES 4OA5 Operator Licensing Initial Examinations a. Inspection Scope The licensee developed operating tests and written examinations in accordance with NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9. The NRC examination team reviewed the proposed examinations.
Examination changes agreed upon between the NRC and the licensee were made according to NUREG-1021 and incorporated into the final version of the examination materials.
The examiners reviewed the licensees examination security measures while preparing and administering the examinations to ensure examination security and integrity complied with 10 CFR 55.49, Integrity of examinations and tests. Two Reactor Operator (RO) and seven Senior Reactor Operator (SRO) applicants were assessed under the guidelines specified in NUREG-1021. The examiners administered the operating tests during the period of January 10-14, 2005. Members of the Farley Nuclear Plant training staff administered the written examination on January 18, 2005. The evaluations of the applicants and review of documentation were performed to determine if the applicants, who applied for licensees to operate the Farley Nuclear Plant, met requirements specified in 10 CFR 55, Operators Licenses.
b. Findings Two RO applicants and three SRO applicants passed the examination. Three SRO applicants failed the written examination. One SRO applicant failed the operating test.
One RO and two SRO applicants who passed both the operating test and the written examination with overall written scores greater than 82 percent were issued operator licenses commensurate with the level of examination administered. One RO applicant and one SRO applicant passed the operating test and scored between 80 and 82 percent on the written examination. These applicants were issued letters notifying them that they passed the examination and that issuance of their license has been delayed pending any written examination appeals that may impact the licensing decision for their application.
The licensee submitted four post examination comments concerning the written examination. The RO and SRO written examinations and answer keys, examination references and licensees post examination comments may be accessed in the ADAMS system (ADAMS Accession Numbers ML050560145, ML050560153, and ML050560083).
Enclosure 1
The NRC determined that the overall examination submittal was within the acceptable quality range expected by the NRC. The examination changes agreed upon between the NRC and the facility were made in accordance with NUREG-1021.
The applications submitted on NRC Form 398 had numerous errors; therefore, the facility was requested to resubmit the applications. As a result, the operating test was delayed for approximately one hour after the examiners arrived on site to allow for the NRCs final review of the applications.
Applicants received unsatisfactory evaluations on five administrative JPMs, seven simulator JPMs, and one in-plant JPM.
The exam team noted a number of generic weaknesses during the simulator portion of the operating test. Several applicants demonstrated a weakness in the ability to locate and manipulate controls in an accurate and timely manner. There were a number of cases where procedural continuous action steps were not effectively tracked. Several applicants had difficulty determining the correct action to take if the actions of an emergency operating procedure Response Not Obtained step could not be accomplished. Some applicants abandoned the procedures completely and operated equipment from memory. Some candidates did not consistently utilize annunciator response procedures. Applicants also demonstrated a significant lack of system knowledge.
4OA6 Meetings Exit Meeting Summary On January 14, 2005, the examination team discussed the generic weaknesses with Mr. John Horn and members of his staff. The inspectors asked the licensee whether any materials reviewed during the examination should be considered proprietary. No proprietary information was identified.
PARTIAL LIST OF PERSONS CONTACTED Licensee personnel R. Wells, Shift Manager J. Powell, Senior Instructor T. Youngblood, Assistant General Manager Support V. Richter, Instructor R. Tyler, Engineering Support Supervisor D. Christensen, Operations Training Supervisor J. Horn, Training and Emergency Preparedness Manager R. Johnson, General Manager G. Ohmstede, Instructor R. Martin, Operations Manager B. Oldfield, QA Supervisor K. Moore, QA Engineer Enclosure 1
NRC personnel C. Patterson, Senior Resident Inspector R. Fanner, Resident Inspector J. Moorman, Chief, Operator Licensing Branch Enclosure 1
SIMULATION FACILITY REPORT Facility Licensee: Farley Nuclear Plant Facility Docket Nos.: 05000348 and 05000364 Operating Tests Administered on: January 10 - 14, 2005 This form is to be used only to report observations. These observations do not constitute audit or inspection findings and are not, without further verification and review, indicative of noncompliance with 10 CFR 55.45(b). These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluations. No licensee action is required in response to these observations.
No fidelity or configuration items were identified or observed while conducting the simulator portion of the operating tests.
Enclosure 2
Farley 2005-301 NRC Response to Licensee Post Exam Comments.
A complete text of the licensees post-exam comments can be found in ADAMS under Accession Number ML050560145.
RO Test Question 20:
The facility contends that during a normal shutdown, Group Rod Position Indication(GRPI) step counters are run down to zero along with the P-A converter. At C-114, the RIL Lo and Lo-Lo annunciators will come into alarm. During the subsequent startup, when the ROD CONTROL STARTUP RESET switch is placed in the RESET position, these annunciators will NOT actuate since they are already in alarm (in solid) due to the fact that the P-A converter is already at zero and the step counters are also at zero steps.
When a reactor trip occurs, the GRPI counters and the P-A converter will be at the last known rod position. In this condition the RIL Lo and Lo-Lo annunciators will NOT be in alarm due to the P-A converter still indicating rods at the post trip condition and the RIL computer determining the limit to be at the zero power limit of C-114.
During the subsequent reactor startup when the ROD CONTROL STARTUP RESET switch is placed in RESET position, the RIL Lo and Lo-Lo alarms will come into alarm since the P-A converter is reading D-230 and is being reset to zero telling the RIL computer the rods are at zero steps (indicating that the control banks are at zero steps) and the computed RIL being at the zero power limit of C at 114 steps.
This question is asked from the standpoint that the GRPI counters are at the full power position and no other actions have been completed because GRPI is not reset. One has to assume that the rod position Lo and Lo-Lo alarms are NOT in at this time due to the above discussion. This would be expected for a reactor trip recovery since GRPI is in the at power position. Therefore the annunciators WILL come into alarm when the ROD CONTROL STARTUP RESET switch is placed in RESET position.
The Facility recommends accepting both A and D as being correct answers.
The Facilitys recommendation is accepted. The facility stated that this question was initially written as being at 100% power and when the ROD CONTROL STARTUP RESET switch is taken to the RESET position, what will happen? During the validation process the validators commented that this question was too hard (level 5) because it put the applicant in a situation resulting from a mistake on the MCB. Under these initial conditions and as directed by UOP-1.3, Unit Startup Procedure, the rod position Lo and Lo-Lo annunciators will NOT be in alarm until the ROD CONTROL STARTUP RESET switch is placed in the RESET position.
Therefore, answers A and D are BOTH correct.
RO Test Question 20 answer key changed to accept answers A and D.
Enclosure 3
RO Test Question 42:
The facility contends that an alternate way to analyze the question was to approach it in the procedural verification mode. The facility stated that this method is reinforced by the wording of the stem with the following items:
- The Diesel Generator (DG) was being started IAW ECP-0.0, Loss Of All AC Power.
- Which one of the following statements is correct that will ensure 2C DG is running properly with service water supplied after the start pushbutton is depressed?
These applicants took the question to mean procedurally how the operator would verify that the 2C DG is running properly with service water. The facility stated that these actions were fresh in their minds since one exam simulator scenario and an active JPM had them start the 2C DG in the Station Blackout (SBO) mode.
At FNP, the term VERIFY means to observe that an expected condition exists and take action to establish the condition if it does not exist. Each step in ECP-0.0 has the word VERIFY at the beginning of the steps. The term ENSURE means to "To make sure or certain." The applicant was asked to make sure or certain that the 2C DG is running properly with SW supplied IAW ECP-0.0. The distractors have the words check a breaker automatically closes or to close the breaker. The facility contends that if the candidate performed the actions as written in A and B, a success path is identified that is procedurally correct due to the way the terms ENSURE and VERIFY are defined in FNP-0-SOP-0.8, Attachment 1, Glossary of Terms and Actions Verbs.
The Facilitys recommendation is accepted. Performing the actions of some of the distractors will act to ensure that the DG is running properly with proper support system operation. The question will be deleted due to the apparent ambiguity between the stem and the distractors with respect to ENSURE and VERIFY.
RO Test Question 42 was deleted from the exam.
RO Test Question 54:
The facility contends that the stem used the wording of "unsafe condition" as the driving force behind taking some action. The facility stated that 3.5% by itself does not constitute an unsafe condition.
Based on the TRM, section 13.12.3, this oxygen concentration would only be out of spec if hydrogen exceeded 4%. Since the hydrogen concentration is not given, one can assume that the TRM conditions are satisfied.
The facility also stated that the question also asks the REQUIRED actions. Since no hydrogen limit is exceeded; no action is required for the stated conditions.
The Facility recommends deleting this question due to all distractors being procedurally correct.
Enclosure 3
The Facilitys recommendation is accepted. NUREG 1021, Appendix E, Part B, Paragraph 7 states: 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 question failed to state the hydrogen concentration. Explosive limits are NOT placed on the waste gas decay tanks if hydrogen concentration is less than 4%.
Since hydrogen concentration is not specified in the stem, one must assume that it is within specification.
If hydrogen concentration was less than 4%, then releasing the tank is NOT needed to prevent an unsafe condition. In the case where hydrogen concentration is less than 4%, many options are available, which may not create an unsafe condition. Additionally, you could contend that there is not enough information in the stem to know that releasing the tank after nitrogen dilution will prevent an unsafe condition. In other words, in order to make releasing the tank necessary to prevent an unsafe condition, then not releasing the tank must cause an unsafe condition. The stem fails to provide enough information for the applicant to determine that.
Therefore, one could contend that there is either no correct answers or multiple correct answers. The question will be deleted due to the fact that there are more than two correct answers or no correct answers, depending on ones view.
RO Test Question 54 was deleted from the exam.
RO Test Question 65:
The facility contends that both responses "A" and "B" are correct depending on factors that are not provided in the stem of the question. A review of plant and NRC Health Physics policies and Reg. Guides revealed the following:
From the Floor Walk Down checklist posted on the health physics home page - Minimize the size of each area posted to just the area affected (e.g. If just 1 corner of a room is a High Radiation Area, only post that portion of the room as a HRA and not the entire room). This would justify "A" as the correct response for a larger room. Since the High Radiation Area (HRA) posting would only be required at a distance of 1.5 ft. from the source (boundary of 100 mrem/hr field), it would not necessarily require posting the entrance to the room as a HRA. In this question the entrance is four feet away.
From Regulatory Guide 8.3.8, Control of Access to High and Very High Radiation Areas Section 2.5 - Controls (e.g., locked doors, access control, and posting) for high radiation areas may be established at locations beyond the immediate boundaries of high radiation areas to take advantage of natural or existing barriers. Smaller rooms, rooms where access is restricted due to other reasons (i.e. contamination levels) or rooms that has physical limitations that preclude posting the HRA at is smallest possible boundary are routinely posted at their entrance. Since this information was also not given in the stem, this could also lead one to pick response "B" as a conservative answer.
The Facility recommends accepting both A and B as being correct answers.
Enclosure 3
The facilitys recommendation is not accepted. Since the facilitys Floor Walk Down checklist posted on the health physics home page states, in part, Minimize the size of each area posted to just the area affected. (e.g. If just 1 corner of a room is a High Radiation Area (HRA), only post that portion of the room as an HRA and NOT the entire room.), the size of the room becomes irrelevant.
Calculations:
Valve is 4 feet from door.
DR = 200 mrem/hr at 1 foot from valve.
(200 mrem/hr)(1/x2)=100 mrem/hr x2 = 2 X = 1.414 (Assume 1.5 feet)
1 foot + 1.5 feet = 2.5 feet DR = 100 mrem/hr at 2.5 feet from valve. Therefore, 100 mrem is 1.5 feet from the door.
Based on the calculation and the facilitys Health Physics (HP) web page statement, Answer A is the only correct answer. Therefore, the facilitys comment is NOT accepted.
RO Test Question 65 answer has been changed from B to A.
Enclosure 3